Privacy Policy

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Last Updated: April 3rd, 2025

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We are committed to providing quality services and a safe environment to users. The aim of this Privacy Policy is to inform users ("you" or "user") about how Whale TV PTE. LTD. ("we," "us," or "our") processes your personal information when you use our website ("website") and other applications, services, and offerings (collectively referred to as "app") provided by Whale TV PTE. LTD., headquartered at 6 RAFFLES QUAY #14-02, Singapore (048580), as the data controller responsible for data protection. Unless specifically stated otherwise, the information provided in this Privacy Policy applies to both our services and the website.

This Privacy Policy provides an overview of what personal information is collected and how it is processed when you use the website, app, or related services, as well as a summary of your rights concerning your personal information and how you can exercise them. "Personal information" refers to any information that can be used to identify you personally.

For further details on how we handle your personal information, please refer to the additional information provided in the sections below.

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Why We Collect Information

To enable building of better services and improvement of our services, we need to collect your personal information. Personal information collected by us is used for the following purposes:

• Support and maintenance: to provide you with quality and maintenance services, and to handle and meet your requirements.
• Improve our products and services: we use your information to make improvements in our products and services.
• Develop new services: we use the information we collect in existing services to help us develop new ones.
• Service communications and customer cares.
• Protect users, the public and us: we use collected information to help improving safety and reliability of our services. This includes protecting, detecting and deterring fraudulent, unauthorized, infringing or illegal activities that could harm us, our users or the public.
• To comply with the law and legal processes.

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Information We Collect

We process the following categories of personal data:

• Information You Provide: You may provide us with personal information when you register an account, subscribe to our Services, or communicate with us, such as your name, email address, phone number, and payment information.
• Automatically Collected Information: We may automatically collect information related to your use of our Services, such as such as country, IP address, device information, usage information (e.g., device ID, unique identifiers, browser information, pages visited, last URL visited), as well as your preferences and settings.
• Device Information: When you use products and services, we may collect device information when you use our services. We may collect your hardware model, firmware and operating system version, unique device identifiers, time and date of server accessing, error logs, crash reports, software version numbers.
• Information from Third-Party Sources: We may receive personal data about you from third-party sources, such as social media platforms or partners, to supplement the information we collect.

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What do we use your Privacy Information for?

We process your personal information primarily to provide you with our services and to ensure that our website and services function correctly. Additionally, we use your data to improve our offerings and deliver advertising tailored to your interests, in compliance with applicable laws.

Furthermore, the information we collect is used to enhance the overall quality of our services and improve the user experience. This includes utilizing analytics to evaluate and optimize our services, performance, and user interactions.

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Data Subject Rights

Your personal information belongs to you, and you have full control over how it is used. You can request details about the personal information we have collected, and you can ask us to delete it or correct any inaccuracies.

Your Rights. Under applicable data protection laws, you have the following rights regarding your personal information:

• Right to Access: You have the right to request access to the personal information we process about you.
• Right to Rectification: You can ask us to correct any inaccurate or incomplete personal data.
• Right to Erasure ("Right to be Forgotten"): In certain circumstances, you can request that we erase your personal data, including when it is no longer necessary for the purposes for which it was collected.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data under specific conditions.
• Right to Object: You can object to the processing of your personal data, particularly if it is processed for direct marketing purposes.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format so that you can transfer it to another data controller.

You also have the right to withdraw your consent to the processing of your personal data at any time by sending an email to Support@whaletv.com. However, please note that this withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

Additionally, you can use the relevant functionality provided in our software to remove all cookies and login details. Please be aware that requesting the deletion of your personal information may also result in a loss of access to some services we provide. We will not delete data that we are legally required to retain.

If you wish to exercise any of these rights, please contact us as specified in the "Contact Us" section of this Privacy Policy.

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Children's Personal Information

Our Services are intended for a general audience and are not specifically directed to children under the minimum age required by applicable law. We do not knowingly solicit or collect personal information from children under this minimum age. If we become aware that we have inadvertently collected personal information from a child under the minimum age without parental consent, we will promptly return or delete the information accordingly.

If you believe that we may have collected personal information from a child under the minimum age without parental consent, please contact us as outlined in the "Contact Us" section of this Privacy Policy.

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Disclosure of Information

We do not sell, lease, or transfer your personal information to third parties, except in the following circumstances:

• Service Providers. We may engage trusted third-party service providers to perform certain services on our behalf, such as IT support, email management, website hosting, and marketing. These service providers act as data processors, and we grant them access to your personal data only to the extent necessary for them to perform their services. For example, this website is hosted by an external service provider, and any personal data collected through the website (such as IP addresses, contact requests, meta and communication data, contractual data, contact details, names, and website access logs) is stored on the web host’s servers. These service providers are contractually obligated to implement appropriate technical and organizational security measures to ensure the protection of your personal data and to process such data only in accordance with our instructions. The legal basis for this transfer is Article 6(1)(b) of the GDPR, which relates to the performance of a contract with our (potential) website users.
• Legal Requirements. We may disclose your personal information if required to do so by law or in response to valid requests by public authorities, such as to comply with an official or court order. This disclosure is based on Article 6(1)(c) of the GDPR, which allows for processing necessary to comply with a legal obligation.
• Business Transfers. In the event of a merger, acquisition, or sale of assets, your personal information may be transferred as part of the transaction. This transfer will be conducted in compliance with applicable data protection laws.
• With Your Consent or Other Legal Grounds. We will forward your data to third parties if we have obtained your explicit consent (based on Article 6(1)(a) of the GDPR) or if the forwarding is required to protect our legitimate interests, provided these interests are not overridden by your rights (also under Article 6(1)(f) of the GDPR)

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Data Storage and Security

Your personal data may be stored and processed in Singapore or other jurisdictions where we or our service providers operate. We implement industry-standard technical and organizational measures to protect your personal information from unauthorized access, use, alteration, disclosure, or destruction. We participate in the IAB Europe Transparency & Consent Framework and comply with its Specifications and Policies. We use the Consent Management Platform with the identification number 300.

We work hard to protect both you and us from unauthorized access to, or unauthorized alteration, disclosure, or destruction of, the information we hold. Our security measures include:

• Encryption: We use encryption to keep your data private during transit.
• Regular Reviews: We regularly review our information collection, storage, and processing practices to prevent unauthorized access to our systems.
• Access Restrictions: We restrict access to personal information to our employees, service providers, and vendors who need that information to process it. Anyone with access to personal data is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

All our products are built with strong security features that continuously protect your information. Insights gained from the maintenance of our services help us detect and automatically block security threats before they reach you. If we detect a significant risk to your personal information that we believe you should know about, we will promptly notify you and provide guidance on steps you can take to protect yourself better.

However, please be aware that while we strive to protect your personal data, no method of Internet transmission, computer system, or wireless connection is entirely secure. If you believe that your account or personal information has been compromised, please contact us immediately as outlined in the "Contact Us" section of this Privacy Policy.

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Data Retention

We will retain your personal data for as long as necessary to fulfill the purposes for which it was collected or as required by applicable laws. Once these purposes have been fulfilled, we will securely delete or anonymize your personal data unless further retention is required by law.

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International Data Transfers

Due to the global nature of our business, your personal data may be transferred to countries outside of your countries. We will take appropriate steps to ensure that any international data transfers comply with applicable data protection laws, including the GDPR, CCPA and that your personal data is adequately protected.

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What Type Of Cookies Does We Use?

Our Site uses cookies and similar technologies to enhance your browsing experience and to provide essential functionalities. Below, we explain the types of cookies we use and their purposes:

• Strictly Necessary Cookies: Our Site uses first-party cookies (i.e., cookies set directly by us on your device) that are strictly necessary for the operation of the Site. These essential cookies allow you to navigate the Site and use its features, such as accessing secure areas. Without these cookies, certain services you request cannot be provided. You cannot opt-out of these cookies, as they are essential for providing the service.
• Cookies to Improve Your User Experience: In addition to strictly necessary cookies, our Site uses both first-party cookies and third-party cookies to enhance your user experience. These cookies may recognize your computer or mobile device when it visits other websites. Third-party cookies are typically used for website analytics or advertising purposes. Some cookies only remain on your device while your browser is open (known as 'session cookies'), while others stay on your device for longer periods (known as 'permanent cookies').

These cookies help us to improve the performance and functionality of our Site, ensuring a better user experience for you. You can change your cookie settings in the settings section of our website.

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How Are We Using Cookies?

From time to time, we may update this Cookies Policy to reflect changes, such as modifications to the cookies we use or for other operational, legal, or regulatory reasons. Please revisit this Cookies Policy regularly to stay informed about our use of cookies and related technologies.

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[For European Economic Area (EEA) Residents Only]

If you are a resident of the European Economic Area (EEA) or any other region protected by the General Data Protection Regulation (GDPR), you have specific rights under GDPR.

Legal Basis for Processing Personal Information

Our processing of your personal information is based on the following legal grounds:

• Contractual Necessity: We process your personal information to fulfill our contractual obligations to you, such as providing the services you have requested.
• Legitimate Interests: We process your personal information for our legitimate business interests, such as improving our services, customer service, and marketing, provided that these interests do not override your rights and freedoms.
• Legal Obligations: We may process your personal information to comply with legal obligations or respond to legal requests.
• Consent: In certain circumstances, we process your personal information based on your explicit consent. You have the right to withdraw your consent at any time; however, this will not affect the lawfulness of processing based on consent before its withdrawal.

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Your Rights Under GDPR

If you are a resident of the European Union (EU) or European Economic Area (EEA), you have the following rights under the General Data Protection Regulation (GDPR):

• Right to Access: You have the right to request access to the personal information we hold about you and to know how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal information.
• Right to Erasure ("Right to be Forgotten"): In certain circumstances, you can request the deletion of your personal information, such as when it is no longer necessary for the purposes for which it was collected.
• Right to Restrict Processing: You can request that we restrict the processing of your personal information under specific conditions.
• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and, where technically feasible, to transmit that information to another data controller.
• Right to Object: You have the right to object to the processing of your personal information, particularly where it is processed for legitimate interests or direct marketing purposes.
• Right to Withdraw Consent: Where the processing of your personal data is based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before the withdrawal.
• Right Not to Be Subject to Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, unless it is necessary for entering into or performing a contract, authorized by law, or based on your explicit consent.

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International Transfers of Personal Information

Due to the global nature of our business, your personal information may be transferred to, stored, and processed in countries outside of the European Economic Area (EEA), including but not limited to Singapore, where our headquarters is located.

Where we transfer your personal data to countries that have not been recognized by the European Commission as providing an adequate level of data protection, we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (SCCs), to ensure that your personal information is protected in accordance with the GDPR.

You can obtain a copy of the relevant data transfer mechanisms or further information about them by contacting us at Support@whaletv.com.

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Submitting Requests and Contact Information

If you wish to exercise your rights or have any questions about how we handle your personal information, you can contact us using the information provided in the "Contact Us" section of this Privacy Policy. EU data subjects have the right to lodge a complaint with a supervisory authority concerning WhaleTV’s data processing activities.

We may require additional information to verify your identity or to confirm your request. We will respond to your request within the timeframe required by law and inform you of the actions we have taken.

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[For California Residents Only]

If you are a California resident, you are entitled to specific rights under the California Consumer Privacy Act (CCPA).

If you are a resident of California, you have the right to make the following requests, up to twice every 12 months:

(i) The right to request a copy of the personal information that we have collected about you in the prior 12 months.

(ii) The right to request details about the categories of personal information we collect, the categories of sources, the business or commercial purposes for collecting information, and the categories of third parties with which we share information.

(iii) The right to request deletion of the personal information that we have collected about you, subject to certain exemptions.

(iv) The right to opt-out of sale of your personal information.

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Personal Information We Collect and Disclose

The CCPA requires us to provide our consumers who reside in California with the additional notice below. In the prior 12 months before the date of this Privacy Policy, we may have collected and disclosed for a business purpose the following personal information:

• Identifiers: IP address, Serial Number, Ethernet MAC address, Device ID, Consumer ID, and the country and language configured on your Smart Device
• Legally Protected Characteristics: Age (only if the user is over 13)
• Commercial Information: Interactions with customer service, customer preferences, and attributes such as likes and interests
• Inferences Drawn from Personal Information: Information about your preferences, attitudes, online behaviors, demographics, and product or ad choices
• Geolocation Data: Information related to your location, including your IP address
• Internet/Electronic Activity: Information collected through tracking tools such as browser cookies and web beacons, including your IP address, and device attributes

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Sources of Personal Information

We collect personal information from the following sources:

• Directly from You: When you communicate with us or provide information offline
• Automatically Collected Information: Through cookies and other online tracking technologies
• Business Partners: Such as analytics companies
• Third Parties: Including advertising partners, data aggregators, and public databases

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Disclosure of Personal Information for Business Purposes

The categories of personal information listed above may be shared with the following types of third parties:

• Whale TV PTE. LTD. and its affiliates.
• In Connection with Corporate Transactions: Such as purchases, sales, leases, mergers, acquisitions, disposals, or financings involving our brands
• Service Providers: Including cloud service providers, technical support, legal advisors, and accounting firms
• Business Partners: Such as marketing agencies
• Advertising Partners: To provide interest-based advertising
• Law Enforcement or Legal Obligations: As required by law

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California Residents' Rights

California law provides residents with certain rights and imposes restrictions on specific business practices:

• Right to Know: You have the right to request information about the categories and specific pieces of personal data we have collected about you, the sources of that data, the purpose for collecting it, and the categories of third parties with whom we share it.
• Right to Delete: You can request the deletion of your personal data that we have collected, subject to certain exceptions (e.g., data necessary for completing a transaction, providing a service, or complying with a legal obligation).
• Right to Opt-Out: You have the right to opt-out of the sale of your personal data.
• Right to Non-Discrimination: The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may include denying goods or services, providing a different level or quality of goods or services, or charging different prices or fees to residents who exercise their CCPA rights, unless such actions are reasonably related to the value provided by the resident's data.

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Submitting Requests

Under the CCPA, California residents have the right to submit a Request to Know, Request to Delete, or Request to Opt-Out of the Sale of their Personal Information. The CCPA requires us to reasonably verify each request before responding.

You or your authorized agent may submit a request to exercise any of the above rights by contacting us through the methods outlined in the "Contact Us" section of this Privacy Policy. We may require additional information to verify your identity or to confirm that your authorized agent has the authority to make the request on your behalf. We will respond to your request within 45 days, as required by law.

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Your Rights Under California's Shine-the-Light Law

Under California's “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us with their personal information are entitled to request and obtain, free of charge, information about the personal information (if any) we have shared with third parties for their direct marketing purposes. Such requests may be made once per calendar year. If you are a California resident and would like to make such a request, please contact us using the methods outlined in the "Contact Us" section of this Privacy Policy, with the subject line “Request for California Privacy Information.”

In your request, please confirm that you are a California resident and provide a current California address. We will respond to valid requests by sending a response to the email address from which you submitted your request. Please note that not all information sharing is covered by the “Shine the Light” law, and our response will include only the relevant details required by the law.

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Updates

This Privacy Policy may be updated periodically to reflect changes in our personal information practices with respect to our Service or changes in the applicable law. We will post a notice on our website to notify you of any significant changes to our Privacy Notice, and indicate at the top of the notice when it was most recently updated.

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Contact Us

If you have any questions regarding our Privacy Policy, wish to request a copy of your personal data, or need to ask us to correct or delete your personal data, you can contact us. You can reach us by:

Email: info@whaletv.com

Mailing Address: 6 RAFFLES QUAY #14-02, Singapore (048580)

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.