Privacy Statement

Avenida Engenheiro Adelino Amaro da Costa, Edifício Central Office, nº 189, 2º Piso, Escritório12, 2750-279 Cascais, distrito de Lisboa, concelho de Cascais, freguesia de Cascais e Estoril.

We appointed an external data protection officer (DPO) – Olga Antoniuk. In addition,  VIDEO-HERO LDA. established a dedicated data protection team, which closely collaborates with the DPO. Our data protection team as well as the DPO can be reached at legal@video-hero.com or at VIDEO-HERO LDA., address: Avenida Engenheiro Adelino Amaro da Costa, Edifício Central Office, nº 189, 2º Piso, Escritório12, 2750-279 Cascais, distrito de Lisboa, concelho de Cascais, freguesia de Cascais e Estoril.

If you have any questions or concerns about privacy, please contact our data protection team in the way listed above. For the conclusion of a data processing agreement pursuant to Art. 28 GDPR and for general questions about our products, please contact our sales department admin@video-hero.com

ABOUT US

VIDEO-HERO LDA. (also referred to as “Company”, “We”, “Our” and “Us”) an outstanding technological company incorporated under the laws of Portugal, having its registered address at Avenida Engenheiro Adelino Amaro da Costa, Edifício Central Office, nº 189, 2º Piso, Escritório12, 2750-279 Cascais, distrito de Lisboa, concelho de Cascais, freguesia de Cascais e Estoril, is the owner of the websites https://herovideo.io/ and its subdomains (also “Our Websites”), and the Services and we are committed to being fully transparent while operating them, as regards our privacy practices.

We provide You with a Header Bidding Management Platform  – a software-as-a-service digital advertising solution for businesses and agencies all over the world, helping to maximize Your revenue on every device and a Hero Video Platform – a comprehensive solution for automatically creating relative videos for each new article, providing them with a new user acquisition channel and additional revenue stream (also the “Services”). 

This Privacy Statement is specifically for when You use Our Websites and Services. It doesn’t cover any other websites linked to Our Websites, whether We share those links or if they’re shared by other users. We can’t control how Your data is gathered, stored, or utilized by these other websites, so we recommend checking their privacy statements before giving them any data.

This Privacy Statement is relevant for:

• Our Websites visitors;

• Our customers (including their internal users);

• End-users of Our customers who interact with Our customers on their cookie profiles on advertising platforms,

(jointly referred to as “Users”, “You”, and “Your”).

We respect Your confidentiality rights and is dedicated to safeguarding Your privacy. This Privacy Statement outlines the information we collect, how we utilize it, and how You can update or modify it. You can anticipate receiving notification of:

• What personally identifiable data of Yours is collected;

• Who is collecting the data;

• How the data is used;

• With whom the data may be shared;

• What choices do You have regarding the collection, use, and distribution of the data;

• What kinds of security procedures are in place to protect against the loss, misuse, or alteration of the data under Our control;

• How You can correct any inaccuracies in the data.

In case You have any additional questions, You can direct them any time to Our data protection team reachable at legal@video-hero.com

YOUR PERSONAL DATA

All personal data is processed and stored securely under the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR),  Portugal Law No. 58/2019 of 8 August — Ensures the implementation, in the national legal order, of Regulation (EU) 2016/679 (General Data Protection Regulation), ePrivacy Directive 2002/58/EC, EU Artificial Intelligence Act,  and other international legislative acts concerning data protection.

Our service uses artificial intelligence (AI) technologies exclusively for the purpose of generating digital avatars derived from the biometric data of individuals who have lawfully provided their explicit consent for such processing and who are subject to a separate agreement governing such purpose. AI technologies are not applied to any other personal data of Users covered by this Privacy Policy, and no other categories of personal data are used for training, improving, or operating the AI models.

We operate as a deployer of a low-risk AI system under the EU AI Act, meaning that we use AI functionalities solely within the scope permitted for low-risk systems and in accordance with the Act’s transparency requirements. Nevertheless, we implement human oversight, bias testing, and risk-mitigation measures to ensure the safe and reliable operation of the AI components. If you have any questions regarding the use of AI within our service, please contact us at legal@video-hero.com

We collect personal data based on consent obtained from the Users who have reached eighteen (18) years of age.

We do not collect and/or process sensitive data, which means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation.

We guarantee that Your personal data is handled in a lawful, fair, and transparent manner, without infringing upon Your rights. We will only process Your personal data if one of the following conditions is met:

• You have given consent to the processing of Your personal data for one or more specific purposes;

• Processing is necessary for the performance of a contract to which You are a party or in order to take steps at Your request prior to entering into a contract;

• Processing is necessary for compliance with a legal obligation to which We are subject; and/or

• Processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

We use Your data to provide the best possible Services to You. This includes:

• Managing and overseeing Your account provision;

• Providing and managing Your access to Our Websites;

• Personalizing and tailoring Your experience on Our Websites;

• Supplying, personalizing, and tailoring the Services for Your benefit;

• Responding to communications from You (to contact You about Your account and provide customer support, including responding to Your comments and questions);

• Keeping You informed about the service, features, surveys, newsletters, offers, and events We think You may find useful or which You have requested from Us and/or that You have subscribed to (You may unsubscribe or opt-out at any time by changing Your email preferences link in emails);

• Selling and marketing the Services;

• Assessing Your requirements and issues, analyzing patterns, enhancing service features and usability, and gaining a deeper understanding of Our customers and users;

• Evaluating Your website usage to enhance Your user experience;

• Verifying Your identity upon logging into Your account.

Our Services utilize the data we gather for advertising intentions, which include:

• Customizing advertisements;

• Displaying advertisements;

• Evaluating the efficiency of advertisements and advertising campaigns;

• Facilitating standard advertising management;

• Assessing and reporting on advertising campaigns and forecasting campaign outcomes;

• Mitigating malicious or deceptive activities;

• Enhancing Our Services;

• Providing Our Services and fostering business partnerships.

We do not collect personal data when You visit Our Websites unless You sign-up for a service, place an order, register, complete a survey, or subscribe to the newsletter. When You visit Our Websites, we also may collect certain data by automatic means that may include Your IP address, Your web browser type and version, Your operating system, a list of URLs starting with a referring site, Your activity on Our Site, and the site You exit to. In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the Services We can provide You without Your consent for Us to be able to use such data.

When You sign-up for a service, We will ask You for the following personal data: name, surname, Your company, billing address and details, and e-mail address. We may use Your personal data to contact You for account purposes.

When You register an account or place an order (upgrade to a paid version of the software provided within Our Services), We will ask You for the following personal data:  name, surname, e-mail, billing address, mailing address, job title, company, phone number, and banking details. This data is requested to verify Your identity. This data is transmitted via a secure, encrypted server using Transport Layer Security (TLS) encryption, more commonly known as HTTPS, the approved industry standard (see Security section below). We may use Your personal data to contact You for account purposes.

When You submit feedback or questions via e-mail or contact Us for information about Our Websites, We will request Your name, company, messenger contact, and e-mail address. We use this data solely to respond to Your inquiries.

When You subscribe to a newsletter, We will request Your name and email address. We use this data to provide You with the news and information according to Your subscription. You can revoke Your consent to receive a newsletter at any time, and Your subscription will be canceled.

All performance statistics and data are kept private and any personally identifiable data is not released to any of Our partners without Your permission. Occasionally, We may reference Our own statistics, but the data will be an aggregate of Our whole client base, without any party’s identification provided.

With Your permission and/or where permitted by law, We may also use Your data for marketing purposes, which may include contacting You by email with information, news, and offers on Our Services. We will not, however, send You any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect Your rights and comply with Our obligations under the GDPR, Portugal Law No. 58/2019,  and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

Below, Company describes more detailed information about the types of pseudonymous data we process via providing our Services:

• Location. In accordance with Your device permissions, we may also receive information about the precise location of Your device, but only if our clients pass it to us. Precise location may be deemed as sensitive personal information in some jurisdictions;

• Age range, gender;

• User-agent or such device information (Demographic information); frequency of identifiers visiting and viewing with respect to advertising (Behavioral data);

• Company Personnel data, such as contact details (name, email, telephone) and professional details (role).

Pseudonymous user data that We receive from our partners is the following:

• Location data. In accordance with Your device permissions, we may also receive information about the precise location of Your device, but only if our clients pass it to us. Precise location may be deemed as sensitive personal information in some jurisdictions;

• Age, range, gender;

• Identifiers: cookie and mobile Ad identifiers (such as IDFA, ADID, GPID etc.); IP address, data that could be used for fingerprinting, latitude and longitude;

• Demographic information: location, age range, gender, other Publisher-specified demographics (tied to an identifier); User-agent or such device information;

• Behavioral data: frequency of identifiers visiting and viewing Publisher Sites, and viewing and taking actions with respect to advertising.

• Client’s Personnel such as contact details (name, email, telephone) and professional and business details (role and billing address).

The Services We provide collect data in the following way:

• From Publishers passing us information so that we can help them monetize ad inventory space on their properties;

• Using cookies and/or pixels;

• From our clients and customers uploading data onto our Services;

• From clients and partners using our technology to gather data;

• Through the displaying ads process.

To provide You with our Services, namely Hero Video Platform, We use Youtube API Services. Please, read Google Privacy Policy accessible at http://www.google.com/policies/privacy to get more information on how data is being collected and processing. Be sure that Company does not and will not attempt to obtain, proxy, request, collect, modify, cache, store, or use any information that You, as a user, provides or that YouTube displays to the user during authentication processes, including YouTube user account login credentials like usernames and passwords.

Company may access or use authorized data. However, you are provided full control over your data, including the ability to revoke access at any time. You can manage and withdraw Company's access to their data by navigating to their Google security settings page at https://security.google.com/settings/. Additionally, we inform you about complying with all applicable data deletion procedures, ensuring that any API Data related to you as a user that was accessed or stored pursuant to such consent  is promptly removed upon request or when access is revoked.

Company discloses depersonalized data that is collected to:

• SSP side partners facilitate publishers in offering advertising inventory within their Publishers Properties for SSP side partners to bid on and populate with pertinent advertisements. Governed by the Data Processing Addendum;

• Advertisers or agencies, their clients to help them improve the effectiveness of their – and their client’s – ads campaign. Governed by Data Processing Addendum;

• Service providers. Governed by Data Processing Addendum;

• Where we think we’re required to by law. Company may disclose user information with law enforcement, regulatory authorities, courts with competent jurisdictions, emergency services, or other necessary third parties for legal, protection, security, and safety purposes, including: to comply with laws or regulatory requirements and to respond to lawful requests and legal process; to protect the rights and property of Company, our affiliates, agents, customers, and others, including enforcing our agreements, policies, and terms of use and protecting our network and physical assets.

Additionally, we inform You that We do not collect sensitive data.  In case something will change in this matter and for the purpose to provide the better Services will require more information as well as sensitive information (i.e., personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual), Company insures You that we will obtain affirmative express consent (opt in) from You if such information is to be (i) disclosed to a third party or (ii) used for a purpose other than those for which it was originally collected or subsequently authorized by You through the exercise of opt-in choice.  In addition, Company treats as sensitive any personal information received from a third party where the third party identifies and treats it as sensitive.

ALL PERSONAL DATA RELATING TO OUR CUSTOMERS AND CLIENTS, INCLUDING NAMES, EMAIL ADDRESSES, AND OTHER PERSONAL DATA, IS KEPT SECURE AND CONFIDENTIAL. WE DO NOT SHARE, SELL, RENT, OR BARTER ANY IDENTIFIABLE PERSONAL DATA TO ANY THIRD PARTY WITHOUT YOUR PERMISSION.

YOUR RIGHTS UNDER GDPR

We believe that You should have control over how Your information is used and shared.  Therefore, we offer You choices and means to manage and limit the use and disclosure of Your personal data.

We are providing You access to personal information about You that our Company holds to be able to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of applicable law,  in Your account according to our Terms of Services, but there are exclusions when where the burden or expense of providing access may be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.

Our Privacy Statement provides You with the opportunity to exercise the following rights You have Under the GDPR as a data subject:

• the right to be informed of what data processing is taking place;

• the right to request access to, deletion of, or correction of Your personal data;

• the right to restrict the processing of Your personal data;

• the right to data portability;

• the right to object to the processing of Your personal data;

• the right to complain to a supervisory authority;

• the right to refuse automated decision-making and profiling.

You may assert these rights by initiating a request through our Data Subject Request process outlined at the outset, or by contacting our Data Protection Officer. To enforce any of the aforementioned rights, kindly reach out to our data protection team at legal@video-hero.com. Company’s data protection team will promptly attend to Your request and furnish a timely response, along with suitable avenues for action, within a reasonable timeframe.

In case any of Your personal data is used by Company for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision by Company.

The right described in the section above, however, does not apply in the following circumstances:

• The decision is necessary for the entry into or performance of a contract between You and Company;

• The decision is authorized by law; or

• You have given Your explicit consent for such automated decision-making.

We currently use NO automated decision-making for any purpose.

We currently profile personal data for the purposes of marketing and advertising. Where Company uses personal data for profiling purposes, the following shall apply:

• Clear information explaining the profiling will be provided, including its significance and the likely consequences;

• Appropriate mathematical or statistical procedures will be used;

• Technical and organizational measures necessary to minimize the risk of errors and to enable such errors to be easily corrected shall be implemented; and

• All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

DATA COLLECTION, STORAGE, AND TRANSFER

All the data collection on Our Websites and through the Services is carried out in a manner clear and transparent manner to Our Users. Company does not affix any spybot or data collection software to any of its products.

We only keep Your data for as long as needed in order to use it for the purposes set in Section 2, and/or for as long as We have Your permission to keep it. In any event, We are conducting an annual review to ascertain whether We need to keep Your data. Your data will be deleted if We no longer need it.

We primarily store data about customers and site visitors in the EU. To facilitate Our global operations, We may transfer and access such data from around the world, including from other countries in which We are operating. Some or all of Your data may be stored or transferred outside of the European Economic Area (“EEA”). If You are not accepting this, please refer to our Data Protection Team at legal@video-hero.com with the appropriate request. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that Your data is treated as safely and securely as it would be within the EEA and under the GDPR.

SECURITY

Data security is of great importance to Us, and to protect Your data, We have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data collected through Our Websites and Services.

Steps We take to secure and protect Your personal data include:

• Access to the data stored within Our Websites and Services is restricted to a limited number of Our employees;

• We use industry best practices to keep any data collected and/or transmitted to Our Websites and Services secure. Our Websites and Services are all secured by SSL protocol, which provides encryption to all data transmitted;

• We use Transport Layer Security (TLS) encryption, more commonly known as HTTPS, for all of the data that We send and receive. This ensures that all User data in transit is both safe and secure, and additionally only available to the intended recipients. This ensures that online transactions and the transmission of personal data such as credit card details are safe from third-party interception;

• Our Websites and Services are protected by a) firewalls establishing a barrier between Our trusted, secure internal network and the Internet and b) IP restrictions, limiting access to allowed IPs;

• We use third-party vendors and hosting partners (such as AWS) to provide the necessary hardware, software, networking, storage, and related technology to run the Services. These vendors all offer best-in-class security, You can see Google’s security features here: https://cloud.google.com/security/; Amazon AWS security features here: https://aws.amazon.com/security/;

• We also use third-party vendors to prevent attacks on Our Websites or the Services and the destruction or theft of any data. Such vendors also monitor potential attacks to inform Our customers in the event their content and/or any related data has been compromised;

• We review Our data collection and processing practices periodically and will review and amend this Privacy Statement accordingly.

Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the Internet may not be completely secure and that You are advised to take suitable precautions when transmitting to Us data via the Internet.

THIRD PARTIES

We may contract with third parties to supply Services represented on Our Websites to You on Our behalf. These may include payment processing, search engine facilities, advertising, and marketing. In some cases, third parties may require access to some or all of Your data. Where any of Your data is required for such a purpose, We will accomplish this only under Your consent and take all reasonable steps to ensure that Your data will be handled safely, securely, and in accordance with Your rights, Our obligations, and the obligations of the third party under the law.

We may compile statistics about the use of Our Websites including data on traffic, usage patterns, sales, and other data. All such data will be anonymized and will not include any personally identifying data. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

In certain circumstances, Company may be legally required to share certain data, which may include Your personal data, for example, where there is involvement in legal proceedings, where Company is complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from You in order to share Your data in such circumstances and will comply as required with any legally binding request that is made by the competent authorities.

TRANSFER OF CONTROL

We may, from time to time, expand or reduce Services represented on Our Websites, and this may involve the sale and/or the transfer of control of all or part of Company. Data provided by Users will, where it is relevant to any part of Our business, so transferred, be transferred along with that part, and the new owner or newly controlling party will, under the terms of this Privacy Statement, be permitted to use the data for the purposes for which it was originally collected by Company.

In the event that any of Your data is to be transferred in such a manner, You will not be contacted in advance and informed of the changes.

We inform You about the Company’s responsibilities regarding onward transfers of personal data to third parties.

Transfers to third-party controllers

• When transferring personal data to a third party acting as an independent controller, Company ensures that such transfers comply with the requirements of the GDPR. This includes:

• transferring the data only for limited and specified purposes that are compatible with the original purpose of collection;

• entering into a contract with the third-party controller that requires the recipient to process the data in accordance with applicable data protection laws and to provide an adequate level of protection;

• requiring the third party to notify Company if it can no longer meet its data protection obligations, in which case Company will take appropriate steps to stop or remediate any unauthorized processing.

Transfers to third-party processors (agents)

When transferring personal data to a third party acting as a processor, Company:

1. transfers such data only for limited and specified purposes;

2. ensures that the processor is contractually obligated to provide a level of protection for the personal data that meets GDPR requirements;

3. takes reasonable steps to verify that the processor processes the data in a manner consistent with Company's instructions and with applicable data protection laws;

4. requires the processor to notify Company if it is unable to comply with these obligations;

5. upon receiving such notice, takes reasonable and appropriate steps to stop or remediate any unauthorized processing; and

6. makes available a summary or a copy of the relevant contractual data-processing terms upon request, where legally permissible.

Company remains responsible for the processing carried out by its processors to the extent required under the GDPR, unless the Company demonstrates that it is not responsible for the event giving rise to the damage.

International data transfers

If You are a resident of the EEA, the UK, or Switzerland, we will protect Your personal data when it is transferred outside of Your jurisdiction by using one or more of the following transfer mechanisms permitted under the GDPR and corresponding local laws:

• transferring data to a country that has been recognized by the European Commission (or relevant authority) as providing an adequate level of data protection;

• entering into Standard Contractual Clauses or other appropriate safeguards approved under applicable data-transfer regulations;

• implementing additional technical, contractual, or organizational measures where required to ensure that the transferred personal data remains protected.

COOKIES

To better serve You, We use cookies to reduce the time required to log in as well as for the continuous improvement of Your User experience across Our Websites. Cookies are pieces of data that Our Websites can set on Your browser or device and they can typically be read on future visits to learn about You more and to personalize Your experience, including the ads that are displayed to You.

We collect and process a variety of non-personally identifying data in order to prevent fraud and support and maintain a higher-quality browsing experience for all Users.

To know more about the way, how We process cookies and use such data, please refer to Our Cookie Policy.

YOUR CHOICE/OPT-OUT

Company provides You with the opportunity to withdraw Your consent for Us to use Your personal data, update, change, or remove Your personal data from Our Websites, and opt out of receiving communications from Us at any time. Please contact Our data protection team with the corresponding request at legal@video-hero.com or perform an automatic cookie opt-out at Our opt-out page. 

As stated in the paragraph above Company offers You the opportunity to choose (opt out) whether Your personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by You. 

By derogation to the previous paragraph,  we inform You that it is not necessary to provide choice when disclosure is made to a third party that is acting as an agent to perform task(s) on behalf of and under the instructions of our company.  However, You must be sure that Company shall always enter into a contract with the agent to regulate and protect Your personal data.

Please, see our Cookie Policy for more information on how we use cookies and other similar technologies to get more about opt-out via this way. For more information about cookies in general, including how to see what cookies have been set on Your device and how to manage and delete them, visit www.allaboutcookies.org.  For more information about how to clear Your browser cache, please see Your browser’s instructions for doing so.  Please note that deleting or resetting cookies and clearing Your browser cache will not opt You out of receiving interest-based advertising (including retargeting) from our Services.

You have the option to limit the use of Cookies by Your internet browser. Further details are available, please see Cookie Policy.

You may withdraw Your consent for Us to use Your personal data at any time by contacting Us using the details set out in section 8, and We will delete Your data from Our systems. However, You acknowledge this may limit Our ability to provide the best possible Services to You.

CHANGES TO THIS PRIVACY STATEMENT

We reserve the right to update this Privacy Statement periodically as deemed necessary or as mandated by law. Any updates will be promptly posted on Our Websites, and Your continued use of Our Websites after such changes are implemented will signify Your acknowledgment and acceptance of the revised Privacy Statement. We advise You to review this page frequently to stay informed of any changes.

CONTACT INFORMATION

If You have any questions or comments about this Privacy Statement, the ways in which Company collects and uses Your data described here, or Your choices and rights regarding such use, please do not hesitate to contact Us at: legal@video-hero.com