December 09, 2024
At CtrlMovie, AG. (“Company”, “CtrlMovie”, “we”, “our”, and/or “us”), we value the protection and the privacy of individuals who use our platform and services through www.ctrlmovie.com (the “Site”), our mobile software application (the “App”), and any related web-based, downloadable or other applications (collectively, the “Service”). This Data and Privacy Policy describes the way we process and protect personal information and data that you provide or we collect in connection with the Service.
This Data and Privacy Policy will explain how our Company uses the personal data we collect from you when you use our Service. Words and terms used in this Data and Privacy Policy unless otherwise defined shall have the meanings given to them in the European Union’s General Data Protection Regulation (“GDPR”), the Brazil Lei Geral de Protecao de Dados (“LGPD”) and the California Consumer Privacy Act of 2018 (“CCPA”), all as amended from time to time. References to the GDPR shall be deemed to include the GDPR as incorporated into UK law under the Data Protection Act 2018 (DPA 2018). Additionally, we adhere to the privacy protection guidelines set forth by Japan’s Act on the Protection of Personal Information (“APPI”), ensuring that personal information is handled in accordance with Japanese legal standards.
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CtrlMovie collects several different types of information to provide and improve our content and development services to our users. Offering the Service and experiences requires CtrlMovie to process personal information you provide. Personal information includes information that identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular user or household. In some instances, information is collected in the aggregate that does not relate to any particular user or household, such as the number of App users per day. In other instances, personal information can be sufficiently anonymized that it cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular user.
Creating a CtrlMovie account requires your basic contact information, including your phone number and/or email address. We may also require you to select a password for authentication and provide a username that may be visible to other users when you post to public portions of the Service if/when available. We receive and store this information and use it to create a user profile and provide you with access to the Service. We may use your email address and/or phone number to contact you with information relating to the Service or to provide support. At such time that the Service allows for you to post or upload materials to the Service, including without limitation text, audio, images, or other media (collectively “User Content”), those materials are personal information.
When you use the Service, CtrlMovie may collect additional personal information, including more detailed contact information you provide, your location, demographics, and your use of the Service. We may also collect and record certain information such as your unique device ID, hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), the version of your operating system (“OS”), and your location (based on your Internet Protocol (“IP”) address). This information is useful to us for troubleshooting and helps us understand usage trends and for providing you with the correct version of the application.
If you contact us directly, we may receive additional information about you. For example, if you contact us for customer support, we may receive your name, email address, phone number, the contents of any message or attachments you may send to us, and any other information you choose to provide.
We automatically receive information about your interactions with our Service, such as the posts or other content you view, the searches you conduct, the people you follow, and the dates and times of your visits.
We may collect information using cookies, pixel tags, and similar technologies. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Service.
We do not intentionally collect sensitive personal information, such as health data, biometric data, or financial information, unless explicitly required for the provision of our Services. If we need to process sensitive personal information, we will obtain your explicit consent and take additional measures to ensure its security and confidentiality.
Our Company also collects the following data:
You directly provide our Company with most of the data we collect. We only collect such Personal Information on our Site or in our App when you voluntarily provide it to us. We collect data and process data when you:
Our Company may also receive your data indirectly from the following sources:
We collect your personal information to provide a better and more personalized experience when using our Service. Specifically, we may use your personal information for the following purposes:
Personalization of Content and Services: To analyze your viewing and decision history, usage trends, and preferences to recommend tailored content, products, or services that align with your interests. For example, we may suggest interactive movie features or similar genres based on your viewing history.
Storage of In-Game Progress: To create your account and store for your own benefit and perusal your achievements and progress in the branched narratives you have watched and interacted with.
Marketing and Advertising: To inform you about new products, updates, promotions, or services we believe may interest you. For example, we may analyze your interactions with the Service to display relevant advertisements or promotional messages within the application, through email communications or via messages and notifications.
Improvement of Services: To enhance our application features and offerings by understanding how users engage with the Service. For instance, we use aggregated user data to improve the interactivity of our platform.
Improvement of Content: To improve current and future content offerings by understanding how users engage with the branched narratives.
Customer Support: To respond to your inquiries, provide assistance, and resolve issues you may encounter while using the Service.
Fraud Prevention and Security: To ensure the security of our platform by monitoring and detecting fraudulent activities and unauthorized access attempts.
Compliance and Legal Obligations: To fulfill our legal obligations, including compliance with data protection regulations, and to respond to valid legal requests or inquiries.
Development of New Features: To analyze anonymized usage data for developing and testing new features, products, or interactive experiences that improve the Service.
Legal Basis for Processing Personal Information under APPI We collect and process personal information from Japanese users under the following legal bases as required by the Act on the Protection of Personal Information (APPI):
We will not process your personal information for purposes beyond these without obtaining additional consent. If for any reason we process your personal information for purposes beyond those originally stated, we will inform you in advance and seek your explicit consent before initiating such processing. This ensures that your personal information is handled transparently and in alignment with your expectations.
For data collected from the European Union, EFTA states, Brazil and the United Kingdom, the primary legal bases/basis we rely on for such processing is contractual necessity for fulfilling our Terms of Service and Terms of Use and to comply with our legal obligations.
We do not and will never rent, sell, or share information about you with nonaffiliated third parties for their direct marketing purposes unless we have your affirmative express consent. We do not and will never rent, sell, or share information about you with nonaffiliated third parties for their direct marketing purposes unless we have your affirmative express consent. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through our Service in violation of our Data and Privacy Policy. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Data and Privacy Policy in effect at the time of the acquisition or merger. We may also disclose your information with your permission.
Sharing Information with Third PartiesIn addition to the circumstances outlined, we may share your personal information with: * Affiliated Companies: For operational purposes, such as data analytics or customer support. * Service Providers: For technical services, such as hosting, data storage, or payment processing. * Legal Authorities: To comply with lawful requests or legal obligations. We will not share your personal information for direct marketing or unrelated purposes without your explicit consent.
Cross-Border Data TransfersIf your personal information is transferred outside Japan, we ensure that the recipient country has equivalent data protection standards, or we obtain your explicit consent after explaining the associated risks. Data transfers may occur to provide our Services, such as hosting data on secure servers outside Japan or working with service providers based in other countries. In all cases, we implement appropriate safeguards, including contractual obligations and technical measures, to protect your personal information.
Our Company securely stores your data. We secure your data through encryption in transit and at rest. Your data will be stored in accordance with the applicable retention requirements of the Company, US laws and any other applicable laws.
Our company will keep log data for 6 months. Once this time period has expired, we will delete your data.
Data Retention for Japanese Users: We retain personal information only for as long as necessary to fulfill the purposes outlined in this privacy policy, comply with legal obligations, or resolve disputes. For Japanese users, personal information is stored in compliance with APPI requirements and securely deleted or anonymized once retention periods expire. Log data is retained for six months unless otherwise required for legal or operational purposes.
Data Breach Notification: If we become aware of unauthorized access, loss, or leakage of personal information, we will notify affected individuals and relevant authorities promptly, as required under APPI. Notifications will include details about the breach, potential risks, and steps being taken to address the situation.
We understand the importance of protecting the personal information of individuals under 18 years of age. While our Services are designed to be accessible to a wide range of audiences, including younger individuals, we ensure that their personal information is handled with appropriate safeguards.
Collection of Personal Information from Individuals Under 18: We may collect personal information from individuals under 18 years of age if it is necessary to provide our Services or support their interactions with our platform. This may include basic account registration details, usage data, and any other information voluntarily provided.
Parental or Guardian Consent: For individuals under 18, we prioritize obtaining consent from a parent or legal guardian where appropriate. This includes situations involving sensitive personal information or activities requiring explicit consent under applicable laws.
Use of Personal Information: Personal information collected from individuals under 18 is used solely for the purposes outlined in this privacy policy, such as providing and improving our Services, ensuring a safe and secure platform, and communicating about content or features. *Enhanced Safeguards: To ensure compliance with international best practices, we apply additional safeguards when processing the personal information of individuals under 18. This includes limiting data collection to what is strictly necessary and avoiding unnecessary sharing or processing.
Parental or Guardian Rights: Parents or legal guardians of individuals under 18 have the right to:
Access the personal information collected.
Request corrections, deletions, or restrictions on processing.
Withdraw consent for specific processing activities. To exercise these rights, parents or guardians can contact us at privacy@ctrlmovie.com.
*Compliance with Local Regulations: As the initiative is conducted within Japan, where the Act on the Protection of Personal Information (APPI) does not specifically regulate the collection of personal information from individuals under 18, we ensure that all processing activities are conducted transparently, lawfully, and with respect for individual rights.
Our Company keeps a record of when and how we received your consent for data collection and processing. Our Company keeps a record of exactly what and where you were told at the time of consent. We regularly review consents to check that their relationship, the processing and their purpose have not changed.
At CtrlMovie, we recognize the importance of maintaining accurate and detailed records of user consent for the collection, processing, and sharing of personal information. These records help us ensure transparency, accountability, and compliance with data protection regulations such as the Act on the Protection of Personal Information (APPI).
To achieve this, we maintain records of: * The Details Provided at the Time of Consent: The version of our privacy policy presented to the user at the time of consent. The specific purposes for which the user consented to the collection, processing, and sharing of their personal information. * Consent Timestamp: The date and time the user provided their consent. * Method of Consent: Whether consent was obtained via online forms, app notifications, checkboxes, or other methods. For sensitive personal information or cross-border data transfers, additional explicit consent (e.g., a separate opt-in) is recorded. * Consent Modifications or Withdrawal: Any changes made to a user’s consent preferences, including the date and time of such changes. Documentation of consent withdrawals and confirmation of subsequent cessation of processing. * Associated User Information: User identification information, such as account ID or email address, to link consent records with the correct user. * Cross-Border Data Transfers: Details of any explicit consent obtained for transferring personal information outside Japan, including the countries or regions involved and associated risks communicated to the user.
Retention of Consent RecordsWe retain consent records for as long as the user’s personal information is processed or as required to comply with applicable laws and regulations. Once the retention period has expired, we securely delete or anonymize these records.
Review and UpdatesConsent records are regularly reviewed to ensure accuracy and alignment with user preferences. Users are notified and prompted to provide updated consent if there are significant changes to our privacy policy or processing activities.
Access to Consent RecordsUsers have the right to request a copy of their consent records, including details of how and when consent was obtained. To request this information, users may contact us at privacy@ctrlmovie.com.
Our Company would like to make sure you are fully aware of all your data protection rights. Every user is entitled to the following:
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: privacy@ctrlmovie.com
Or write to us:
CtrlMovie AG
Grenzstrasse 5a
6214 Schenkon
Switzerland
Our Company uses cookies in a range of ways to improve your experience on our Site, including:
Cookies We use cookies to enhance your experience and provide personalized content. For users, we ensure that: * Consent is obtained before using non-essential cookies. * Information about the types of cookies used and their purposes is clearly communicated. * You can manage cookie settings and withdraw consent at any time through your browser or our cookie management tool.
There are a number of different types of cookies our Site uses:
You can set your browser not to accept cookies, and the website tells you how to remove cookies from your browser. However, some of our features may not function as a result.
If you have any questions about Our Company’s Data and Privacy Policy, the data we have collected, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.
If you live in the United States, any country outside of the European Union or EFTA States, you can contact us at:
By email at: privacy@ctrlmovie.com
Or write to us at:
CtrlMovie AG
Grenzstrasse 5a
6214 Schenkon
Switzerland
Should you wish to report a complaint or if you feel that our Company has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office or contact our Data Protection Officer for the contact information for the appropriate authority.
Our company keeps its privacy policy under regular review and places updates on this web page.
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit our CCPA Privacy Notice at https://ctrlmovie.com/documents/ccpapolicy.pdf.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Service who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an e-mail to privacy@ctrlmovie.com
To the extent possible, users will receive equal service and price regardless of whether they exercise their privacy rights under the California Consumer Privacy Act of 2018. CtrlMovie does not sell the personal information of its users.
If you are a resident of Japan, you are entitled to specific rights regarding the collection, use, and handling of your personal information under the Act on the Protection of Personal Information (APPI). These rights include, but are not limited to:
Right to Access: You have the right to request access to the personal information we hold about you, including the purposes for which it is being used and any third parties to whom it has been disclosed.
Right to Correction: You have the right to request corrections, additions, or deletions of your personal information if you believe it to be inaccurate, incomplete, or outdated. Right to Suspend Usage or Deletion: Under certain circumstances, you may request that we suspend the use of, delete, or cease sharing your personal information if it has been handled improperly or if you withdraw your consent.
Right to Explanation: You have the right to request an explanation of the handling of your personal information, including the measures taken to ensure its security.
Right to Object to Certain Uses: You may object to the use of your personal information for purposes not previously disclosed or that exceed the scope of your consent, except where required by law. To exercise these rights or for inquiries about our handling of personal information under APPI, please contact us via the following:
By email: privacy@ctrlmovie.com
CtrlMovie AG
Grenzstrasse 5a
6214 Schenkon
Switzerland
We will respond to your request within the timeframe stipulated by the Act, typically within one month, unless otherwise specified under applicable law.