Privacy Statement

Last Updated: March 12, 2024

Privacy Statement

This Privacy Statement explains our practices, including your choices, regarding the collection, use, and disclosure of certain information, including your personal information in connection with the HotShorts service.

Collection of Information

We receive and store information about you such as:

Information you provide to us: We collect information you provide to us which includes:

Your third-party account used to log in to HotShorts and the payment account used to top up coins and other identifiers you might use. We collect this information in a number of ways, including when you enter it while using our service, interact with our customer service, or participate in surveys or marketing promotions;

Information we collect automatically: We collect information about you and your use of our service, your interactions with us and our advertising, as well as information regarding your network, network devices, and your computer or other HotShorts capable devices you might use to access our service (such as mobile devices and other streaming media devices). This information includes:

your activity on the HotShorts service, such as title selections, shows you have watched, ads viewed (if applicable) and search queries;

your interactions with our emails and texts, and with our messages through push and online messaging channels;

details of your interactions with our customer service, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings;

device IDs or other unique identifiers, including for your network devices (such as your router), and devices that are HotShorts capable on your network;

resettable device identifiers (also known as advertising identifiers), such as those on mobile devices, tablets, and streaming media devices that include such identifiers (see the “Cookies and Internet Advertising” section below for more information);

device and software characteristics (such as type and configuration), connection information including type (wifi, cellular), statistics on page views, referring source (for example, referral URLs), IP address (which can be used to tell us your general location, such as your city, state/province, and postal code), browser and standard web server log information;

information collected via the use of cookies, web beacons and other technologies, including ad information (such as information on the availability and delivery of ads, the site URL, as well as the date and time). (See our “Cookies and Internet Advertising” section for more details.)

Use of Information

We use information to provide, analyze, administer, enhance and personalize our services and marketing efforts, to provide, analyze, administer, enhance and select ads in connection with our ad supported subscription plans, to process your registration, your orders and your payments, and to communicate with you on these and other topics. For example, we use such information to:

provide you with customized and personalized viewing recommendations videos we think will be of interest to you (collectively “content”);

determine your general geographic location (such as your city, state/province, and postal code);

provide localized content;

determine your ISP to support network troubleshooting for you (we also use aggregated ISP information for operational and business purposes);

help us quickly and efficiently respond to inquiries and requests;

secure our systems, prevent fraud and help us protect the security of HotShorts accounts;

prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and to enforce our terms;

analyze and understand our audience, improve our service (including our user interface experiences and service performance) and optimize content or ad selection, recommendation algorithms and delivery;

communicate with you concerning our service so that we can send you notices about HotShorts, details about new features and content available on HotShorts, special offers, promotional announcements, consumer surveys, and to assist you with operational requests such as password reset requests. These communications may be by various methods, such as email, push notifications, text message, online messaging channels, and matched identifier communications (described below). Please see the “Your Choices” section of this Privacy Statement to learn how to set or change your communications preferences.

Our content recommendations system strives to predict what you will be in the mood to watch when you log in. The biggest driver of these recommendations is what you actually choose to watch through our service. However, our content recommendations system does not infer or attach socio-demographic information (like gender or race) to you.

International Transfer of Personal Data

In disclosing your Personal Data to a third party, we may transfer your Personal Data to countries outside your country of residence, such as Japan, the Republic of Korea and the United States These countries may not have personal data protection laws as comprehensive as those that exist in your country of residence, and the same level of protection as that set forth in the personal data protection laws in your country may not necessarily be guaranteed. In such case, we shall implement necessary safety management measures pursuant to the requirement pursuant to any and all the applicable laws or legislations in respect with protection of your Personal Data (the “Applicable Law”).

Data Storage and Retention Period

Your Personal Data will be stored securely in our data server or in the third-party’s data server. We will strictly control access to this information and will review such access control from time to time. We will not keep your Personal Data for longer than required for the purpose of which it has been processed, in accordance with the Applicable Law or in any case to allow the Company to protect the legitimate rights and interests of its own or of third parties. To determine the appropriate retention period for the Personal Data, we shall consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of the Personal Data, the purposes for which we process the Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your Choices

Push Notifications.You can choose to receive mobile push notifications from HotShorts. On some device operating systems, you will be automatically enrolled in the notifications. If you subsequently decide you no longer wish to receive these notifications, you can use your mobile device’s settings functionality to turn them off. We also offer push notifications on certain web browsers. If you agree to receive those notifications and subsequently decide you no longer wish to receive these notifications, you can use your browser’s settings to turn them off.

Matched Identifier Communications from HotShorts. Some third party sites and apps allow us to reach our users with online promotions about our titles and services by sending a privacy protective identifier to the third party. A privacy protective identifier means we convert the original information (such as an email address or phone number) into a value to keep the original information from being revealed. The third party compares the privacy protective identifier to identifiers in its database and there will be a match only if you have used the same identifier (such as an email address) with HotShorts and the third party. If there is a match, HotShorts can then choose whether or not to send a given promotional communication to you on that third party site or app, and can optimize and better measure the effectiveness of online advertising.

Behavioral Advertising.Behavioral advertisements are those that are selected based on your use and/or interactions with various unaffiliated third party apps or websites across the Internet (behavioral advertising). HotShorts can advertise its services using behavioral advertising, and if you are using a browser, then certain cookies and web beacons can be used to collect information to help determine your likely interests. If you are using a mobile device, tablet, or streaming media device that includes a resettable device identifier, then that identifier can be used to help determine your likely interests. For your choices about behavioral ads from HotShorts, please see the “Cookies and Internet Advertising” section (below).

Cookies and Internet Advertising

We and our Service Providers use cookies and other technologies (such as web beacons), as well as resettable device identifiers, for various reasons. We want you to be informed about our use of these technologies, so this section explains the types of technologies we use, what they do and your choices regarding their use.

Cookies and similar technologies, web beacons, and resettable device identifiers

Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. We use other technologies such as browser storage and plugins (e.g., HTML5, IndexedDB, and WebSQL). Like cookies, these other technologies may store small amounts of data on your device. Web beacons (also known as clear gifs or pixel tags) often work in conjunction with cookies. In many cases, declining cookies will impair the effectiveness of web beacons associated with those cookies.

If you use the HotShorts app on a mobile device, tablet, or streaming media device, we may collect a resettable device identifier from your device. Resettable device identifiers (also known as advertising identifiers) are similar to cookies and are found on many mobile devices and tablets (for example, the “Identifier for Advertisers” (or IDFA) on Apple iOS devices and the “Google Advertising ID” on Android devices), and certain streaming media devices. Like cookies, resettable device identifiers are used to make online advertising more relevant and for analytics and optimization purposes.

Why does HotShorts use these technologies?

We use these types of technologies for various reasons, like making it easy to access our services by remembering you when you return; to provide, analyze, understand and enhance the use of our services; to enforce our terms, prevent fraud; to improve site performance, monitor visitor traffic and actions on our site; and to deliver and tailor our marketing or advertising, and to understand interactions with our emails, marketing, and online ads on third party sites. We may also use these technologies to support the operation of our ad supported subscription plans.

To help you better understand how we use cookies and resettable device identifiers, please see the information below:

Essential cookies:These cookies are strictly necessary to provide our applications or online service. For example, we and our Service Providers may use these cookies to authenticate and identify our registered users when they use our applications so we can provide our service to them. They also help us to enforce our Terms of Use, prevent fraud and maintain the security of our service.

Performance and functionality cookies:These cookies help us to customize and enhance your online experience with HotShorts. For example, they help us to remember your preferences and prevent you from needing to re-enter information you previously provided. We also use these cookies to collect information (such as popular pages, conversion rates, viewing patterns, click-through and other information) about our visitors’ use of the HotShorts service so that we can enhance and personalize our website and service and conduct market research. Deletion of these types of cookies may result in limited functionality of our service.

Advertising cookies and resettable device identifiers:hese cookies and resettable device identifiers use information about your use of this and other websites and apps, your response to ads and emails, and to deliver ads that are more relevant to you.

When we advertise our services on other websites or apps, some of the websites and apps where we advertise, as well as advertising technology companies that we use to purchase, deliver, optimize, and/or measure our advertisements (collectively “Advertising Partners”), may receive information from us as part of our campaign targeting, measurement, and optimization (e.g., steps completed in sign-up and site visit or app open/install information). Common uses of this type of information are to judge the effectiveness of and optimize ad campaigns, by allowing Advertising Partners to see when someone who saw an ad later signed up for our service. Another common use is to make sure we do not serve ads trying to get individuals to sign up for the HotShorts service if they are already a HotShorts user. HotShorts uses contractual and technical measures designed to prevent Advertising Partners from accessing information regarding specific title selections you make, URLs you land on, or shows you have watched on our service. We do not share information about title selections or your shows you have watched on our service.

In connection with our ad supported subscription plans, HotShorts, our Ad Service Providers, and Ad Measurement Companies can use these technologies to operate and support our ad supported subscription plans, including supporting an Advertiser’s ad campaigns, measurement, and optimization of the same.

How can I exercise choice regarding these technologies?

To exercise choice regarding cookies For more information about cookies set through our applications, as well as other types of online tracking (including the collection of information by third parties about your online activities over time and across third-party websites or online services for online behavioral advertising), and to exercise choices regarding them. At this time, we do not respond to web browser “do not track” signals. Exercising choice over cookies is specific to that web browser or device. If you subscribe to an ad supported subscription plan and wish to exercise your choices, you can exercise such choices by accessing the ad supported subscription plan controls described in the section “Behavioral Advertising” above.

To exercise choice regarding resettable device identifiers

To opt out of behavioral ads from HotShorts in connection with an resettable device identifier on a mobile device, tablet, or streaming media devices, please configure the appropriate setting on your device (usually found under “privacy” or “ads” in your device’s settings). You may still see HotShorts ads on your device, but they will not be selected based on your likely interests. Exercising choice over a resettable identifier is specific to that device. If you subscribe to an ad supported subscription plan and wish to exercise your choices, you should access the ad supported subscription plan controls described in the section “Behavioral Advertising” above.

To exercise choice using self-regulatory program resources

To exercise choice regarding other technologies

There are a number of ways to exercise choice regarding technologies that are similar to cookies, such as browser storage and plugins (e.g., HTML5, IndexedDB, and WebSQL). For example, many popular browsers provide the ability to clear browser storage, commonly in the settings or preferences area; see your browser’s help function or support area to learn more. Other technologies, such as Silverlight storage, may be cleared from within the application.

Your Information and Rights

You can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you. You may also request that we delete personal information that we hold about you.

When you visit the “My”or“Me”, you have the ability to access and update a broad range of information about your account, including your payment information, and various related information about your account (such as the content you have viewed ).

For other requests. For more information about how to access your information, including our verification process. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Please also see the “Your Choices” section of this Privacy Statement for additional choices regarding your information. We may reject requests that are unreasonable or not required by law, including those that would be extremely impractical, could require disproportionate technical effort, or could expose us to operational risks such as enabling fraud.

Retention of information: We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes and to fulfill the purposes described in this Privacy Statement. Specifically, we retain information for our legitimate interests and essential business purposes, such as operating, maintaining and improving our services; complying with our legal obligations; and exercising our legal rights and remedies, including enforcing our terms of use. Our retention of information is based on many factors such as your relationship with HotShorts (for example, are you a HotShorts current user); the nature of the information; compliance with our legal obligations; defending or resolving actual or anticipated legal claims. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required. For information about deletion, removal and retention of information.

Security

We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, we cannot guarantee the security of your personal information.

Changes to This Privacy Statement

We will update this Privacy Statement from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of the HotShorts service after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes. If you do not wish to acknowledge or accept any updates to this Privacy Statement, you may cancel your use of the HotShorts service. To see when this Privacy Statement was last updated, please see the “Last Updated” section below.

We use personal information to provide, analyze, administer, enhance and personalize our services and marketing efforts, to provide, analyze, administer, enhance and select ads in connection with our ad supported subscription plans, to process your registration, your orders and your payments, and to communicate with you on these and other topics. For example, we use such information to:

provide you with customized and personalized viewing recommendations for videos we think will be of interest to you (collectively “content”);

determine your general geographic location (such as your city, state/province, and country);

provide localized content;

determine your ISP to support network troubleshooting for you (we also use aggregated ISP information for operational and business purposes);

help us quickly and efficiently respond to inquiries and requests;

to coordinate with Partners on making the HotShorts service available to users and providing information to non users about the availability of the HotShorts service, based on the specific relationship you have with the Partner;

prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and to enforce our terms (such as determining whether and for which HotShorts signup offers you are eligible and determining whether a particular device is permitted to use the account consistent with our Terms of Use);

analyze and understand our audience, improve our service (including our user interface experiences) and optimize content selection, recommendation algorithms and delivery;

communicate with you concerning our service so that we can send you notices about HotShorts, details about new features and content available on HotShorts, special offers, promotional announcements, consumer surveys, and to assist you with operational requests such as password reset requests. These communications may be by various methods, such as email, push notifications, text message, online messaging channels, and matched identifier communications (described below). Please see the “Your Choices” section of our Privacy Statement to learn how to set or change your communications preferences.

Identifiers: We may disclose identifiers for business purposes with the following categories of third parties: Service Providers, Partners, an entity engaged in a business transfer, law enforcement, courts, governments and regulatory agencies. In the context of an ad supported subscription plan, certain identifiers may be shared with our Ad Service Providers, Ad Measurement Companies and Advertisers.

Commercial information:We may disclose commercial information for business purposes with the following categories of third parties: Service Providers, Partners, an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies. In the context of an ad supported subscription plan, certain pieces of commercial information may be shared with our Ad Service Providers, Ad Measurement Companies and Advertisers.

Internet or other electronic network activity information:We may disclose these types of information for business purposes with the following categories of third parties: Service Providers, Partners, an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies. In the context of an ad supported subscription plan, certain Internet or other electronic network activity information may be shared with our Ad Service Providers, Ad Measurement Companies, and Advertisers.

Geolocation data:We may disclose geolocation data for business purposes, including HotShorts’s own marketing, with the following categories of third parties: Service Providers, Partners, an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies. In the context of an ad supported subscription plan, geolocation data may be shared with our Ad Service Providers, Ad Measurement Companies, and Advertisers.

Audio, electronic, visual, thermal, olfactory or similar information:We may disclose these types of information for business purposes with the following categories of third parties: Service Providers, Partners, an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies.

We do not knowingly sell, share or use the personal information of minors under 18 years of age.

Retention of Personal Information.We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes and to fulfill the purposes described in our Privacy Statement. Specifically, we retain information for our legitimate interests and essential business purposes, such as operating, maintaining and improving our services; complying with our legal obligations; and exercising our legal rights and remedies, including enforcing our terms of use. Our retention of information is based on many factors such as your relationship with HotShorts (for example, are you a HotShorts current member); the nature of the information; compliance with our legal obligations; defending or resolving actual or anticipated legal claims. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.

Contact Us

If you have any questions or comments about this Policy, the ways in which we collect and use your information described above, or wish to exercise your rights provided in the section“Your Information and Rights”, please do not hesitate to email us at the following email address: hotshortscustomer@gmail.com