Privacy Policy

This Privacy Policy explains the information that Display Europe collects when you use its products and services, how that information is used, with whom it may be shared, and your privacy choices. With this privacy policy we inform both platform visitors and registered users (video/audio/text owners) about the data processing associated with our products and services.

1. Who we are and what we do

This Privacy Policy covers Display Europe Coop (collectively, “Display Europe,” “we” “us” or “our”). We provide online video/audio/text hosting, sharing, and related services through our owned-and-operated websites, including https://displayeurope.eu. and our embeddable video players (collectively, the “services”). We are the controller according to Art 4 No 7 GDPR for the data processing related to the use of the platform as a platform visitor.

Acceptance and Changes

By registering for, downloading, or using our services, you accept this Privacy Policy. We may modify this Privacy Policy from time to time. We will post any modified version of our Privacy Policy at https://displayeurope.eu. If we change the Privacy Policy, we will announce such publicly and we will provide notice to registered users by email or other methods.

2. Children’s Privacy

We do not knowingly collect personal information from individuals who are under the minimum required ages specified herein. You must be at least 16 years old to use our services. Individuals under the applicable age may use our services only through a parent or legal guardian’s account and with their involvement. If you are a parent or legal guardian who believes your child has provided personal information to Display Europe without your consent, you may ask us to delete such information by contacting us at privacy@displ.eu. 

3. Data We Collect About You

We collect information about you when you use our services. In addition, third parties may collect information about you when you use our services. Collected information may include or reflect personal information that could identify you (personal data according to Art 4 No 1 GDPR), as well as non-personal information. 

Financial Information – Subscription

When you donate to us, we process the data necessary for the payment. The legal basis for this is the contractual relationship of the donation according to Art 6 (1) lit b GDPR. In addition, we are required by law to keep your data, e.g. to report large donations to the tax office (§ 121a BAO) and to comply with our tax obligation (§ 131 BAO). Your data will also be processed by the respective payment provider you choose for payment. These have their own privacy policies.

3.1 Specific data protection information for platform visitors

Automatically-Collected Information

We automatically collect certain types of data when you use Display Europe as a platform visitor. Depending on the respective service that we have integrated for the use of our service, this data may include your IP address, the web page you visited or search query you entered before reaching us, User ID, location, date and time, title and URL of the page being viewed, screen resolution, pages generation time, technical information about your device (device type, unique device identifiers, operating system, browser data like user agent and main language), media and form interactions and your usage behavior (likes, views, unique viewers, average audience retention, total viewing time, viewer binding time, listening seconds, number of first clicks on play button, login attempts).We may track your activities using cookies and similar technologies whereas we only use technically necessary cookies.

Some registered users and third parties may collect data about you when you use our services. This may include your IP-address when you use our service (PeerTube).

For the purpose of operating our services, we use this data to provide our service and comply with our contractual obligations to our registered users. We also use this data for the purpose of improving our services to understand how our services are being used and how we can improve them. In general, we analyze aggregated data, rather than specific user data. We may, however, need to analyze a specific case to address a specific problem (e.g., a bug that affects only a few accounts). Also for the purpose of customizing, we use this data to personalize the service to you (which may include remembering your preferences for language or volume or displaying videos/audios/texts that you might enjoy, based upon your viewing choices).

Capture Forms

You may submit information through a form set up by a registered user (video/audio/text owner) or webinar host. This information will be received by both Display Europe and the registered user and is subject to both Display Europe’s Privacy Policy as well as the registered user’s privacy policy. Except where Display Europe is the video/audio/text owner, Display Europe will not use any information you submit through such forms for direct marketing purposes.

For the purpose of operating our services, we use this data to provide our service. 

Other Information You May Submit

You may submit data to us for limited purposes such as requesting customer support; participating in a study or survey; entering contests; applying for a job; or signing up to receive communications from us or another user.

For the purpose of communication, we use this data when we communicate with you.

Further purposes of processing your data

Exercising our rights
 Where reasonably necessary, we use your data to exercise our legal rights and prevent abuse of our service. For example, we may use your data to detect and prevent fraud, spam, or content that violates our Terms of Service.

Legal compliance
 We use your data where we are legally required to do so. For example, we may need to gather your data to respond to a subpoena or court order.

Protecting your information
 Where appropriate, we may anonymize, backup, and delete certain data.

We may use algorithms and other automated means to implement any of the above, but we don`t perform automated decision-making including profiling.

3.1.2 Legal basis for data processing

Whenever we process your data for one of these purposes, we have determined that one or more of the following lawful bases apply:

• Legitimate interest;
• Compliance with a legal obligation; or
• Consent

3.1.3 Data Storage

We store personal data only for as long as is necessary to ensure the fulfilment of the stated purposes or for as long as we are legally obliged to do so.

In the case of services where claims for damages or other titles are asserted, for the required period (between 3 and 30 years).

In the case of enquiries (contacting us): Personal data that you voluntarily disclose to us will be stored by us for the purpose of providing the associated processing and evidence (for up to 3 years after completion or termination), unless a longer storage period is also required for the purpose of fulfilling a legal obligation or for asserting or defending legal claims.

3.2 Specific data protection information for registered users

Account Information

To create an account, you must provide a valid email address and password. If you choose to sign up and/or authenticate using a third-party account (e.g., Facebook, Google), you authorize us to obtain account information from the third-party platform.

For the purpose of identification and authentication, we use this data to verify you when you access your account.

Content You Submit

You may upload and create content such as videos, audio, text, photographs, and artwork. For that you need to sign a user agreement with us. Your account profile may display information about you and your activities. This information may be accessed by others. Your videos may be viewed and otherwise accessed by others, and associated metadata (e.g., titles, closed captions, descriptions, tags, etc.) may be viewable by others. You may choose to limit the availability of your profile and videos/audios/texts.

Your interactions during events such as live streams and webinars, or with other users (e.g., comments, emojis or likes, poll responses) may be seen by others. Such contributions may be replicated to other nodes of the Fediverse, that have subscribed Display Europe channels or feeds.

For the purpose of operating our services, we use this data to provide our service and comply with our contractual obligations to you. We also use this data for the purpose of improving our services to understand how our services are being used and how we can improve them. In general, we analyze aggregated data, rather than specific user data. We may, however, need to analyze a specific case to address a specific problem (e.g., a bug that affects only a few accounts).

Other Information You May Submit

You may submit data to us for limited purposes such as requesting customer support; participating in a study or survey; entering contests; applying for a job; or signing up to receive communications from us or another user.

For the purpose of communication, we use this data when we communicate with you.

Further purposes of processing your data

Exercising our rights
 Where reasonably necessary, we use your data to exercise our legal rights and prevent abuse of our service. For example, we may use your data to detect and prevent fraud, spam, or content that violates our Terms of Service.

Legal compliance
 We use your data where we are legally required to do so. For example, we may need to gather your data to respond to a subpoena or court order.

Protecting your information
 Where appropriate, we may anonymize, backup, and delete certain data.

We may use algorithms and other automated means to implement any of the above, but we don`t perform automated decision-making including profiling.

3.2.1 Legal basis for data processing

Whenever we process your data for one of these purposes, we have determined that one or more of the following lawful bases apply:

• Performance of a contract;
• Legitimate interest;
• Compliance with a legal obligation; or
• Consent

3.2.2 Organization-Administered Accounts

You may create a Display Europe account using an email address provided or assigned to you by an organization (such as your work email address). If the organization establishes a direct relationship with us, they may convert your personal account to become part of the organization’s account.

This means the organization may:

• Access information about your account activity;
• Take control of the account, including any content whether uploaded before or after the date that the organization converts your account to the organization’s account; and/or
• Delete your account.

If you sign up for a Display Europe account using an email address issued to you by an organization, Display Europe may share your personal information (e.g., name, email address) with such organization. If you do not want an organization to access or otherwise control an account, use a personal email address and do not use an organizational email address when creating an account.

3.2.3 Your Privacy Choices

We enable you to make numerous choices about your data:

• You may choose not to provide us with certain information. For example, you may choose not to create an account or not to provide optional account information.
• You may change your account and video/audio/text privacy settings.
• You may change or correct information voluntarily submitted to us. We encourage you to keep your data current by viewing your settings page.
• You may opt out of receiving commercial emails from us.
• You may limit the use of cookies.
• You may backup your videos/audio/texts.
• You may close your account (which will delete all videos/audio/texts) or delete certain videos/audio/texts.
• Users in certain jurisdictions may have additional rights.

3.2.4 Account and Video Privacy Settings

As part of our services, we offer you the ability to limit the distribution of your content, including your videos/audio/texts. This section explains some of your choices.

Videos/Audio/Texts

We enable you to manage the privacy settings of your videos/audio/texts. On https://displayeurope.eu, for example, your options, which depend on your subscription plan, may include:

Public: Your video/audio/text will be publicly available.

Private: Your video/audio/text will be available to you and authorized Team Members.

Unlisted: Your video/audio/text will be available to anyone who has the unique URL.

Internal: Your video/audio/text may be accessed by anyone on the same server, but will not be federated to other servers.

You may change a video/audio/text`s privacy settings at any time. Changes will be applied on a go-forward basis.

You may create a sharable link to your content for the purpose of sharing your content with others or embedding your content on a third-party website (including your own). Creating such a sharable link will override your privacy settings and will allow anyone who enters the link in a browser to view your content without restriction. Similarly, embedding your content on a publicly-available website will allow the public to view your content regardless of your privacy settings.

You should exercise caution in granting access to others (whether through link sharing or passwords). Once you have granted access to someone else, you lose a degree of control over the distribution of your content as those persons may share the password and/or link with other people.

Regardless of your profile or video/audio/text privacy settings, Display Europe reserves the right to inspect them for compliance with its Terms of Service, to provide customer support, or to address technical issues.

3.2.5 Communications from Us

Emails

If you create an account, you may receive emails from us. This includes newsletters and offers. You may always opt out from receiving commercial messages in your account settings. Please note that any opt-out request may take several days to process, and you will continue to receive transactional emails from us (e.g., emails confirming transactions and/or providing information about your account).

3.2.6 Data Storage

We retain your data for as long as you have an account. When you close an account, we will delete its content, including its videos/audio/texts. We may retain logs of automatically collected information (for internal analytics and security purposes); your email address; communications with you; and your transactional information (for auditing, tax, and financial purposes). When we no longer have a business reason for retaining data, we will delete or anonymize it.

We retain deleted videos/audios/texts on our servers for a short period in case you wish to reverse deletion. Once we delete a video, we may not be able to recover it. If you have previously made a video public, the video or its thumbnail may be discoverable in a search engine’s cache for a time. We have no control over search engines.

It is also pointed out here that the processing concerned here is carried out for journalistic purposes, to which the media privilege according to § 9 (1) DSG in conjunction with Art 85 GDPR applies.

If we receive legal process pertaining to your account, we will retain your data for as long as we in good faith believe is necessary to comply with the legal process. Similarly, if we believe that your account has been involved in wrongdoing, we may preserve your data to defend or assert our rights.

4. With Whom We Share Your Data

We share data with third parties as follows

• As you instruct as a registered user: We may make your profile and videos/audios/texts available to others as you instruct in using our services.
• With your consent: We may share your data with third parties where we have obtained your express consent to do so.
• Authorized vendors: We may share your data with third-party vendors that help us operate our services and comply with your instructions and our contractual obligations. This includes content delivery networks (CDNs), cloud-based hosting services, monitoring services, email service providers, quality assurance and testing vendors, fraud and abuse prevention vendors, customer relations management (CRM) vendors.
• Analytics: We may share your data with analytics providers which help us understand how customers are using our services. We may also share identifying analytics information with the hosts of webinars you attend, or users of your organization-administered account (see below for more details).
• Affiliates, Content-Partners and advisors: We may share your data with our auditors and advisors for planning, financial reporting, accounting, auditing, tax filings, and legal compliance. We may share your data with our affiliates to the extent necessary to provide you with the services ordered.
• Certain legal situations: We may share your data where we believe disclosure is necessary to comply with a legal obligation.
• Aggregated or anonymized information: We may publicly disclose non-personal aggregated or anonymized information such as our number of visitors and registered users.

We use reasonable efforts to vet third party services embedded in our platform for their privacy and data security practices. We require that such vendors agree to protect the data we share.

Specifically, we have integrated the following services as part of the use of our services:

• Matomo – it is an open source web analytics platform, which collect, analyse and report visitors data for purposes of understanding and optimizing websites
• PeerTube – it is a tool used by us to create our video hosting website
• CBA Portal – it is a civil society media and communication platform
• WordPress – it is a free content-management-system

5. Legal and Safety-Related Disclosures

We may disclose your data in response to official requests (e.g., court orders, subpoenas, search warrants, national security requests, etc.) (“requests”) that we receive from government authorities or parties to legal proceedings.

We handle EU law enforcement requests in accordance with Austrian law. If the request originates from a foreign jurisdiction, we will typically disclose information where we in good faith believe that disclosure is permitted by both Austrian law and local law. In all cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

We may disclose user data where we reasonably believe that someone’s life is at risk. For example, if we become aware of a person threatening to commit suicide, we may share that person’s data with appropriate entities that may have the ability to help.

We may disclose user data to report suspected crimes. We report content suspected of exploiting minors along with the data identifying the uploading user.

We may disclose user data in situations involving legal claims against us or one of our users. If you submit a Digital Millennium Copyright Act (DMCA) or other takedown notice, we may share that notice with the affected user. If you challenge such a notice, we may share your response with the complainant.

We may share your data with potential transaction partners, advisors, and others in the event our platform is, in whole or part, acquired by a third party. In such case, we will use reasonable efforts to require the acquiring entity to comply with this Privacy Policy.

6. Protecting Your Information

We use physical, technical, and organizational security measures to safeguard your data from unauthorized or accidental disclosure. Despite these efforts, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. Users also have a role to play in keeping their data safe. We encourage you as a registered user to use a unique and hard-to-guess password for your account and to not share it with others. You should only grant access rights to people whom you know and trust, and, even then, you should be careful in granting all access rights. You should monitor your account regularly. If you believe that someone has gained access to your account without your permission, please contact us immediately so that we can investigate.

7. Your Responsibilities

You may receive other people’s data in using our service. If you receive information from other users, you as a registered user must process that information in compliance with your published privacy policy and all applicable laws, including those concerning privacy, data security, and online marketing.

8. Third-Party Services

We may provide access to online services that we do not own or operate via hyperlinks or integrations. These services fall outside of this Privacy Policy, and we have no control over the data they collect. Once on a third-party site, your data may be collected by others.

You may use our service through third-party sites. For example, you may watch a video that is embedded on a third-party site or use one of our apps on a third-party platform. This Privacy Policy covers our apps and video players, but does not cover any third-party site or any third-party video player.

9. International Data Transfers

Location of Data

Display Europe is based in Vienna, Austria. We provide services globally, using computer systems, servers and databases located in Austria and Germany. When you use our services from outside of the EU, your information may be transferred to and processed in the EU. However, there is no intention to transfer data outside the EU and if data from outside the EU are transferred this doesn’t resemble a third country transfer in the meaning of chapter V of GDPR.

10. How to Contact Us

For any questions, inquiries, or complaints relating to your privacy, please contact us at:

Display Europe Attention: Data Protection Coordinator privacy@displayeurope.eu. Please provide us with enough information to identify you (e.g., your full name, email address, and any other information we may need to process your request). We may also request that you provide additional information to confirm your identity.

11. Rights of the data subject

Provided that the respective legal requirements are met, you can assert the following data subject rights:

Right to information: you can request confirmation as to whether personal data relating to you is being processed and request information about this data and the information pursuant to Art 15 DSGVO.

Right to rectification if we process inaccurate or incomplete data about you (Art 16 GDPR).

Right to erasure of personal data concerning you, if the conditions of Art 17 DSGVO are met.

Right to restrict the processing of your data (Art 18 GDPR).

Right to data portability of your data provided to us, if the processing is based on consent (Art 6 (1) lit a) or on a contract (Art 6 (1) lit b) to which you are a party and the processing is carried out with the help of automated procedures (Art 20 GDPR).

In the case of processing based on legitimate interests (pursuant to Art 6 (1) lit f of the GDPR), you have the right to object to the processing of your personal data pursuant to Art 21 of the GDPR, provided that there are grounds for doing so that arise from your particular situation. In the case of processing for the purpose of direct marketing, this right exists without restrictions.

You can withdraw given consent to the processing of personal data at any time, please contact us (see in Section 10). The withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the withdrawal.

We enable the exercise of these rights primarily through our services (which we reserve the right to modify). For example, we allow users under certain circumstances in balance with the public interest of a public archive to change their information, download their videos, and close their accounts. We also fulfill our obligations in response to direct requests. We will endeavour to process requests not later than within one month. Please note that we may not be able to comply with requests to the extent that they would cause us to violate any law or infringe upon any other person’s rights. We reserve the right to request appropriate identification in cases of reasonable doubts regarding the identity of the requesting person. We will process requests free of charge unless they would impose an unreasonable cost on us.

Right of complaint: You also have the right to complain to the competent supervisory authority if you believe that the processing of personal data concerning you violates the GDPR or your data subject rights have been violated. To do so, you can either contact the competent supervisory authority in your place of residence or the authority responsible for in Austria, which can be reached at the following contact address:

Austrian Data Protection Authority (DPA)
Barichgasse 40-42, A-1030 Vienna
Telephone: +43 1 52 152-0
E-mail: dsb@dsb.gv.at
Web: https://www.dsb.gv.at

We request that in cases where you were not completely satisfied with our work, you first contact our Data Protection Coordinator at the address listed in Section 10 so that we can have an opportunity to correct any errors.

12. Miscellaneous

12.1 Cookies and Similar Technologies

We use cookies and similar technologies on our websites, but only technically required ones.

12.3 Do Not Track Disclosures

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.

 

Last Updated: September 21 2023