Sfera Privacy Policy

Overview

Deluxe Media Inc. and its affiliates and subsidiaries (“Deluxe”) is committed to protecting your privacy when you communicate with us, or access and use www.sferastudios.com (the “Website”), its content, the Sfera platform (“Platform”), or any activities that we engage in (collectively, “Activities”). The purpose of this Privacy Policy is to inform you about the types of information we might collect about you when you visit the Website, use the Platform, speak with us on the phone, or correspond with us, how we may use that information, and whether we disclose that information to third parties.

The Information We Collect and Process

As part of Deluxe’s ordinary business practices, Deluxe collects and processes your personal information that we obtain when you register for, access or use the Website and the Platform and interact with us. This data is described below and is hereinafter referred to collectively as “Personal Information,” and includes:

1. Information which you provide to Deluxe about yourself (including by means of uploading or inputting information on the Platform or connecting to the Platform) - your title, name, email address, postal address, telephone number, information about your computer, including where available your cookies, IP address, operating system and browser type, and any other personal or financial information provided by you such as payment details, ID documentation and biographical details (such as your career experience and language skills); and
2. A record of any correspondence between you and Deluxe.
3. Information which Deluxe creates pertaining to you, your work for Deluxe and your activities on the Platform (such as your job history on the Platform, the ratings which we assign to you and skill certifications which you have completed on the Platform).

The provision of personal information by you is necessary in order for us to provide you with certain services and where in our legitimate interests for the performance of a contractual relationship with you or the efficient conduct of our business.  You are under no obligation to provide this information, but if you do not, then we may not be able to approve your application, provide you with certain information, or allow you to access certain pages of our Website or areas of the Platform.

How We Use the Information We Collect and Process

Deluxe may use Personal Information for the following purposes: (i) to establish or maintain our relationship with you; (ii) to contact you and respond to your requests and inquiries; (iii) to operate the Website and the Platform and procure and manage services provided by you via the Platform; (iv) to keep you informed of operational aspects of the Website and the Platform (such as newly available training modules or features or service unavailability) (v) to personalize your experience with us and to assist you while you use the Website or the Platform; (vi) for business administration, including statistical analysis; (vii) to improve the Website and the Platform by helping us understand who uses the Website and the Platform; (viii) to provide services to our customers utilizing the services provided by you to us via the Platform; and (ix) for fraud prevention and detection and to comply with applicable laws, regulations or codes of practice.

We may disclose Personal Information to our affiliates and subsidiaries and to our service providers to the extent necessary to enable them to perform certain Website or Platform-related services (for example, web hosting, to improve Website or Platform-related services and features, or for maintenance services) on our behalf. All service providers are required to comply with the privacy practices and policies of Deluxe and are permitted to use data only for the purpose of performing services on our behalf. We also reserve the right to disclose Personal Information to a purchaser or potential purchaser of Deluxe or any of its business units, or their respective advisers but will always ensure that such disclosure is on the basis that compliance with the privacy practices and policies of Deluxe are required. We furthermore reserve the right to disclose such information to any third party if we believe that we are required to do so for any or all of the following reasons: (i) by law; (ii) to comply with certain legal processes or governmental requests; (iii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of our websites, the Platform or our network; and/or (iv) to protect the rights, property, or safety of Deluxe and its affiliates, their partners, and employees, the users of our websites, the Platform, or the public.  We will not disclose Personal Information to any other third parties without your approval.

Your Personal Information and Security

You acknowledge that you have all rights necessary to authorize Deluxe to collect and process the Personal Information in the ways envisaged by this Privacy Policy.

All Personal Information you provide to Deluxe is stored on secure servers. Any payment transactions or exchange or disclosure of your Personal Information will be encrypted using appropriate technology. You are responsible for maintaining the confidentiality of any usernames or passwords provided to you or that you select, which are associated with any account that you use to access the Platform and for monitoring all activity under your account. If you become a registered user, you may not disclose or share your username or password with any third parties or use them for any unauthorized purpose. You shall be deemed responsible and you agree to assume full responsibility for all activities, acts or omissions of anyone that occur under your account. If you become aware of any unauthorized use of your password or your account you agree to notify Deluxe immediately at the email address provided at the end of this Privacy Policy or at the end of the Terms of Use.

Unfortunately, the transmission of information via the Internet is not completely secure. Although Deluxe will use reasonable efforts to protect your Personal Information, it cannot guarantee the security of your information transmitted over the Internet to the Website or the Platform. Any transmission is at your own risk. Once Deluxe has received your Personal Information, it will use reasonable procedures and security features to try to prevent unauthorized access.

Deluxe retains Personal Information for as long as reasonably necessary to fulfil the purposes for which such Personal Information was collected and in compliance with applicable laws. In the event that you cease to provide services to us via the Platform and we close your account, we may nonetheless retain certain items of Personal Information which we require (i) for the purposes of our internal business administration and record-keeping and the provision of services to our customers; (ii) to allow your account to be re-activated efficiently should we agree that you commence providing services to us again via the Platform; or (iii) to ensure that you do not open a new account on the Platform without our approval.

Cookies

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognise a user’s device. You can find more information about cookies at http://www.allaboutcookies.org and http://www.youronlinechoices.eu for a video about cookies visit https://www.google.com/policies/technologies/cookies/.

Cookies perform different functions such as letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. A list of the cookies that may be used on the Sites is set out below:

• Strictly necessary cookies are essential in order to enable you to move around the Sites and use its features, such as accessing secure areas of the Sites. Without these cookies, certain services you have asked for cannot be provided.
• Performance cookies collect information about how you use the Sites, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information that these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
• Functionality cookies allow the Website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.

Changes to the Privacy Policy

Deluxe may update this Privacy Policy at any time without notice, and without liability of any kind, to you or any third party.  Deluxe will handle your information in accordance with the version that was in place when you submitted it. We will notify you of any changes by posting the new Privacy Policy on the Website. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use, which are available on our Website at https://www.sferastudios.com/site/privacypage/terms

You acknowledge and agree that it is your responsibility to review, and that you will review, this Privacy Policy prior to using the Website or the Platform to ensure you are acting under and aware of the current version. Any disputes arising under this Privacy Policy shall be governed by the Privacy Policy in effect at the time the claim or dispute arose.

Questions, comments and requests in relation to this Privacy Policy should be sent to Deluxe via email at privacy@bydeluxe.com, or via regular mail to:

Deluxe Media Inc.

2130 N. Hollywood Way,

Burbank,

CA 91505