Privacy Notice
Last Modified: February 13, 2024
Introduction
Aylo Freesites Ltd (hereinafter “we”, “us” or “our”) operates the website https://redtube.com/ (hereinafter “RedTube") and is the controller of the information collected or provided via RedTube and its affiliates.
Please read this Privacy Notice carefully, as your access to and use of RedTube signifies that you have read and understand all terms within this Privacy Notice. We respect your privacy and are committed to protecting your personal data.
If you have any questions about our privacy practices, please see the section “Contact Information” below for information on how to contact us.
1. Scope
For the purposes of this Privacy Notice, “process”, “processed” or “processing” means any operation or set of operations performed on personal data or on sets of personal data (excluding disclosure thereof), whether by automated means, including one or several of the following operations: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, alignment or combination, restriction, erasure or destruction. Information on disclosure of personal data or of sets of personal data may be found in the "Disclosure of Your Personal Information” section below.
This Privacy Notice applies to information we collect:
- on RedTube,
- and your communications with RedTube, via email, online support chats, phoneline support or otherwise.
2. The Data We Process About You
We may process different kinds of personal data about you, depending on whether you chose to create an account with us.
Persons who visit RedTube without logging in or registering (“Unregistered Users”):
- Contact Data: We will only process your email address or any other information which you voluntarily provide to us at your direction for a specific function, namely, to participate in a contest or survey.
- Online Forms and Communication Data: We process Contact Data and other information that you submit through online forms provided on RedTube or information send to us via email, online support chats or such as information provided in the context of support requests or any other inquiries, the content reporting and moderation of content, and our internal complaint handling system.
- Website activity data: We process information about how you use RedTube and interact with content and advertisements, including the pages you visit on and search history on RedTube, and the referring web page from which you arrived on RedTube from. We process browser and operating system information, devices you use to access RedTube and your time zone setting. We also process online identifiers. Specifically, we process internet protocol (IP) address information and we set cookies as explained below in the section on "Cookies and Automatic Data Collection Technologies"
- Identifiers: Some users may be asked to provide identifiers (including government-issued photo identification as well as other documentation) in order to verify that they are over the age of majority required to have access to the Website and to view their contents. In such cases, this information is processed by trusted third party age verification service providers. This Privacy Notice does not apply to the privacy practices of these third-party age verification service providers. Read the privacy terms and conditions of these service providers carefully.
Persons who choose to create an account on RedTube (“Registered Users”): we process the same categories of information described above for Unregistered Users, and additionally the following information:
- Contact Information: We process username and email addresses. If you choose to register through a third-party platform, we will collect certain personal information from those platforms.
- User Submitted Personal Information: We process information you submit in order to personalize your account or for a specific function, for example your date of birth, age, gender, your interests, preferences, feedback, survey responses, your preferences in receiving marketing from us and our third parties, and your communication preferences, as well as any other information which you voluntarily provide to us at your direction for a specific function.
- Identifiers and Biometric Information: You may be asked to provide identifiers (including government-issued photo identification as well as other documentation) to verify your identity and that you are over the age of majority required to access RedTube and to view the contents. We also process biometric information to verify the authenticity of the identifiers you provide to us while registering to RedTube as further explained in the section “Biometric Information” below. This information is processed by trusted third party age verification service providers. This Privacy Notice does not apply to the privacy practices of these third-party age verification service providers. Read the privacy terms and conditions of these service providers carefully.
- User Contributions including Audio/Video Information: We provide areas on RedTube where you can post information about yourself and others, communicate with others, upload content (e.g., pictures, video files, etc.), and post comments or reviews of content found on RedTube.
Please use caution in providing user contributions. By providing user contributions you are making that content and information publicly available. User contributions can be read, collected, used, and disclosed by others, and we cannot control who accesses your user contributions or what other users may do with the information you voluntarily post or submit. User contributions are governed by the RedTube terms of use found at https://www.redtube.com/info/terms
We may process your data to produce and share aggregated insights that do not directly or indirectly identify you and are not associated with you. Such aggregate information is not personal information.
RedTube is forbidden of access to persons under the age of 18 or the applicable age of majority in the jurisdiction from which RedTube is accessed (“minors”), and we therefore prohibit minors from using RedTube. As indicated throughout this Privacy Notice, some users may be asked to provide some information to us and our service providers to verify that you are over the age of majority required to have access to RedTube and to view the contents. We do not knowingly process personal information from minors. If you are the parent or legal guardian of a minor who has provided us with personal information, then please contact us at support@redtube.com to have that minor’s personal information deleted.
3. The Sources from Which We Process Personal Information
We process Personal Information in the following ways:
- Directly from you: We process the categories of information listed above directly from you.
- Automated technologies or interactions: As explained in the section below on Cookies and Automatic Data Processing Technologies, we set cookies and other automatic techniques to process website activity data when you visit RedTube or another website owned by our corporate group.
- Third-Party Single Sign-on: We may obtain information if you create or sign-in your account through a third-party platform (such as Google), we will have access to certain information from that platform such as your name, email address or such other information you may have submitted and allowed this third party to share.
4. Purposes for Which We Process Your Personal Information
We process personal information for the purposes described below.
- Provision of services: We process identifiers, website activity data, and, additionally, for Registered Users, Contact Data, and user contributions, including any interactive features on RedTube, to verify your eligibility and deliver prizes in connection with contests and sweepstakes.
- Customer management (Registered Users Only): We process identifiers and Contact Data to manage Registered Users’ account, to provide customer support and notices to the Registered User about their account, and notices about changes to RedTube or any products or services we offer or provide through them. We process identifiers and biometric information for the purpose of verifying your identity and the authenticity of the identifiers you provide to us while registering for certain services on RedTube.
- Customization of content and marketing (Unregistered Users and Registered Users): We process for both Registered Users and Unregistered Users, identifiers and contact information, website activity data; and for Registered Users, user submitted personal information and user contributions to analyze your use of, or interest in, our Website’s content, products, or services, in order to develop and display content and advertising tailored to your interests on our Website.
- Communications and handling of requests: We process Online Forms and Communications Data and other information as necessary to respond to and resolve any of your requests, including where this is required to ensure compliance with our legal obligations.
- Analytics: We process identifiers and website activity data to determine whether users of RedTube are unique, or whether the same user is using RedTube on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed, demographic patterns.
- Functionality and security: We may process any of the categories of data we process to diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement.
- Compliance: We may process any of the categories of data we process to enforce our terms and conditions and to comply with our legal obligations. In certain jurisdictions, this includes our legal obligation to verify the age of users having access to RedTube.
- Hash Values: We may create hash values from any of the categories of data we process, such as infringing or illegal content to train our models to detect, prevent, and combat illegal activities including fraud, sexual assault, or exploitation. We reserve the right to share any hashes with law enforcement agencies.
- Information you provide: We will process contact information and user submitted personal information in any other way we may describe when you provide the information or for any other purpose with your consent provided separately from this Privacy Notice.
5. Our Legal Bases Under Canadian and European Union (EU) Privacy Law
To the extent required by applicable law, we rely on several lawful bases to use your data in these ways. This means we process your personal data only where:
- You provide your consent to do so for a specific purpose: for example, when you allow us to show you personalized ads or to send you e-mail marketing. Biometric information is also processed based on your consent. You may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any collection, use, processing, or disclosure that occurred prior to the withdrawal.
- It is necessary to perform our contract with you: for example, to create your account and provide our services.
- It is necessary to comply with our legal obligations: for example, we may be required to collect, use or disclose your information in connection with civil, criminal, corporate, taxation, regulatory matters or litigation.
- It satisfies a legitimate interest (which is not overridden by your data protection interests): for example, to keep RedTube safe and secure from fraud and illegal activities.
- It is used to protect your or others’ vital interests: for example, in case of emergency or to prevent a crime or fraud.
- It is used for tasks carried out in the public interest: for example, to combat unlawful behaviour where it is in the public interest to do so and where the public interest is laid down by applicable law.
Depending on the circumstances, we may rely on different legal bases when processing your same information for different purposes. If you reside outside the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”), the legal bases on which we rely may differ from those listed above.
6. Disclosure of Your Personal Information
We disclose personal information:
- To the public: When you submit user contributions including audio/video content, you are using RedTube and services to make that information public.
- Within our corporate group: We may disclose any of the categories of personal information to members of our corporate group (including affiliates and related entities) to the extent this is necessary for our purposes listed in the sections above.
- Service providers: We disclose the categories of personal information we process to our authorized service providers that perform certain services on our behalf. These services may include, identity and document authenticity verification including biometric processing, age verification, risk and fraud detection and mitigation, customer service, marketing and advertising, customization of content, analytics, security, or hosting RedTube or supporting RedTube’s functionality. These service providers may have access to personal information needed to perform their functions but are not permitted to process such information for any other purposes. Where required under applicable laws, we entered into data processing agreements with such service providers to ensure that personal information is only processed securely within our instructions.
- Legal successors: We may disclose all the categories of personal information we process to a buyer or other successor in the event of a merger, acquisition or sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding.
- To comply with the law or protect our rights or the rights of third parties: We access, preserve and share all of the categories of personal information with regulators, law enforcement or others where we reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, (d) protect against harm to the rights, property or safety of our company, our users, our employees, or others; or (e) to maintain and protect the security and integrity of RedTube or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.
For more information on recipients of personal information, please see the section “Contact Information” below on how to contact us.
7. Cookies and Automatic Data Collection Technologies
As you navigate through and interact with RedTube, we use automatic data collection technologies to collect website activity data. The technologies we use for this automatic data collection may include cookies, which are small text files that are stored in your web browser or downloaded to your device when you visit a website.
We currently use the following types of cookies, which are set by RedTube’s domains, or by other domains we own or control:
- Strictly necessary cookies: These are cookies that are required for the operation of RedTube. These include, for example, cookies that enable a user to log in to RedTube and to check if a user is allowed access to a particular service or content.
- Functionality cookies: These cookies help us to personalize and enhance your online experience on RedTube. This type of cookies allows us to recognize you when you return to RedTube and to remember, for example, your choice of language.
- Analytics cookies: These cookies allow us to recognize and count the number of users and to see how users use and explore RedTube. These cookies help us to improve RedTube, for example by ensuring that all users can find what they are looking for easily. Additionally, we are using third party session recording technologies that helps us better understand our users’ experience, however, the recording data is pseudonymized.
- Targeting and Advertising cookies: These cookies record visits of a user on RedTube, the pages a user visits and the links a user follows to enable us to make RedTube more relevant to the user’s interests and to help us serve ads that might be of interest to the user. Targeting and advertising cookies are only used for Unregistered Users and Registered Users.
Analytics, Functionality and Advertising/Targeting cookies can be switched off at any time by accessing the ‘Manage cookies’ option that is located at the footer of RedTube. However, if you decline to accept these cookies, some functionality on RedTube may be disabled and can interrupt your access to certain parts of RedTube. Cookies can be either session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires, or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple years.
Do Not Track: Our systems do not recognize browser “Do Not Track” signals.
Use of Google Analytics. We use Google as a service provider to collect and analyze information about how users use RedTube, including by collecting website activity data through first-party cookies set by our domains, and third-party cookies set by Google. Because we activated IP anonymization for Google Analytics, Google will anonymize the last octet of a particular IP address and will not store your full IP address. Google will use the information only to provide Google Analytics services to us and will not use this information for other purposes. In addition, RedTube uses Google Signals, which are also services provided by Google that help us to run remarketing campaigns, collect more accurate data, and understand in a better way how users engage with RedTube on different devices (cross-device activity). Google Signals apply to Google users who accept personalized advertising on their Google accounts. The information collected by Google Analytics may be transmitted to and stored by Google on servers in the United States pursuant to standard contractual clauses approved by the EU and the adequacy decision of the EU Commission C (2023) 4745 confirming an adequate level of data protection in the US under the EU-US Data Privacy Framework and applicable national extensions (for example the UK Extension to the EU-US Data Privacy Framework). You can learn more on how Google uses data here, and you can opt-out of Google Analytics by visiting the Google Analytics opt-out page or by accepting only necessary cookies.
8. Third-party Use of Cookies and Other Tracking Technologies
Some content or applications, including advertisements, on RedTube are provided or served by third parties. These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about you when you click to view, access, or use any of the third-party feature on RedTube or directed to such third-party website. Unless expressly stated otherwise, RedTube does not provide any personal information to these third parties, however, when you click on a third-party internet-based advertising, they may collect information, including your IP address, advertisements you click, time zone setting and location, and information about your browser, operating system, and devices you use to access RedTube to provide targeted content.
You can set your browser to refuse all third-party cookies, or to alert you when cookies are being sent.
9. Your Choices About How We Process and Disclose Your Personal Information
We strive to provide you with choices regarding the personal information you provide to us.
- You can choose not to provide us with certain personal information, but that may result in you being unable to use certain features of RedTube because such information may be required for you to register as a member; participate in a contest, promotion, survey, or sweepstakes; ask a question; or initiate other transactions on RedTube.
- The Cookie Banner can be utilized to customize your cookie preferences. The Cookie Banner will record when you have consented to our cookies. For logged in users, we will ask for consent once a year or when we have major changes to our cookies, to ensure you stay up to date with changes to our cookies and privacy policies. For non-logged in users, your Cookie Banner selection will be kept only for the specific session. The Cookie Banner specifically controls the Functionality, Analytics, and Advertising cookies set by using RedTube. Strictly necessary cookies cannot be disabled, nor can the tool be used to block cookies on third party websites linked from RedTube.
- You can access the Cookie Banner anytime by clicking on the ‘Manage cookies’ option that is located at the footer of RedTube.
- You can opt out of receiving marketing emails from us using the opt-out link provided in our emails or by changing your preferences in your account settings. You may use your account settings to delete your user contributions and audio/video information.
- You may also delete and deactivate your account with us at any time unless required not to do so by law or by a court order. If you do so, your profile will no longer be accessible by you. If you later choose to have an account with us, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved.
- Where we provide you personalised services, we may analyse the information you supply, as well as your activity on RedTube, so that we can offer a more relevant, tailored service. For instance, we could use your favourites list to provide you personalised content recommendations or ads. If you don’t want to receive these services, you can switch off the recommended videos icon on the “recommended” page.
10. California Rights and Choices
As of January 1, 2020, the California Consumer Privacy Act of 2018 (“CCPA”) provides California residents (“Consumer(s)”) certain rights with respect to their personal information, as this term is defined under the CCPA. In addition to the rights that we state under this Privacy Notice, and subject to the exceptions found under the CCPA, Consumers have the right to:
- Opt-out of the sale of their personal information, should we sell their personal information;
- Be informed of certain information concerning our collection and use of their personal information;
- Request that we delete certain personal information we collected from them;
- Appoint an agent to exercise their rights provided for by the CCPA, provided that a duly executed notarized power of attorney is presented and provided that the agent has information deemed sufficient to allow us to verify the identity of the Consumer in question and to locate his/her information in our systems;
- Not be subjected to discrimination for the exercise of these rights. We will not deny California residents the use of our service, neither will we provide a different level or quality or services for exercising any of their CCPA rights, unless as permitted under the CCPA.
RedTube does not sell, nor has it sold in the past twelve (12) months personal information to third parties for monetary or other valuable consideration. We may however disclose certain personal information with third parties, service providers and entities within our corporate group to enable them to perform certain services on our behalf and namely to make RedTube work properly, as described in the section above titled “Disclosure of Your Personal Information”.
Regardless, we respect the California residents’ right to exclude personal information from such sharing arrangements and to thereby opt-out of any future sale of their personal information. If the CCPA is applicable to you and you would like to exercise your rights, please use the buttons at the bottom of this page or email us at support@redtube.com with the email subject line “CCPA Request.”
In either case you will need to provide the following information to verify your identity and enable us to locate your information in our systems: your username and email address that you used to create an account with us, as well as any other information which we may reasonably request for us to verify your identity. We may require you verify that you have access to your account and/or email account that you used to register with us.
You can designate an agent to make a request by executing a notarized power of attorney to have that person act on your behalf and providing that person with the information listed above that allows us to verify your identity and locate your information. Alternatively, you will need to directly confirm your identity with us using the methods described above, sign an authorization for the agent to act on your behalf and provide us with confirmation that you have done so.
11. Resident’s Rights – Jurisdictions in the United States, Where Applicable
We do not sell, trade, or exchange the Registered Users’ personal information with anyone for money.
12. Biometric Information
We employ third-party service providers to verify your identity, age and the authenticity of the identification documents you provide using facial recognition technology. Facial recognition technology creates a mathematical representation of your facial features from the live scan of your face, your selfie, and the government-issued ID you submit or previously submitted to us. Information derived from this mathematical representation, which may be considered biometric information under the laws of certain states and countries, is shared by our service providers with us as further described below.
Your biometric information will be processed to:
- verify you are a real, live person and to prevent the use of methods which would allow a user to identify as someone else;
- to match your selfie with your government-issued ID you submit or previously submitted to us to make sure that nobody is impersonating you;
- to help confirm your age; and
- we will store your biometric information according to the section “Retention of Personal Information” below.
Please note that this section entitled “Biometric Information” applies to relevant users who wish to upload content onto RedTube but does not apply to identifiers processed by our third-party age verification service providers solely for the purpose of granting you access to RedTube.
13. Notice to Law Enforcement
The following information serves as a guideline for law enforcement officials seeking disclosure of records. You may serve us a valid court order, subpoena, search warrant or equivalent legal or official administrative document by respecting the following conditions:
- The document(s) is uploaded, and all required fields have been filed out adequately on our platform for Legal Service Process located at: https://legalservice.aylo.com/legal/datarequest;
- The document(s) you are serving is correctly issued to Aylo Freesites Ltd by a valid Court of Law or equivalent legal or administrative authority to us;
- The document(s) is also sent by mail at the following address: 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540.
We reserve the right to refuse online service through RedTube, namely in cases where the above requirements are not met and require formal legal service at the above address. In such an event, you will be notified. We may raise or waive any legal objection or right available, in our sole discretion.
14. Transfers of Your Personal Information to Other Countries
Where the laws of your country allow you to do so, by using RedTube you consent to the transfer of information that we process about you, including personal information, to other countries in which we, members of our corporate group (including affiliates and related entities) or our service providers are located. When we transfer personal information to countries outside of the EEA or other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with the applicable laws. Where available, we rely on decisions of the European Commission, known as “adequacy decisions”, recognizing that certain countries offer a level of protection of personal data that is essentially equivalent to the EEA. In other situations, we rely on standard contractual clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK, where appropriate) or on derogations provided for under the applicable law to transfer information to a third country.
For more information or to obtain a copy of our standard contractual clauses, please see the section “Contact Information” below on how to contact us.
15. Retention of Personal Information
We will only retain your personal information for as long as your account is active, or for as long as necessary to fulfil the purposes we processed it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider several factors, including what personal data we are processing, the risk of harm from any unauthorised disclosure, why we are processing your personal data and whether we can achieve this outcome by another means without having to process it.
Where we no longer need to process your personal information for the purposes set out in this Privacy Notice, we will delete your personal information from our systems.
For more information on data retention periods, please contact us by using the information in the section “Contact Information” below.
Where permissible, we will also delete your personal information upon your request as explained in the section “Your Rights Related to Your Personal Information”.
16. Third-Party Links and Sites
If you click on a link to a third-party website, you will be taken to websites we do not control. This Privacy Notice does not apply to the privacy practices of these websites. Read the Privacy Notice of other websites carefully. We are not responsible for these third-party practices.
17. Changes to Our Privacy Notice
We may modify or revise our Privacy Notice from time to time. If we change anything in our Privacy Notice, the date of change will be reflected in the “last modified date”. We may attempt to notify you of any material changes as required by law. Please also periodically review the most up-to-date version of our Privacy Notice, which will be posted at this location, so you are aware of any changes.
18. Contact Information
If you have any questions about this Privacy Notice or our information-handling practices, please contact us at support@redtube.com.
You may also contact us at 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662 320, Fax: +357 22343 282.
Our Data Protection Officer can be contacted at the following email address: dpo@redtube.com.
19. Your Rights Related to Your Personal Information
Subject to local law and applicable legal requirements and exemptions, you have certain rights regarding your personal data:
- Right of access: you have the right to receive information on the personal data we hold about you and how such personal data is used, as well as a copy of your personal data;
- Right to rectification: you have the right to rectify inaccurate personal data concerning you;
- Right to be forgotten: you have the right to delete/erase your personal data;
- Right to data portability: you have the right to receive the personal data provided by you in a structured, commonly used and machine-readable format and to transmit this personal data to another data controller;
- Right to object: you have the right to object to the use of your personal data where such use is based on our legitimate interests or on public interests;
- Right to restriction of processing: you have the right in some cases, to restrict our use of your personal data.
- Right to file a complaint: If you are located in the EEA or the UK, you also have a right to lodge a complaint with your local data protection authority.
If we ask for your consent to process your personal data, you have the right to withdraw your consent at any time. Note that, in that case, you may no longer able to use several functionalities of RedTube or access RedTube in some cases.
You can exercise your Rights of Access or Deletion of your data by following the dedicated links in the section “Manage My Data” below. If you need assistance regarding the exercise of your rights, you can also send an e-mail at support@redtube.com to help you with the process. Please note that we have one month to respond to your request.
Prior to processing an access or deletion request, we will need to verify your identity and ensure your right to access or delete the information. This is an appropriate and reasonable security measure to ensure that personal data is not disclosed to any person who has no right to receive it or deleted in an unauthorized way.
Please note that unless you have created an account with us, we may not have sufficient information to identify you and therefore may not be able to respond to your request. Additionally, in some cases to adequately verify your identity or your authorization to make the request, we may require you to provide additional information.
Note that some requests to delete certain personal information will require the deletion of your user account as the provision of user accounts are inextricably linked to the processing of certain personal information (e.g., your e-mail address). If you delete your account, your personal data and all account related information including, but not limited to, user profile data, sharing data and any data or content specifically associated with your account will no longer be accessible by you. If, after deleting your account, you wish to have an account with us in the future, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved
20. Manage My Data
Registered Users may request a copy of their personal data or request the deletion of their personal data via the links below. Please note that the below website is governed by the present Privacy Notice.
Note: AdBlocker add-ons interfere with the Manage My Data system. Please disable them.