Privacy Policy

In this Privacy Policy, we explain how we handle your Personal Identifiable Information (“PII”) when you contact us or use one of our services. In particular, we will tell you:

• Why we may process your PII
• For what purpose we process your PII
• Whether you are required to provide us with certain information
• How long we will store your PII
• Whether there are other recipients of your PII
• Whether we intend to transfer your PII to another country
• Whether we use automated decision-making or profiling

In principle, we will only use your PII in accordance with the applicable data protection laws, in particular the New York Privacy Act (“NYPA”), the EU`s General Data Protection Regulation (“GDPR”), and only as described in this Privacy Policy.

Contact details of the data controller

Unless otherwise stated, BFree Wireless, Inc. of

45 Rockefeller Plz., 20th Fl. New York, USA

(hereinafter “BFree TV”, “we”, “us” or “our”) is the data controller for all processing of PII on the Bfree TV website at www.bfreetv.com and our iOS and Android mobile application.

What data protection rights do I have?

Below we inform you about the rights to which you as a Data Subject may be entitled to.

The GDPR grants Passport holders of the European Union the following rights:

• Right of access
• Right to rectification
• Right to restriction of processing
• Right to erasure
• Right to information
• Right to data portability
• Right to object
• Right of withdrawal
• Right to complain to a supervisory authority

The NYPA grants New York residents the following rights:

• Right to Notice
• Right to Opt-In Consent
• Right to Access, Correct Data
• Right to Delete

The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal PII about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it.

We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your PII.

To assert these rights, please contact us at any time using the details provided.

Furthermore, you can revoke consent, in principle with effect for the future. You may also withdraw your consent and request us to stop using and/or disclosing your PII for any or all of the purposes by submitting your request to us in writing. Should you withdraw your consent to the collection, use or disclosure of your PII, it may impact our ability to proceed with your transactions, agreements, or interactions with us. Prior to you exercising your choice to withdraw your consent, we will inform you of the consequences of the withdrawal of your consent. Please note that your withdrawal of consent will not prevent us from exercising our legal rights (including any remedies) or undertaking any steps as we may be entitled to at law.

How do we obtain PII? 

For the most part, we process PII that has been provided to us directly by you. This can happen for various reasons: 

• You have submitted an inquiry to us, 
• You have submitted a request for information to us, 
• You have subscribed to our service, 
• and of course, data that is automatically collected.

Contacting us

If you contact us, we process the following data from you for the purpose of processing and handling your enquiry: Name, contact details -if provided by you- and your message. The legal basis of the data processing is our obligation to fulfill the contract and/or to fulfill our pre-contractual obligations and/or our legitimate interest in processing your enquiry.

Data management 

For optimal customer support, we use first name, last name, and e-mail address if provided, and the data related to your contract with us. Your data will be stored on our website and or our customer relationship management system ("CRM system"). This data processing is based on our legitimate interest in providing our service.

 

Registration

You can register and log in to BFree TV. Here, too, we store data in order to create an account for you: E-mail address, chosen password. We store this data as long as you are registered with us. If you delete your account, we will delete your data unless there is a legal retention period on our part. In this case, we must store your data for longer.

 

Alternatively, you are able to sign up using the convenience login and sign up from Facebook, Google and Apple. For Facebook and Google log in and sign up, you will be asked to provide your basic information (i.e., name, email address, and display picture) linked to your Google account. If granted, username and password will be auto generated to fill in the rest of required user data. For Apple log in and sign up, you will be asked to provide your name and either their real or an obfuscated email address generated by Apple’s email relay service, according to their Apple ID. When registering via connect functions, you agree to the respective terms and conditions of Facebook, Google or Apple and also consent to certain data from your respective profile being transferred to us.

 

Using BFree TV

When users provide and upload content, their IP addresses are stored for 7 days on the basis of our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author. 

 

Within BFree TV you may be able to display certain profile information, share certain details, engage with others, exchange knowledge and insights, post, upload and view relevant content. Content and data are publicly viewable. You have choices about the information on your comment. You don’t have to provide additional information on your comment; however, information helps you to get more from our Services. It’s your choice whether to include sensitive information in your comment and to make that sensitive information public. Please do not post or add PII to your profile that you would not want to be available. The legal basis for the storage is our legitimate interest.

 

Some of the PII you provide may be considered “special” or “sensitive”. This includes PII concerning for example your health, racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this data, you consent to our processing of that data. 

 

Where any PII relates to a third party, you represent and warrant that the PII is up-to-date, complete, and accurate and that you have obtained the third party’s prior consent for our collection, use and disclosure of their PII for the Purposes. You agree that you shall promptly provide us with written evidence of such consent upon demand by us. 

 

You may withdraw your consent and request us to stop using and/or disclosing your PII for any or all of the Purposes by submitting your request to us.

 

Payment Details

The provision of bank details is subject to our payment processor. We do not collect or store payment information or bank details ourselves but receive payment confirmation statements. The legal basis for the data processing is the fulfillment of our contractual obligations and the fulfilment of our legal obligations.

 

Service Notifications

By using our services, you are giving your consent to receiving notifications and messages per email. Those typically include general, profile and content information in relation to your use of BFree TV. Our system notifications are designed to enhance your experience. You can of course opt out from receiving notifications by following the unsubscribe instructions at the bottom of every notification e-mail sent by us. The legal bases are to provide you with our services and your consent as well as our legitimate interest.

 

Log files

In principle, you can use our website for purely informational purposes without disclosing your identity. However, our website collects a series of general data and information with each visit and this data is temporarily stored in log file. A log file is created in the course of an automatic protocol of the processing computer system. The following can be recorded: host name of the accessing end device, IP address, Date and time of the server request, Time sone difference to Greenwich Mean Time (GMT). 

 

The temporary processing of the IP address by the system is necessary to technically enable delivery of the website to your computer. Processing your IP address for the duration of the session is necessary for this. The legal basis for this processing is our legitimate interest.

 

Use of cookies

We use so-called cookies on our web site. Cookies are small text files that are stored on your respective device (PC, smartphone, tablet, etc.) and saved by your browser. For further information please refer to our Cookie Policy. The legal basis for the use of cookies is your consent as well as our legitimate interest.

 

Use of our App

The App can be downloaded from the "Google Playstore" and the "Apple App Store". Downloading the App may require prior registration with the respective App Store and/or installation of the respective App Store software.

 

1. i) Installation of the App via the Google Playstore.

You may use the Google service "Google Play" of Google LLC, to install the App. As far as we are aware, Google collects and processes the following data: License verification, network access, network connection, WLAN connections and location information.

 

It cannot be ruled out that Google also transfers the information to a server in a third country. We have no influence on which PII Google processes during your registration and the provision of downloads in the respective app store and app store software. Google as the operator of the Google Play Store is solely responsible for this. 

 

1. ii) App installation via the Apple App Store.

You may use the Apple app service "App Store", a service of Apple Inc, to install the App. As far as we are aware, Apple collects and processes the following data: Device identifiers, IP addresses and location information.

 

It cannot be excluded that Apple also transmits the information to a server in a third country. We have no influence on which PII Apple processes during your registration and the provision of downloads in the respective App Store and the App Store Software. In this respect, Apple is solely responsible as the operator of the Apple App Store. 

 

iii) General app accesses

As with every server request, information such as IP address, user agent, etc. is transmitted and stored anonymously for 30 days in the server log. The provision of PII is not required by law or contract, nor is it necessary for the conclusion of a contract. You are also not obliged to provide the PII. However, failure to provide the data could result in you not being able to use our App or not being able to use it to its full extent. 

 

1. iv) Network access data

The provision of network access data is necessary if you wish to make full use of our App. However, failure to provide this data could result in you not being able to use our App or not being able to use it to its full extent. Your data will be treated confidentially by us and deleted if you revoke the rights of use, or they are no longer required for the provision of services and there is no legal obligation to retain them.

 

1. v) Push messages

When you use the app, you will receive so-called push messages from us using the Google Firebase Tool, even if you are not currently using the app. These are messages that we send you as part of the performance of the contract. You can adjust or stop receiving push messages at any time via the device settings of your device.

 

1. vi) Device information

Google and Apple may collect information from and about the device(s) you use to access our App, including hardware and software information such as IP address, device ID and type, device-specific and App settings and properties, App crashes, advertising IDs, information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope and compass. 

 

vii) Authorizations and access

We may request access or permission from your mobile device for certain features (internet, Camera, Microphone, GPS, your Geo-Location and push notifications). The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can change your permissions at any time via the settings menu of your device.

viii) Uninstall

You can stop the collection of data by the App by uninstalling it using the standard uninstall procedure for your device. 

 

Advertising

BFree TV is build using the Freemium Model. As such, BFree TV uses third-party advertising networks service to display ads. In order to provide personalized advertisements to our users, those advertising networks use device information that include personal and non-personal information, such as advertising (or ad) identifiers, IP address regarding the delivery of advertisements and your interaction with them and/or other tracking technologies to enable and optimize this advertising procedure.

 

Ad identifiers are non-permanent device identifiers such as Google’s or Apple`s advertising ID. Advertisers and third parties also may collect information about your activity on BFree TV, on devices associated with you, and on third-party sites and applications using tracking technologies. Tracking data collected by these advertisers and third parties is used to decide which ads you see both on BFree TV and on third-party sites and applications. You can opt out on the Digital Advertising Alliance (DAA) if you wish not to receive targeted advertising. In addition, you may also choose to control targeted advertising you receive within applications by using the settings and controls on your devices.

 

Is there an obligation for me to provide data? 

Within the scope of our business relationship, you are only required to provide PII that is necessary for the establishment, implementation, and termination of a business relationship or that we are legally obliged to collect. Without this data, we will usually have to refuse to conclude the contract or will no longer be able to perform an existing contract and may have to terminate it.

 

Data Security

Our data processing is subject to the principle that we only process the PII that is necessary for the sensible and economic use of our offer. In doing so, we take great care to ensure that your privacy and the confidentiality of all PII are always guaranteed.

 

All transmitted data is protected by TLS encryption. Transport Layer Security (TLS) is a protocol used to ensure secure data transmission on the Internet. The public-private key procedure is used here. This means that data encrypted with a publicly accessible key can only be decrypted again with a separate private key.

 

We stand for high security when shopping online. BFree TV uses technical and organizational security measures (TOMs) throughout the company to protect the data we manage from you against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons. For example, we regularly train all employees on current IT security topics.

 

Passing on of data

Your PII will only be passed on to third parties,

• if you have given your express consent to this;
• if the disclosure is necessary for the fulfillment of contractual obligations;
• if we are legally obligated to disclose the data;
• if the disclosure of the data is in the public interest;
• if the disclosure of the data is necessary for the protection of our legitimate interests or the legitimate interests of a third party unless your interests in the protection of your data override these interests.

 

Duration of storage of PII

Your data will be stored by us for as long as it is needed for the respective purposes underlying the processing. Beyond that, we only store data insofar as we are legally obligated to do so, e.g., due to statutory retention obligations.

 

Integration of third-party services and content

Within BFree TV, we use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services (hereinafter uniformly referred to as "content"). This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to you. The IP address is therefore necessary for the display of this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. 

 

Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our website, as well as being linked to such information from other sources.

 

The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any:

 

• Analytics and Tracking: Google Analytics by Google LLC 
• Fonts: Google Font API by Google LLC
• Web Hosting Provider: GoDaddy

 

Marketing

Insofar as you have also given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

 

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

 

Direct Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out. 

 

Automated Decision Making

Automated decision making within the meaning of the NYPA and GDPR is not used at BFree TV.

 

Do Not Sell

We do not sell PII to third parties.

 

Social Media

We are present on social media on the basis of our legitimate interest. If you contact us via those social media platforms, you should note that the chat history can neither be deleted by us nor by you. And that, in accordance with the NYPA and the GDPR, the relevant social media platforms, we are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. A Joint Controller Agreement itself is very legalistic and lengthy, but in a nutshell, it clarifies how the jointly responsible parties will fulfill the obligations arising from data protection laws that are applicable to them. The legal basis for the use of the relevant social media platform is our legitimate interest, your consent or, in the case of a (pre) contractual relationship with us, the initiation of a contractual service.

 

Updating your information

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so in your account or contact us. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

 

Exercising your rights

If you wish to access your PII or exercise any of the rights listed above, you should apply in writing, providing evidence of your identity. Any communication from us in relation to your rights as detailed above will be provided free of charge. However, in case of requests that are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or refuse to act on the request.

 

Incorporating the data deletion request details into the existing privacy policy draft, the following section could be added under the heading "Exercising your rights," specifically after the paragraph discussing the existing rights under the GDPR and NYPA:

 

**How to Submit a Data Deletion Request**

 

As part of our commitment to your privacy and in compliance with applicable data protection laws, including the NYPA and GDPR, BFree TV offers you the right to request the deletion of your Personal Identifiable Information (PII) from our records.

 

If you decide that you no longer wish for us to hold or process your PII, you may submit a data deletion request. To do so, please follow these steps:

1. Navigate to our Contact Us page: https://bfreetv.com/contact-us.

 

1. Provide us with your full name and the email address associated with your BFree TV account to help us identify your records accurately.

 

1. Clearly state your desire to have your PII deleted from our systems. You may specify if you want us to remove all or only certain aspects of your data.

 

1. If you wish, you may explain the reason for your request, though you are not obliged to do so.

 

Upon receiving your written request, we will take steps to verify your identity to prevent unauthorized access to your information. This might include asking you to provide additional details or documentation as proof of identity.

 

After confirming your identity, we will process your request and delete your PII from our systems, unless we are required to retain certain information by law or for legitimate business purposes. We will inform you about any data that we cannot delete and the reasons for retaining such information.

 

We will strive to complete the deletion process promptly and will notify you once it has been completed. Our goal is to ensure your right to privacy is respected and to provide a transparent and straightforward process for managing your data.

 

Please be aware that the deletion of your PII may affect the availability of certain services we offer. If crucial information for service provision is removed, it may result in the termination of your account or inability to access specific features of BFree TV.

 

If you experience any difficulties or have questions regarding the data deletion process, do not hesitate to reach out to us via the contact details provided below.

 

**Contact Details for Data Protection Inquiries and Requests:**

BFree Wireless, Inc.

45 Rockefeller Plaza, 20th Floor New York, New York 10111, USA

Contact Us: https;//bfreetv.com/contact-us

Insofar as you have given us consent to process PII for specific purposes, the lawfulness of this processing is given on the basis of your consent. Consent given can be revoked at any time.

 

Validity and questions

This privacy and cookie policy is valid as of Thursday, February 8, 2024. It is the current and valid version of our privacy policy. However, we point out that from time to time due to actual or legal changes a revision to this privacy and cookie policy may be necessary. 

If you have any data protection questions, please feel free to contact us.