This document covers the principles of protection of Users' personal data when using:

1. the Website: www.streamsage.io

2. the Stream Sage Platform

Protecting your personal information is important to us and we are committed to ensuring that you are safe when using our Services.

Please familiarize yourself with this document (hereinafter referred to as "Privacy Policy") which is intended to explain how we handle your personal information when using our Services. You are subject to this Privacy Policy whenever you use our Services.

This Privacy Policy is effective as of 5 July 2022 and outlines, among other things: how to contact Stream Sage Inc. with the registered office in Dover - 8 The Green, Ste R, Dover, DE 19901 (hereinafter referred to as "Stream Sage"), how Stream Sage collects, stores and processes personal data, the sources of collection of personal data, the scope and purpose of processing personal data, the length of time personal data is processed and an individual's rights regarding their personal data.

EU data protection representative

Stream Sage, in performance of its obligation under Article 27 of the GDPR, has appointed as its data protection representative in the EU its subsidiary StreamAI spółka z ograniczoną odpowiedzialnością with its registered seat at ul. Zygmunta Starego 22/42, 44-100 Gliwice, entered into the Register of Entrepreneurs by the District Court in Gliwice, Xth Commercial Division of the National Court Register under KRS no.: 0000831023, NIP: 6312690302, REGON: 38564825700000, share capital: PLN 5,000 (five thousand 00/00). Users can contact both Stream Sage and its subsidiary StreamAI with regard to data protection issues.

Glossary

The following phrases should be understood as:

Platform - an IT solution by means of which Vendors can increase sales on their online stores through its integration with their online store and through broadcasting audio-visual materials in real time (i.e. streaming). The said streams can in turn be viewed by Viewers, who can also purchase the goods and services advertised in the streams directly from the Vendors’ websites. The Platform is available at console.streamsage.io.

Contact Form - an interactive form placed on the Website, used to contact Stream Sage in order to obtain detailed information regarding the Services provided by Stream Sage or terms of cooperation, as well as to report technical problems on the Website, through which the User provides an e-mail address.

Vendor - a natural person, legal entity or organizational unit without legal personality which uses the Platform in its free or paid version to broadcast streams or make integrations of the Platform with its website.

Processing - any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction

Newsletter - shall mean an information bulletin concerning the Services provided by Stream Sage, which the User has agreed to subscribe to by providing his/her email address in the "Newsletter" box on the Website.

Stream Sage - shall mean Stream Sage Inc. with its registered office in Dover - 8 The Green, Ste R, Dover, DE 19901.

Site or Website – the website available at www.streamsage.io.

Services – shall mean the services provided by Stream Sage, namely access to: 

• the Website,

• the Platform.

Viewer - a person viewing a stream broadcasted by a Vendor via the Platform.

User – the Vendor, the Viewer, or any third party visiting the Website.

§ 1

Introductory provisions

1. The Services are rendered by Stream Sage.
   
   

2. The Services may include external links (hyperlinks) to third-party websites, plug-ins or applications. Clicking on these links or granting permission to connect will transfer the User's data (IP address and browser ID) to the controller of the website in question, who in turn becomes the co-controller of the User's personal data in this regard (in accordance with the CJEU's judgment in case C-40/17). External links may, in particular, lead to the websites of Vendors or services from which audiovisual materials contained in streams broadcasted via the Platform are downloaded, such as:

   • Facebook,

   • Youtube,

   • Vimeo.
     
     

3. Stream Sage does not have any control over third-party sites and web services, and is not responsible for them. When leaving the Platform to a third-party website the collection, use, and disclosure of personal information will be governed by the privacy policy of the relevant third party. We recommend that our Users review the privacy policies and practices of each third party website and online service they visit.
   
   

4. By accepting this Privacy Policy, you are indicating that you have read and agree to be bound by its terms and conditions.

§ 2

Personal data

1. Personal data is information about an identified or identifiable natural person. Data anonymized in such a way that the data subjects cannot be identified at all or can no longer be identified are not personal data.
   
   

2. Personal data is processed by Stream Sage lawfully and with due regard to the principles of fairness, transparency and adequacy.
   
   

3. No personal data is collected or processed through the Services for the purpose of transferring or selling it to third parties for marketing purposes. Stream Sage also does not distribute marketing messages on behalf of third parties.
   
   

4. We may collect, process, store and transfer different types of data, which we have grouped as follows:
   
   Identity Data, which includes personal information such as your name, username or similar identifier.
   
   Contact Data, which includes personal information such as business name, address, billing address, email address, phone number.
   
   Transaction Data, including financial data such as completed transactions and payments made.
   
   Technical Data, including technical data such as IP address, login data, browser type and version, time zone and location settings, plug-in types and versions, operating system and other technologies used by Users on the devices through which they access the Services.
   
   Behavior Data, statistical and analytical information about how Users use the Services.
   
   Marketing and Communications Data, which includes Users' preferences for receiving commercial information and communications from Stream Sage.
   
   

5. Providing personal data is voluntary, however, if you do not provide us with personal data it may not be possible for Stream Sage to provide Services.
   
   

6. One of the ways we process Personal Data may be by profiling. We may use Identity, Contact, Technical, and Behavioral Data to create a profile of the preferences of Users of our Services. In particular, profiling helps us to respond appropriately to irregularities and technical errors.

§ 3

Data processed by the Website

1. The controller of the data processed through the Website is Stream Sage.
   
   

2. The Website is not directed to individuals under the age of 13 and we do not knowingly collect personal information from such individuals through the Website.
   
   

3. The Website uses "Cookies". When a User accesses the Website, a cookie banner appears informing that the Website uses cookies. The banner is visible to the User until he accepts one of the options of using cookies by the Website.
   
   

4. More detailed information on our use of Cookies, indicating what Cookies are and how they are used by the Website is available when the User clicks the box with the inscription: "Cookie Policy" appearing on the banner and in the "Cookie Policy" tab located on the Website.
   
   

5. If the User submits personal data via the Website, it will be used in accordance with the purpose of the submission. The following is a listing of the purposes/activities of the processing of personal data by category of such data, attributed to the legal basis for the processing of personal data.
   
   

   1. Requesting beta access to the Platform:

      • Type of personal data:

        • Identity Data

        • Contact Data
          
          

      • Basis for processing:
        Conclusion and performance of the agreement
        
        

   2. Newsletter subscription:

      • Type of personal data:

        • Identity Data

        • Contact Data
          
          

      • Basis for processing:

        • Conclusion and performance of a contract

        • Consent to the sending of marketing information by electronic means and consent to direct marketing performed by means of telecommunication equipment
          
          

   3. Notification of changes to regulations and policies:

      • Type of personal data:

        • Identity Data

        • Contact Data
          
          

      • Basis for processing:

        • Performance of contract 

        • Legal obligation
          
          

   4. Managing and ensuring the security of Stream Sage and the Website (system diagnostics and maintenance, data analysis, testing, server management and hosting):

      • Type of personal data:

        • Identity Data

        • Contact Data

        • Technical Data
          
          

      • Basis for processing:

        • Legitimate interest of the controller (ensuring network security, preventing fraud)

        • Legal obligation
          
          

   5. Ensuring appropriate content of the Website and advertisements, as well as analyzing the effectiveness of advertising campaigns conducted:

      • Type of personal data:

        • Behavioral Data 

        • Marketing and Communications Data 

        • Technical Data
          
          

      • Basis for processing:

        • Consent by accepting the Website's use of cookies
          
          

   6. Answering inquiries regarding details of our Services or technical issues on the Website, responding to complaints

      • Type of personal data:

        • Identity Data

        • Contact Data
          
          

      • Basis for processing:

        • Taking action before concluding a contract

        • Performance of a contract

        • Protection against claims

          
          

   7. Transferring data to other entities (that operate websites, plugins or applications to which external links are provided on our Website):

      • Type of personal data:

        • Technical Data
          
          

      • Basis for processing:

        • Consent by accepting the Website's use of cookie

§ 4

Vendors’ data processed by the Platform

1. The controller of Vendors’ data processed through the Platform is Stream Sage.
   
   

2. The Platform is not directed to individuals under the age of 13 and we do not knowingly collect personal information from such individuals through the Platform.
   
   

3. In order to properly perform the cooperation between Stream Sage and a Vendor it may become necessary for the Vendor to share limited data of its customers with Stream Sage. In case of such data sharing Stream Sage will be the data processor and the Vendor will be the controller. The data will be processed on the basis of a data processing agreement between Stream Sage and the Vendor, which will be concluded when the Vendor creates an account on the Platform.
   
   

4. The following is a list of the purposes/activities of Vendors’ (and their customers’) personal data processing via the Platform by category of such data, along with the legal grounds for the processing.
   
   

   1. Creating an account on the Platform

      • Type of personal data:

        • Identity Data

        • Contact Data
          
          

      • Basis for processing:

        • Conclusion and performance of the agreement
          
          

      •  Data subjects:

        • Vendor
          
          

   2. Ongoing cooperation with the Vendor

      • Type of personal data:

        • Identity Data

        • Contact Data

        • Transaction Data
          
          

      • Basis for processing:

        • Concluding and performing an agreement

        • Legal obligation
          
          

      •  Data subjects:

        • Vendor

        • Vendor’s clients
          
          

   3. Notification of changes to regulations and policies

      • Type of personal data:

        • Identity Data

        • Contact Data
          
          

      • Basis for processing:

        • Performance of contract

        • Legal obligation
          
          

      •  Data subjects:

        • Vendor
          
          

   4. Managing and ensuring the security of Stream Sage and the Platform (system diagnostics and maintenance, data analysis, testing, server management and hosting)

      • Type of personal data:

        • Identity Data

        • Contact Data

        • Technical Data
          
          

      • Basis for processing:

        • Legitimate interest of the controller (ensuring network security, preventing fraud)

        • Legal obligation
          
          

      •  Data subjects:

        • Vendor
          
          

   5. Answering inquiries regarding details of our Services or technical issues on the Platform, responding to complaints

      • Type of personal data:

        • Identity Data

        • Contact Data
          
          

      • Basis for processing:

        • Performance of a contract

        • Protection against claims
          
          

      •  Data subjects:

        • Vendor

        • Vendor’s clients

§ 5

Viewers’ data processed by the Platform

1. Stream Sage does not process any Viewers’ personal data.
   
   

2. In order to gain access to live audiovisual material, the Viewer, upon entering the relevant link, is requested to set up a username which must be in compliance with the Terms & Conditions for Viewers (ex. the username should not be the Viewer's first or last name).
   
   

3. The Platform is not directed to individuals under the age of 13 and we do not knowingly collect personal data from such individuals through the Platform.
   
   

4. The only data collected from Viewers by Stream Sage is:
   
   

   1. Enable the Viewer to watch a stream and use all features available to Viewers

      • Type of personal data:

        • Technical Data (excluding IP)

        • Behavioral Data
          
          

      • Basis for processing:

        • Concluding and performing a contract
          
          

      •  Data subjects:

        • Viewer
          
          

   2. Managing and ensuring the security of Stream Sage and the Platform (system diagnostics and maintenance, data analysis, testing, server management and hosting)

      • Type of personal data:

        • Technical Data (excluding IP)

        • Behavioral Data
          
          

      • Basis for processing:

        • Legitimate interest of the controller (ensuring network security, preventing fraud)

        • Legal obligation
          
          

      •  Data subjects:

        • Viewer

§ 6

Sharing of personal data and international transfers

1. For the purposes set out in the preceding paragraphs, we may disclose your personal information to external third parties such as our contractors, accounting firms, law firms and, if obliged, to public authorities.
   
   

2. Your personal data may also be transferred to our subsidiary StreamAI Sp. z o.o. with its registered seat at ul. Zygmunta Starego 22/42, 44-100 Gliwice, Poland, entered into the Register of Entrepreneurs by the District Court in Gliwice, Xth Commercial Division of the National Court Register under KRS no.: 0000831023, NIP: 6312690302, REGON: 38564825700000, share capital: PLN 5,000 (five thousand 00/00). This company is responsible for the development of our product and for its proper maintenance and also acts as our EU GDPR representative.
   
   

3. We require all third parties to maintain security measures with respect to your personal data and to process it lawfully. We do not allow our suppliers to use your personal information for their own purposes, and we process it for the purposes and in accordance with our instructions.
   
   

4. Because Stream Sage is a U.S. company, your personal data may be transferred outside the EEA. In such cases, we ensure an adequate level of protection for that data by providing at least one of the following safeguards:
   
   

   • transfer of personal data to countries recognized by the European Commission as providing adequate protection for personal data,

   • applying the data protection clauses adopted by the European Commission which guarantee the same protection as in the European Union.

§ 7

Data security

1. Stream Sage's processing of your personal data is carried out in compliance with all the rules regarding the security of personal data processing, meeting the requirements imposed by law. We have put in place the necessary security measures to protect User data from accidental loss, unauthorized access or use, alteration or disclosure. We restrict access to Users' data to employees, agents, service providers and other third parties to whom such access is necessary for the provision of Services. They will only process Users' personal data in accordance with Stream Sage's instructions and are bound by a duty of confidentiality.
   
   

2. Stream Sage has adopted appropriate procedures to deal with suspected breaches. We will notify Users and the applicable regulatory authority of a breach when we are legally required to do so.

§ 8

Data retention

1. Users' personal data will be stored for no longer than the time necessary to fulfill the purpose for which they were collected (e.g. for the time necessary to perform the contract concluded between Stream Sage and the Vendor), unless a longer time results from the need to fulfill legal, accounting or reporting obligations incumbent on us, or for the time necessary to assert claims under the law.
   
   

2. In certain situations, Users may request deletion of their personal data, in accordance with § 9.
   
   

3. In certain situations, we may anonymize Users' personal data (ensuring that an individual is irreversibly unidentifiable) for research and statistical purposes, in which case we may retain this information indefinitely without further obligation to notify Users.

§ 9

Users' rights related to data protection. Complaint to the supervisory authority.

1. You have the right in certain situations to make a request to Stream Sage to review, correct, amend, restrict, rectify or erase your personal data that Stream Sage administers and the right to object to Stream Sage processing your personal data. To do so, please send an email to: support@streamsage.io.
   

2. Please note that we will not always be able to comply with requests by Users to delete their personal data, namely due to individual legal obligations or the assertion of claims. In such cases, this will be communicated to Users after such a request has been made. Similarly, in the case of personal data of which the Vendor is the controller (i.e. personal data of the Vendor’s clients), the entity suitable to comply with the requests of data subjects is the Vendor. In the event that we receive a request from a data subject to exercise their rights in relation to personal data processed by us on the basis of a data processing agreement, we will notify such data subject of the need to make an appropriate request to the controller.
   
   

3. If you would like more information about any of the individual rights set forth under this paragraph, please contact us.
   
   

4. The User has the right, at any time, to withdraw consent to the processing of personal data for marketing purposes by sending an email to support@streamsage.io or by clicking on the deactivation link sent each time in the Newsletter or other marketing message. Withdrawal of consent does not affect the lawfulness of processing, which was performed on the basis of consent before its withdrawal. This means that the withdrawal of consent applies to future processing, not to past processing that took place in the period between the granting and withdrawal of consent.
   
   

5. You have the right to request that Stream Sage transfers your personal data it controls to another personal data controller, provided that technical and organizational requirements allow the transfer of such personal data.
   
   

6. Stream Sage shall, without undue delay - and in any event within one month of receipt of a request - provide the User who has submitted one of the requests listed in this paragraph with information about the action taken in answer to the request, or about a possible extension of the deadline due to the nature of the request or the large amount of requests, or about the reasons for not taking action, and about the possibility of filing a complaint with a supervisory authority and pursuing legal remedies before a court.
   
   

7. The exercise of the rights set out above is free of charge, however Stream Sage may charge you a reasonable fee where the request(s) made are manifestly unfounded, repetitive, or excessive. In such cases, we may also refuse to comply with the request presented.
   
   

8. In order to comply with particular requests, Stream Sage may require certain information from you in order to verify your identity and ensure the exercise of particular rights. This is a security measure to ensure that personal data is not disclosed to unauthorized persons.
   
   

9. A User whose personal data Stream Sage controls has the right to lodge a complaint with a supervisory authority, in particular in the country:
   
   

   • of their usual residence,

   • of your place of employment,

   • or the place where the alleged violation was committed,

     
     if it believes that the processing of personal data relating to it violates relevant data protection legislation. A complaint may be sent by post to the supervisory authority's physical address or by email to the authority's email address.

   
   

§ 10

Stream Sage's liability and possibility to file notices

1. Stream Sage, acting with due diligence, cares for the correct operation of the Services, but is not responsible for technical limitations in the ability to use the Services resulting from the technical condition of the User's equipment and resulting from failure of data transmission (Internet connection) used by the User.
   
   

2. Stream Sage requests that you report any irregularities related to the operation of the Website of Platform to the following email address: support@streamsage.io

§ 11

Final provisions, changes to Privacy Policy, notification of changes

1. Stream Sage reserves the right to amend this Privacy Policy, which amendment shall be effective upon posting of the new Privacy Policy on our Website.
   
   

2. Any changes to this Policy will be communicated by an appropriate notice appearing on the Website. In the case of significant changes, information on changes to the Privacy Policy may also be sent to the User's e-mail address.
   
   

3. For all matters relating to Stream Sage's processing of your personal information, please feel free to contact us at the email address: support.streamsage.io or at the telephone number indicated on the Site. Alternatively, you can also contact the EU data protection representative indicated above.