Your privacy is critically important to us. At OVERTURE+, we have a few fundamental principles:
- We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
- We store personal information for only as long as we have a reason to keep it.
- We aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.
- We help protect you from overreaching government demands for your personal information.
- We aim for full transparency on how we gather, use, and share your personal information.
Who We Are and What This Policy Covers
- Our websites (including overture.plus, playplay.tv, surfcode.io);
- Other users’ websites that use our Services, while you are logged in to your account with us.
Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.
Information We Collect
We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better.
We collect this information from three sources: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us directly. Here are some examples:
- Basic account information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for a OVERTURE+ account to provide an email address and password, along with a username or name — and that’s it. You may provide us with more information — like your address and other information you want to share — but we don’t require that information to create a OVERTURE+ account.
- Public profile information: If you have an account with us, we collect the information that you provide for your box office page if you are a business or non profit. OVERTURE+ does not create profiles for patrons viewing a show.
- Payment and contact information: If you buy something from us or earn revenue through your site, we’ll collect information to process those payments and contact you. If you buy something from us — a subscription to a OVERTURE+ plan — or if you pay fees to a person or business through their OVERTURE+ site (for example via the Payments feature), you’ll provide additional personal and payment information like your name, credit card information, and contact information. We also keep a record of the purchases you’ve made. If you use our Ecommerce Services
- Content information: You might provide us with information about you in draft and published content (a blog post or comment that includes biographic information about you, or any media or files you upload).
- Credentials: Depending on the Services you use, you may provide us with credentials for your self-hosted website (like SSH, FTP, and SFTP username and password). Content creators users may provide us with these credentials in order to use our one-click restore feature if there is a problem with their site, or to allow us to troubleshoot problems more quickly.
- Communications with us: You may also provide us with information when you respond to surveys, communicate with our Engineers about a support question, post a question in our public forums, or sign up for a newsletter like the one we send through Longreads. When you communicate with us via form, email, phone, OVERTURE+ comment, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).
- Job applicant information: If you apply for a job with us — awesome! You may provide us with information like your name, contact information, resume or CV, and work authorization verification as part of the application process.
Information We Collect Automatically
We also collect some information automatically:
- Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services — for example, when you create or make changes to your website on OVERTURE+.
- Usage information: We collect information about your usage of our Services. For example, we collect information about the actions that site administrators and users perform on a site using our OVERTURE+ — in other words, who did what and when (e.g., [OVERTURE+ username] deleted “[title of post]” at [time/date]). We also collect information about what happens when you use our Services (e.g., page views, support document searches at overture.plus, features enabled for your website) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, get insights on how people use our Services so we can make our Services better, and understand and make predictions about user retention.
- Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps (like when you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.
- Stored information: We do not store information on any devices outside of the browser sandbox.
- Interactions with other users’ sites: We collect some information about your interactions with other users’ sites while you are logged in to your account with us, such as your “Likes” and the fact that you commented on a particular post, so that we can, for example, recommend posts we think may interest you.
Information We Collect from Other Sources
We may also get information about you from other sources. For example, if you create or log in to your OVERTURE+ account through another service (like Google) or if you connect your website or account to a social media service (like Twitter), we’ll receive information from that service (e.g., your username, basic profile information, friends list) via the authorization procedures for that service. As another example, if you use Stripe Payments, we’ll receive information relating to your Stripe account, such as your email address and phone number. The information we receive depends on which services you use or authorize and what options are available.
Third-party services may also give us information, like mailing addresses for individuals who are not yet our users (but we hope will be!). We use this information for marketing purposes like postcards and other mailers advertising our Services.
How and Why We Use Information
Purposes for Using Information
We use information about you for the purposes listed below
- To provide our Services. For example, to set up and maintain your account, host your video content, backup and restore your content, provide customer service, process payments and orders, and verify user information.
- To ensure quality, maintain safety, and improve our Services. For example, by providing automatic upgrades and new versions of our Services. Or, for example, by monitoring and analyzing how users interact with our Services so we can create new features that we think our users will enjoy and that will help them create and manage websites more efficiently or make our Services easier to use.
- To place and manage ads in our advertising program. For example, to place ads on our users’ sites and some of our own sites as part of our advertising program, and understand ad performance.
- To market our Services and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our users (like those who have a particular plan with us or have been users for a certain length of time), advertising our Services, analyzing the results of our marketing campaigns (like how many people purchased a paid plan after receiving a marketing message), and understanding and forecasting user retention.
- To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of OVERTURE+ and others, which may result in us, for example, declining a transaction or terminating Services.
- To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
- To customize the user experience. For example, to personalize your experience by serving you relevant notifications and advertisements for our Services, recommending content through our Reader post suggestions, and providing new essays and stories through Longreads for your reading pleasure.
- To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, or keep you up to date on OVERTURE+; texting you to verify your payment; or calling you to share offers and promotions that we think will be of interest to you. If you don’t want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we’ll still send you important updates relating to your account.)
- To recruit and hire new OVERTURE+ Folks. For example, by evaluating job applicants and communicating with them.
Legal Bases for Collecting and Using Information
A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:
(1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device or charge you for a paid plan; or
(2) The use is necessary for compliance with a legal obligation; or
(3) The use is necessary in order to protect your vital interests or those of another person; or
(4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or
How We Share Information
We share information about you in limited circumstances, and with appropriate safeguards on your privacy. These are spelled out below, as well as in the section called Ads and Analytics Services Provided by Others:
- Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request. For more information on how we respond to requests for information about OVERTURE+ users, please see our Legal Guidelines.
- To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of OVERTURE+, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
- With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties when you authorize us to do so.
- Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services, or share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
- Site owners: If you have a OVERTURE+ account and interact with another site using our Services, your information may be shared with the administrators of the site. For example, if you leave a comment on a site created on OVERTURE+, your IP address and the email address associated with your OVERTURE+ account may be shared with the administrator(s) of the site where you left the comment. Or if you make a payment (like via the Payments feature) to a site, your public display name, user name, and email address may be shared with the administrator(s) of the site.
- Published support requests: If you send us a request for assistance (for example, via a support email or one of our other feedback mechanisms), we reserve the right to publish that request in order to clarify or respond to your request, or to help us support other users. We have a long-standing policy that we do not sell our users’ data. We aren’t a data broker, we don’t sell your personal information to data brokers, and we don’t sell your information to other companies that want to spam you with marketing emails.
- We show ads on some of our users’ sites as well as some of our own, and the revenue they generate lets us offer free access to some of our Services so that money doesn’t become an obstacle to having a voice.
- Under a new California law, the California Consumer Privacy Act (“CCPA”), some personalized advertising you see online and on our services might be considered a “sale” even though we don’t share information that identifies you personally, like your name or email address, as part of our advertising program.
- You have choices about these ads, learn more about them and our ads program.
Information Shared Publicly
Information that you choose to make public is — you guessed it — disclosed publicly.
OVERTURE+ only allows businesses to disclose information about themselves to sell shows publicly on the OVERTURE+ websites. We encourage no personal information to be disclosed while setting up content to sell.
Please keep all of this in mind when deciding what you would like to share publicly.
How Long We Keep Information
We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — and we’re not legally required to keep it.
For example, we keep the web server logs that record information about a visitor to one of OVERTURE+’s websites, like the visitor’s IP address, browser type, and operating system, for approximately 30 days. We retain the logs for this period of time in order to, among other things, analyze traffic to OVERTURE+’s websites and investigate issues if something goes wrong on one of our websites.
As another example, when you delete a post, page, or comment from your OVERTURE+ site, it stays in your Trash folder for thirty days in case you change your mind and would like to restore that content, because starting from scratch is no fun. After the thirty days are up, the deleted content may remain on our backups and caches until purged.
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We monitor our Services for potential vulnerabilities and attacks.
You have several choices available when it comes to information about you:
- Limit the information that you provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services — for example, premium themes that carry an additional charge — may not be accessible.
- Limit access to information on your mobile device: Your mobile device operating system should provide you with the option to discontinue our ability to collect stored information or location information via our mobile apps. If you choose to limit this, you may not be able to use certain features, like geotagging for photographs.
- Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
- Set your browser to reject cookies: At this time, OVERTURE+ does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using OVERTURE+’s websites, with the drawback that certain features of OVERTURE+’s websites may not function properly without the aid of cookies.
- Close your account: While we’d be very sad to see you go, you can close your account if you no longer want to use our Services. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data
European General Data Protection Regulation (GDPR)
If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
- Request access to your personal data;
- Request correction or deletion of your personal data;
- Object to our use and processing of your personal data;
- Request that we limit our use and processing of your personal data; and
- Request portability of your personal data.
You also have the right to make a complaint to a government supervisory authority.
California Consumer Privacy Act (CCPA)
The California Consumer Privacy Act (“CCPA”) requires us to provide California residents with some additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it.
The CCPA also requires us to provide a list of the “categories” of personal information we collect, as that term is defined in the law, so, here it is. In the last 12 months, we collected the following categories of personal information from California residents, depending on the Services used:
- Identifiers (like your name, contact information, and device and online identifiers);
- Commercial information (your billing information and purchase history, for example);
- Characteristics protected by law (for example, you might provide your gender as part of a research survey for us);
- Internet or other electronic network activity information (such as your usage of our Services, like the actions you take as an administrator of a OVERTURE+ site);
- Geolocation data (such as your location based on your IP address);
- Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);
- Professional or employment-related information (for example, your company and team information if you are an OVERTURE+ user, or information you provide in a job application); and
- Inferences we make (such as likelihood of retention or attrition).
You can find more information about what we collect and sources of that information in the Information We Collect section above.
We collect personal information for the business and commercial purposes described in the How and Why We Use Information section. And we share this information with the categories of third parties described in the Sharing Information section.
If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to
- Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific
- pieces of information we collect about you;
- Request deletion of personal information we collect or maintain;
- Opt out of any sale of personal information; and
- Not receive discriminatory treatment for exercising your rights under the CCPA.
The CCPA & Personalized Advertising in Our Ads Program
The personal information we share includes online identifiers; internet or other network or device activity (such as cookie information, other device identifiers, and IP address); and geolocation data (approximate location information from your IP address). These disclosures may be considered a “sale” of information under the CCPA. We do not sell (or share) information through our ads program that identifies you personally, like your name or contact information. We don’t knowingly sell personal information of those under 16. Learn how you can opt out by going to California: Do Not Sell My Personal Information.
Contacting Us About These Rights
- You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to or you’d like to contact us about one of the other rights, scroll down to “How to Reach Us” to, well, find out how to reach us.
- When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.
Controllers and Responsible Companies
OVERTURE+’s Services are worldwide. Different OVERTURE+ companies are the controller (or co-controller) of personal information, which means that they are the company responsible for processing that information, based on the particular service and the location of the individual using our Services.
Depending on the Services you use, more than one company may be the controller of your personal data. Generally, the “controller” is the OVERTURE+ company that entered into the contract with you under the Terms of Service for the product or service you use. In addition, OVERTURE+ Inc., our US-based company, is the controller for some of the processing activities across all of our Services worldwide.
The chart below explains the current controllers for processing your personal information. We use the term “Designated Countries” to refer to Australia, Canada, Japan, Mexico, New Zealand, Russia, and all countries located in the European continent.
If you reside outside of the Designated Countries:
2220 County Road 210 West Suite 108-165 Jacksonville, FL, USA
If you reside in the Designated Countries:
2220 County Road 210 West Suite 108-165 Jacksonville, FL, USA
How to Reach Us
Other Things You Should Know (Keep Reading!)
- In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or
- In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.
Ads and Analytics Services Provided by Others
Third-Party Software and Services
Visitors to Our Users’ Websites
Users control the content posted on their sites, so any disputes regarding content on a user’s site should be made directly to the site owner, through their “contact us” page, at an email address they provide, or by leaving a comment on the site.