Last Revised: December 12, 2019

Interlude US Inc., its subsidiaries and affiliates, d/b/a Eko ("Eko", "Company" "we" or "us") respects the privacy of the users of its websites at https://eko.com/, https://helloEko.com/ and https://company.eko.com/ and its subdomains (the "Site") and of its branded mobile application (the "App"), including viewers of the interactive videos made available by Eko through the Site, App and/or video players embedded on third party platforms ("Video(s)" and "Embedded Video Player", respectively), as well as well as the privacy of the creators of such videos which use the Eko Studio which is available on the Site (respectively, the "Creator(s)" and "Eko Studio" and collectively, "User" or "you" and the "Services"). 

This Privacy applies to our Users located in the European Union (EU), European Economic Area and Switzerland ("Europe"). If you do not reside in Europe the applicable privacy policy is available [Link].

Please read the following carefully to understand Eko's views and practices regarding the use of the personal information which may be collected and processed as part of your use of our services and how Eko will treat it.

Table of Content

  1. About this Privacy Policy
  2. Who we are
  3. Your acknowledgment of this policy
  4. How Do We Collect Information on Our Users?
  5. What are the Purposes of the Collection of Information?
  6. Sharing Information with Third Parties
  7. What are our Legal Basis Data Processing?
  8. Sharing Information with Third Parties
  9. Your Rights
  10. Location of Your Data
  11. Minors
  12. Links to Third Party Websites
  13. Security
  14. Data Retention
  15. Changes to the Privacy Policy
  16. Got any Questions?

1. About this Privacy Policy

This Privacy Policy applies when you visit or use our Site, the Eko Studio, the App and/or view or interact with any of the videos which are available through any of the abovementioned and/or on any Embedded Video Players. It also applies where we are in contact with you in other ways whether in your capacity as an individual or as director, shareholder, partner, employee or other representative of a company or other organization.

2. Who we are

In this policy, references to Eko, or to "we" or "us" are to Interlude US Inc., which is a registered company in the state of New York, with its registered address at235  Park Ave S. New York, NY 1000324, U.S.A. Individuals wishing to contact us about data protection issues may do so by writing to us at the above address or by emailing us at privacy@helloeko.com. 

3. Your acknowledgment of this policy

This privacy policy ("Privacy Policy") details how your Personal Information collected through your use of the Services is used and processed by Eko. 

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE OR THE APP OR THE EKO STUDIO OR THE EMBEDDED VIDEO PLAYERS, YOU ACKNOWLEDGE THAT YOU ARE OR HAVE HAD THE OPPORTUNITY TO BECOME AWARE OF AND AGREE (IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED) TO THIS PRIVACY POLICY AND EKO'S PRACTICES DESCRIBED THEREIN, INCLUDING THE PROCESSING (INCLUDING COLLECTING, USING, DISCLOSING, RETAINING OR DISPOSING) OF YOUR INFORMATION UNDER THE TERMS OF THIS POLICY. 

4. Which information we may collect on our Users?

We collect from Users of our Site, App, Embedded Video Players and the Eko Studio two types of data and information: 

4.1. Non-personal Information. The first type is non-identifiable and anonymous information. Non-personal Information, which is being gathered, consists of technical information and behavioral information that does not pertain to a specific individual ("Non-Personal Information").

You may access, browse and use the Site, App and/or Embedded Video Players without disclosing personal information, although, like most websites and online services, we passively collect certain Non-Personal Information from your devices when you access, use and browse the Site, App, the Eko Studio and/or our Embedded Video Players, including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc.; and (ii) behavioral information which may include the User's click-stream on the Site and App and/or Embedded Video Players, the activities of the User on the Site and App and/or Embedded Video Players and additional information of a similar nature (collectively, "Technical and Behavioral Information"). We may also use third-party service providers such as Google Analytics, Facebook and Snowplow Analytics to obtain detailed analytics on the device and the User's behavior on the Site, App, Embedded Video Players and the Eko Studio. 

Please note that we or our third-party service providers will collect such Technical and Behavioral Information by using certain technologies such as Cookies (as further detailed under our Cookie Policy at [Please insert Link] ("Cookie Policy")). 

4.2. Personal Information. The other type of information we collect is individually identifiable information. To put it simply, this information identifies an individual or is of a private and/or sensitive nature, such as your contact information ("Personal Information"), including:

4.2.1. Personal Information which is provided voluntarily when using the Site, App and/or Embedded Video Players:

4.2.2. Personal Information which is provided voluntarily when using the Eko Studio:

4.2.3. Personal Information relating to job applicants:

You may use the "Careers" page available on our Site in order to apply for a position at Eko and send us your CV, and in such case the following applies: 

4.2.4. Personal Information collected via technology: 

4.2.5. Information from other sources:

4.3. Please note

5. How Do We Collect Information on Our Users?

There are two main methods we use: 

a) We collect information through your entry, connection, access and/or use Site and/or Creator Studio and/or Embedded Video Players and/or the App. In other words, when you are using the Services we are aware of it and may gather, collect and store the information relating to such usage (such as the Non-personal Information detailed above, your IP address and your Video viewing history). 

b) We collect information which you provide us voluntarily. For example, we collect Personal Information when you register and open an account to use the Creator Studio and when you contact us via the Site or App. We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below.

c) We collect information relating to you from third-parties. For example, we may process publicly-available information relating to our Users to obtain demographic, interest based and online advertising related data.

6. What are the Purposes of the Collection of Information?

We collect Non-personal Information and Personal Information in order to provide the Service.

Non-personal Information is processed in order to:   

Personal Information is processed in order to:  

7. What are our Legal Basis Data Processing?

In order for Eko to process your Personal Information, as detailed herein, such processing must be justified by a "basis" for processing. Please note that the Personal Information processing activities detailed herein may be justified on the basis that:

8. Sharing Information with Third Parties

8.1. Eko respects your privacy and will not disclose, share, rent, or sell your Personal Information to any third party, other than as permitted under this Privacy Policy. 

8.2. In addition to using the information collected by us for the purposes described under Section 6 above, we may also share your information in the following cases: 

8.3. For avoidance of doubt, Eko may transfer and disclose Non-personal Information to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Site and App.

9. Your Rights

We hereby inform you of the following rights (by virtue of EU law), in respect of your Personal Information:

To exercise these rights please contact us by sending an email to: privacy@helloeko.com. In order to process your request without undue delay, we kindly request that communications relating to your data subject rights include your contact details, account username (if available) and sufficient details relating to your inquiry/request.   

10. Location of Your Data 

The information collected from you by Eko, as detailed in this Privacy Policy, may be transferred to, and stored at, servers which may be located in countries outside of your jurisdiction and in a country that is not considered to offer an adequate level of protection under your local laws. It may also be processed by Eko and its suppliers, service providers or partners' staff operating outside your country. 

In order to keep your Personal Information safe, we apply strict safeguards when transferring it outside of the EEA, which may include the following: 

You have a right to request further information regarding the data transfer mechanisms used by us with respect to data transfers to third countries, which may be exercised by sending us an email to: privacy@helloeko.com.

11. Minors 

The Site and/or App and/or Embedded Videos and/or Eko Studio are intended for Users over the age of sixteen (16). Therefore, Eko does not intend and does not knowingly collect Personal Information from minors under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Service. If we learn that we collected Personal Information from minors under the age of sixteen (16) we will delete that information as quickly as possible.

12. Third Party Service Providers and Third-Party Software 

12.1. While using the Site and App we may be using third party service providers, who may collect, store and/or process your information, as detailed in this Privacy Policy.

12.2. Note, that we collect, hold and/or manage your Personal Information through Eko's authorized third parties vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes. 

12.3. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction. 

12.4. Such third parties service providers include without limitation the following categories of service providers (for the avoidance of doubt, the specimens of service providers listed below in non-exhaustive): 

Please read such third party service providers' terms of use and privacy policies to understand their privacy practices.

13. Links to Third Party Websites  

Certain links provided in the Site and App permit Users to leave our Site and App and enter non-Eko sites or use non-Eko services. Most of such linked sites and services provide legal documents, including Terms of Use and Privacy Policy governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information about you is being collected.

14. Security 

14.1. We take reasonable appropriate measures to maintain the security and integrity of our Site and App and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures.

14.2. Your Personal Information is hosted on AWS servers, which provide advanced strict security standards (both physical and logical). 

14.3. Some of the security measures that we employ include, without limitation: highly secure services design and implementation using state of the art encryption and architectures mechanisms, restriction of access to your Personal Information to individuals who need access to it in order to process it on Eko's behalf and implementation of a secured permission management and auditing system using specific and proprietary firewall and network access filtering as well as security group mechanisms. 

Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.

14.4. Eko will comply with applicable laws in the event of any breach of the security, confidentiality, or integrity of your Personal Information and will inform you of such breach, if required by applicable law.

14.5. TO THE EXTENT THAT EKO IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, EKO SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE PERSONAL INFORMATION.    

15. Data Retention 

Eko will retain the Personal Information for as long as we have a legitimate business purpose to retain it and as long as it is accurate and can be relied upon. For the avoidance of doubt, Personal Information which is no longer required for the purpose for which is was initially collected will be deleted unless we have a valid justification (including legitimate business purposes) to retain it, or as permitted under applicable law, including to resolve disputes or comply with our legal obligations. 

16. Changes to the Privacy Policy 

The terms of this Privacy Policy will govern the use of the Site and/or App and/or Eko Studio and/or Embedded Videos and any information collected with respect thereto. Eko reserves the right to change this policy at any time, so please re-visit this page frequently. In case of any material change, we will make reasonable efforts to post a clear notice on the homepage of the Site and/or the App or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such substantial changes will take effect seven (7) days after such notice was provided on our Site or sent by e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated "Last Revised" date and your continued use of the Site and/or App and/or Eko Studio and/or Embedded Videos after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

17. Got any Questions? 

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address privacy@helloeko.com. and we will make an effort to reply within a reasonable timeframe.