1. Scope of This Privacy Policy
This Privacy Policy applies to GALLERY+ services that link to or expressly incorporate this Privacy Policy, including, where applicable:- the primary GALLERY+ website;
- GALLERY+ streaming services;
- GALLERY+ divisions and division-specific websites;
- GALLERY+ Backlot;
- content submission systems;
- creator, partner, contributor, or administrator portals;
- support and Help Center services;
- contact, reporting, consent, and inquiry forms;
- newsletters, operational emails, and other electronic communications;
- media distribution-related services;
- music distribution-related services;
- event, school, student, or community-focused GALLERY+ divisions; and
- other digital products or services operated under the GALLERY+ name.
2. Who Is Responsible for Your Information
For purposes of applicable privacy and data protection law, GALLERY+ is responsible for determining how personal information covered by this Privacy Policy is processed unless a particular service states otherwise. For users located in the European Union or European Economic Area, GALLERY+ acts as the “controller” of personal data where GALLERY+ determines the purposes and means of processing that data. In some situations, GALLERY+ may instead process information on behalf of another organization, creator, school-related organization, partner, or service provider. In those situations, the other organization may be the controller of the information. Privacy-related requests may be submitted through the GALLERY+ Help Center or other privacy contact method made available by GALLERY+.3. Information We Collect
The information GALLERY+ collects depends on how you interact with our services.A. Information You Provide Directly
You may provide information to us when you:- create or access an account;
- use GALLERY+ Backlot or another portal;
- submit media for publication or distribution;
- submit music, films, series, albums, photographs, livestreams, or other content;
- submit metadata, credits, artwork, captions, subtitles, or release information;
- contact GALLERY+;
- submit a support request;
- report a technical, legal, copyright, safety, or accessibility issue;
- complete a consent or media-release form;
- apply to participate as a creator, contributor, partner, administrator, or collaborator;
- communicate with GALLERY+ by email;
- subscribe to communications;
- participate in events or programs; or
- otherwise voluntarily provide information.
- name;
- email address;
- telephone number;
- account information;
- username or display name;
- organization or school affiliation;
- creator or artist name;
- role or relationship to submitted content;
- social media or website information;
- release metadata;
- copyright or ownership information;
- licensing information;
- signatures or consent records;
- messages and correspondence;
- support-ticket information;
- submitted files and media;
- information contained within submitted photographs, audio, video, or other media; and
- any other information you voluntarily provide.
4. Content and Media Submitted to GALLERY+
GALLERY+ allows creators, contributors, partners, and other authorized individuals to submit media and related information. Submitted content may include information that identifies or depicts individuals, such as:- names;
- photographs;
- video recordings;
- voice recordings;
- performances;
- interviews;
- credits;
- biographical information;
- school or organizational affiliations; and
- information contained in the media itself.
5. Information Collected Automatically
When you access GALLERY+ websites or digital services, certain technical information may be collected automatically by GALLERY+ or by service providers operating infrastructure on our behalf. This information may include:- Internet Protocol address;
- browser type;
- browser version;
- operating system;
- device type;
- approximate geographic region derived from an IP address;
- referring webpage;
- pages or services accessed;
- date and time of access;
- request logs;
- network information;
- error information;
- diagnostic data;
- security logs; and
- information about interactions with platform features.
6. Streaming and Playback Information
When you stream content through GALLERY+, technical systems involved in content delivery may process information necessary to provide the stream. This may include:- IP address;
- network requests;
- content requested;
- playback session information;
- browser or device information;
- streaming quality requests;
- error or buffering information;
- timestamps; and
- delivery-server or CDN logs.
7. Account and Backlot Information
Certain GALLERY+ services may require authentication. Where an account is provided, we may process information such as:- account identifier;
- email address;
- authentication information;
- account role;
- login timestamps;
- session information;
- permissions;
- actions performed within the account;
- content submissions;
- administrative activity; and
- security-related logs.
8. Support, Contact, and Reporting Information
When you contact GALLERY+, submit a support request, or report an issue, we may retain the information contained in your request and subsequent correspondence. This may include your contact details, description of the issue, screenshots or attachments you provide, technical information, account information, and records of how the matter was resolved. We use this information to respond to you, investigate problems, maintain records, improve GALLERY+ services, and address legal, accessibility, copyright, or safety concerns.9. How We Use Personal Information
GALLERY+ may use personal information to:- provide and operate GALLERY+ services;
- make requested content available for streaming;
- administer accounts and portals;
- authenticate users;
- process content submissions;
- communicate with creators and contributors;
- manage distribution activities;
- review media for publication;
- administer permissions and consent records;
- provide technical support;
- respond to inquiries;
- send service-related notifications;
- notify relevant administrators about submissions or activity;
- maintain platform security;
- prevent fraud, abuse, unauthorized access, or misuse;
- investigate reports and complaints;
- troubleshoot technical problems;
- improve website and streaming performance;
- understand aggregate use of GALLERY+ services;
- comply with legal obligations;
- respond to valid legal requests;
- establish, exercise, or defend legal claims;
- enforce applicable agreements and policies; and
- protect the rights, safety, security, and property of GALLERY+, our users, creators, partners, and others.
10. Legal Bases for Processing Information in the European Union and EEA
Where the General Data Protection Regulation (“GDPR”) or similar European data protection law applies, GALLERY+ processes personal data only where a lawful basis exists. Depending on the circumstances, our legal bases may include:Contract
Processing may be necessary to provide a service you requested or to take steps at your request before entering into an agreement. For example, this may apply when you submit content for publication or distribution or use an account-based GALLERY+ service.Legitimate Interests
We may process personal data where reasonably necessary for legitimate interests pursued by GALLERY+ or another party, provided those interests are not overridden by your fundamental rights and freedoms. These interests may include:- operating GALLERY+;
- securing our services;
- preventing fraud and abuse;
- administering content;
- communicating with users;
- protecting intellectual property;
- resolving disputes;
- improving service reliability; and
- maintaining appropriate business and administrative records.
Consent
Where required, GALLERY+ may process information based on your consent. If processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before consent was withdrawn.Legal Obligation
GALLERY+ may process information where necessary to comply with applicable laws, regulations, court orders, legal processes, or legally binding requests.Protection of Vital Interests
In limited circumstances, information may be processed where necessary to protect someone’s vital interests.11. Cookies and Similar Technologies
GALLERY+ services may use cookies, local storage, session storage, or similar technologies. These technologies may be used for purposes such as:- maintaining login sessions;
- remembering settings;
- providing security functions;
- maintaining user preferences;
- supporting media playback;
- preventing abuse;
- measuring technical performance; and
- understanding service operation.
12. Analytics
GALLERY+ may use analytics or diagnostic services to understand how its websites and services perform. Analytics data may include information about page visits, device types, approximate location, interaction events, errors, and general usage patterns. Where reasonably possible, GALLERY+ may use aggregated or de-identified information for analytics. If GALLERY+ introduces analytics technologies that require consent under applicable European privacy or electronic communications laws, appropriate consent mechanisms should be provided before those technologies are activated.13. Service Providers and Infrastructure Providers
GALLERY+ relies on third-party technology providers to operate its services. Depending on the service being used, these providers may support areas such as:- website hosting;
- content delivery;
- media storage;
- video processing;
- databases;
- authentication;
- email delivery;
- support services;
- security;
- forms;
- infrastructure;
- analytics; and
- domain or network services.
14. When We Share Personal Information
GALLERY+ does not disclose personal information indiscriminately. We may disclose information in the following circumstances.Service Providers
We may provide information to companies that operate technology or services on our behalf.Creators, Partners, or Division Administrators
Where reasonably necessary to operate a GALLERY+ division, process a submission, administer content, or respond to a request, information may be shared with authorized creators, administrators, partners, or staff responsible for the relevant activity. Access should be limited to information reasonably necessary for that role.Legal Requirements
We may disclose information where we reasonably believe disclosure is necessary to:- comply with applicable law;
- respond to a subpoena, court order, or other valid legal process;
- cooperate with lawful government requests;
- investigate suspected unlawful activity;
- enforce our rights or agreements;
- protect the safety of a person;
- protect GALLERY+ systems or property; or
- establish, exercise, or defend legal claims.
Organizational Changes
If GALLERY+ or a portion of its operations is reorganized, transferred, merged, acquired, or otherwise changes ownership or control, information associated with the affected service may be transferred as part of that transaction, subject to applicable law.15. Sale and Sharing of Personal Information
GALLERY+ does not intend to sell personal information in exchange for money. GALLERY+ also does not intend to use personal information for cross-context behavioral advertising or targeted advertising based on activity across unrelated websites unless this practice is separately disclosed and any legally required choices are provided. If GALLERY+ changes these practices in the future, this Privacy Policy and any required opt-out mechanisms will be updated accordingly.16. International Data Transfers
GALLERY+ services may be accessible internationally, and the infrastructure supporting GALLERY+ may operate in countries other than the country where you reside. As a result, personal information may be transferred to, processed in, or stored in the United States, European countries, or other jurisdictions. Privacy and data protection laws in those jurisdictions may differ from the laws of your country. Where the GDPR requires safeguards for a transfer of personal data outside the European Economic Area, GALLERY+ will seek to rely on a legally recognized transfer mechanism where required, which may include:- an adequacy decision;
- Standard Contractual Clauses;
- another legally approved transfer mechanism; or
- a specific exception permitted by applicable law.
17. Data Retention
GALLERY+ retains personal information only for as long as reasonably necessary for the purposes for which it was collected, subject to legal, operational, security, contractual, and recordkeeping requirements. Retention periods may vary depending on the type of information. For example:- account information may be retained while an account remains active and for a reasonable period afterward;
- support records may be retained to maintain service history and resolve recurring issues;
- technical logs may be retained for limited periods for security and diagnostics;
- content-submission records may be retained while content remains published or distributed;
- licenses, releases, permissions, and legal records may be retained for longer periods where needed to demonstrate authorization or protect legal rights; and
- information subject to a legal dispute or preservation obligation may be retained until that obligation ends.
18. Data Security
GALLERY+ takes reasonable technical and organizational measures intended to protect personal information against unauthorized access, disclosure, alteration, destruction, loss, or misuse. Measures may include, where appropriate:- encrypted network connections;
- authentication controls;
- restricted administrative access;
- role-based permissions;
- secure hosting infrastructure;
- security logging;
- access controls;
- backups;
- monitoring;
- limited access to administrative systems; and
- security practices implemented by infrastructure providers.
19. Privacy of Children
GALLERY+ is a general-audience service and is not intended to be directed primarily toward children under 13. GALLERY+ does not knowingly seek to collect personal information directly from children under 13 without authorization required by applicable law. If GALLERY+ learns that personal information has been collected directly from a child under 13 in circumstances where parental consent was legally required and was not obtained, we may take steps to delete the information. A parent or legal guardian who believes a child has provided personal information to GALLERY+ inappropriately may contact us through the GALLERY+ Help Center. Different age thresholds may apply outside the United States. Where European law requires parental authorization for consent-based processing involving a child, GALLERY+ will seek to comply with the applicable national age threshold.20. Students and Minors Appearing in GALLERY+ Content
Some GALLERY+ content, particularly content associated with school, student, educational, community, or event divisions, may feature individuals under the age of 18. The presence of a minor in publicly streamed or published media does not necessarily mean GALLERY+ directly collected online account information from that minor. Media involving minors should be submitted only where the person submitting or authorizing the material has obtained any permission, consent, media release, or other authorization required by applicable law, school policy, event rules, or agreement. GALLERY+ may request evidence of authorization before publishing certain media. A parent, guardian, school representative, or other authorized person may contact GALLERY+ if they have a privacy concern regarding a minor appearing in content hosted by GALLERY+.21. School-Related Divisions
A GALLERY+ division associated with a school, student group, event, organization, or community does not necessarily mean that GALLERY+ is owned, operated, sponsored, endorsed, or controlled by that institution. Where an independent GALLERY+ division receives media or information from students, creators, event organizers, school-related individuals, or other contributors, applicable privacy responsibilities will depend on the circumstances under which the information was collected. GALLERY+ may maintain additional consent, media-release, submission, or legal procedures for these divisions.22. Public Content
Certain information submitted to GALLERY+ is specifically intended for public display. Examples may include:- creator names;
- artist names;
- film credits;
- album credits;
- photographs;
- artwork;
- biographies;
- release information;
- performances;
- videos;
- livestreams; and
- other published media.
23. Third-Party Links and Services
GALLERY+ services may contain links to third-party websites, social networks, services, stores, streaming providers, or other platforms. This Privacy Policy does not govern independent third parties. When you leave GALLERY+ or interact directly with another service, that service’s privacy policy and terms apply. GALLERY+ is not responsible for the privacy practices of independent third-party websites or services.24. Email and Electronic Communications
GALLERY+ may send operational messages related to:- accounts;
- invitations;
- submissions;
- approvals;
- support tickets;
- security;
- service changes;
- administrative activity;
- content distribution; or
- other requested services.
25. Automated Decision-Making
Unless separately disclosed, GALLERY+ does not make decisions producing legal or similarly significant effects about users based solely on automated processing of personal information. GALLERY+ may use automated technical systems for ordinary functions such as spam detection, security monitoring, content delivery, or authentication.26. Your Privacy Rights
Depending on where you live and applicable law, you may have rights regarding your personal information. These may include the right to:- request information about how your personal information is processed;
- request access to personal information held about you;
- request correction of inaccurate information;
- request deletion of certain personal information;
- request restriction of processing;
- object to certain processing;
- withdraw consent;
- receive certain information in a portable format;
- opt out of certain sales, sharing, targeted advertising, or profiling where applicable;
- limit certain uses of sensitive personal information where applicable; and
- lodge a complaint with an appropriate privacy or data protection authority.
27. European Union and EEA Privacy Rights
If you are located in the European Union or European Economic Area and the GDPR applies to the processing of your personal data, you may have the right to:Access
Request confirmation of whether GALLERY+ processes your personal data and obtain access to applicable data.Rectification
Request correction of inaccurate or incomplete personal data.Erasure
Request deletion of personal data in circumstances recognized under the GDPR.Restriction
Request that processing of certain personal data be restricted.Objection
Object to processing based on certain legitimate interests or to processing for direct marketing.Data Portability
Where applicable, request certain personal data you provided in a structured, commonly used, machine-readable format.Withdraw Consent
Where processing relies on consent, withdraw that consent at any time.Complaint
You may lodge a complaint with the data protection authority in the EU or EEA country where you live, work, or believe an infringement occurred. You are encouraged to contact GALLERY+ first so that we have an opportunity to address your concern.28. United States Privacy Rights
Residents of certain U.S. states may have additional privacy rights under state law. Depending on the applicable state and whether GALLERY+ is legally subject to that state’s privacy law, rights may include:- knowing what personal information is collected;
- accessing personal information;
- correcting inaccurate personal information;
- deleting personal information;
- obtaining a portable copy of certain information;
- opting out of the sale of personal information;
- opting out of sharing for cross-context behavioral advertising;
- opting out of targeted advertising;
- opting out of certain profiling;
- limiting certain uses of sensitive personal information; and
- exercising privacy rights without unlawful discrimination.
29. California Privacy Notice
This section supplements the remainder of this Privacy Policy for California residents where the California Consumer Privacy Act, as amended (“CCPA”), applies to GALLERY+. Depending on our interactions with a consumer, categories of personal information collected may include:- identifiers, such as names, email addresses, IP addresses, or account identifiers;
- internet or electronic network activity;
- audio, visual, or similar information;
- professional, educational, creator, or organizational information voluntarily provided to us;
- account or authentication information;
- correspondence;
- content-submission information; and
- inferences or diagnostic information derived from use of our services where applicable.
30. Sensitive Personal Information
GALLERY+ generally does not seek sensitive personal information unless it is necessary for a specific service. Sensitive information may receive enhanced protection under applicable law. Users should avoid submitting information such as:- government identification numbers;
- financial account credentials;
- precise location information;
- medical information;
- biometric identifiers;
- passwords; or
- other highly sensitive information
31. Exercising Your Privacy Rights
Privacy requests may be submitted through the privacy or contact options provided by the GALLERY+ Help Center. When submitting a request, please provide enough information for us to understand:- who you are;
- which GALLERY+ service your request relates to;
- the information or account involved; and
- which privacy right you wish to exercise.
32. Response to Privacy Requests
GALLERY+ will respond to valid privacy requests within the timeframe required by applicable law. Under the GDPR, this is generally without undue delay and normally within one month, subject to legally permitted extensions in appropriate circumstances. U.S. state privacy laws may provide different response periods. If we cannot fulfill a request, we may explain the reason where required by law. Certain information may be exempt from deletion, access, or other rights where retention or processing is necessary for legal compliance, security, fraud prevention, freedom of expression, contractual obligations, the rights of others, or the establishment, exercise, or defense of legal claims.33. Account Deletion
Where GALLERY+ provides registered accounts, users may request deletion of their accounts unless retention is reasonably necessary for legal, security, contractual, or administrative purposes. Deleting an account does not necessarily require deletion of publicly released media, creator credits, distribution records, licensing records, consent documentation, legal records, or other information that GALLERY+ has an independent lawful basis to retain.34. Do Not Track and Privacy Preference Signals
Web browsers and devices may transmit privacy preference signals. Where applicable law requires GALLERY+ to recognize a legally valid opt-out preference signal, GALLERY+ will seek to honor that signal for the processing to which the requirement applies. Because GALLERY+ does not currently intend to sell personal information or use personal information for cross-context behavioral advertising, certain opt-out signals may not materially change the operation of the service.35. Data Breaches and Security Incidents
If GALLERY+ becomes aware of a security incident involving personal information, we may investigate the incident and take reasonable steps to contain and remediate it. Where applicable law requires notification to affected individuals, regulators, or other authorities, GALLERY+ will seek to provide such notification in accordance with those requirements.36. Law Enforcement and Government Requests
GALLERY+ may receive requests for information from law enforcement agencies, courts, regulators, or government authorities. GALLERY+ will evaluate such requests and may disclose information where legally required or where disclosure is otherwise permitted under applicable law. GALLERY+ may challenge, narrow, or reject requests that we believe are invalid, overly broad, or legally insufficient where appropriate.37. Content Removal and Privacy Requests Are Different
A privacy request is not necessarily the same as a request to remove published media. Requests concerning copyrighted content, media rights, consent, legal disputes, safety concerns, or unauthorized publication may be handled under separate GALLERY+ reporting, legal, copyright, or media-consent procedures. Where a request involves both personal data and published media, GALLERY+ may evaluate the request under both privacy law and applicable content rights.38. Changes to This Privacy Policy
GALLERY+ may update this Privacy Policy from time to time. Changes may be made to reflect:- new services;
- changes in technology;
- new service providers;
- changes in privacy practices;
- legal or regulatory requirements; or
- operational changes.
39. Applicable Privacy Laws
GALLERY+ seeks to handle personal information consistently with privacy and data protection laws applicable to its operations. Depending on the circumstances, these may include:- applicable United States federal privacy laws;
- applicable U.S. state consumer privacy laws;
- the California Consumer Privacy Act, as amended, where applicable;
- the Children’s Online Privacy Protection Act where applicable;
- the European Union General Data Protection Regulation;
- applicable European electronic communications and cookie rules; and
- applicable national privacy laws within EU and EEA Member States.