Last Updated: September 12, 2023
We built TODA with privacy in mind. Our priority is to keep your information safe and secure and clearly explain how we use it. This Privacy Policy (“Policy”) explains how we handle your information, and how to exercise your rights and choices.
This Policy applies to these services:
» The TODA Live Live apps for distributed on iOS, Android, Mac, Windows;
» the TODA Live extensions for Adobe, Avid and Blackmagic products and services;
» the TODA Live web application; and
» anywhere else we gather information about you and refer to this Policy
For simplicity, we call these services the “Services” in this Policy. This policy does not apply to use of LMMV.com, aside from the TODA Live web application
1. who we are and how this Policy works;
2. the categories and specific types of information we collect;
4. when we exchange information with other parties; and
5. your rights and controls over information about you, including rights under GDPR and California law.
We encourage you to read this Policy carefully. If you have questions, please Contact us.
Like Minded Labs Canada operates the Services and is referred to in this Policy as “TODA”, “we”, “our” or “us”. This Policy supplements and is governed by our Terms of Service (“Terms”). Capitalized terms that we use but do not define in this Policy are defined in our Terms. The Terms describe how the Services works in general, including security measures we use to protect our systems and the information described in the Policy.
This Policy applies to you when you use the Services. By using or accessing the Services, you signify that you have read, understand and agree to be bound by this Policy and the Terms.
» If you are a current or former employee or contractor of ours, this Policy does not apply to you. You may contact us about your privacy practices and rights at legal@lmmv.com.
» If we receive your information in our role as a contractor or service provider to another business, please see Our Role.
This Policy is effective as of the Last Updated date above.
Because the Services changes often, this Policy may change over time. Anytime we modify the Policy, we will post a revised version on the Services and update the Last Updated date above. If you have given us your contact information, we will notify you before any material changes take effect so you have time to review them. Still, you should review this Policy periodically to ensure that you are aware of the disclosures in the current version.
The Services operates from the United States, but this Policy applies worldwide. Our practices generally do not differ based on your location, but your rights and choices depend in part on the law where you live. For example, you may have rights under:
» “GDPR”: implementations of the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679; and
» “CCPA”: the California Consumer Privacy Act, as amended.
As a result, some sections of this Policy apply to you only if you reside in a particular location.
» California residents should see Rights under California law .
→ If you reside in a U.S. jurisdiction that has enacted a data privacy law similar to CCPA, we extend the same rights CCPA grants to California residents to you, except where we specify otherwise.
» Residents of jurisdictions where GDPR applies – such as U.K., EU and Swiss residents – should consult the Rights under GDPR and International Data Transfers sections.
If any of those sections apply to you, those sections override any contrary descriptions elsewhere in the Policy as they relate to you. If you have questions about your rights under other data privacy laws, please Contact us .
Often, we are the business controlling the personal information we collect about you.
However, if we receive your personal information in our role as a contractor or service provider to one of our customers (such as any account owner provisioning your access or account with TODA), we may serve in a different role under applicable law. That customer may serve as business controlling our processing of your information. In those circumstances:
» Additional privacy notices or policies, provided by the customer to you, may govern or apply to the personal information you provide through our services
» We will direct any questions or rights requests you may send us as required under our customer agreements or applicable law.
This table explains the categories of personal information we collect, with examples.
For clarity, we do not collect:
» Sensitive personal information
» Personal information about anyone under the age of 16 (see Use by minors for more details)
We don’t use, sell, share any of those types of information.
Our personnel do not access User Content—including meeting or messaging content—unless authorized by the administrator or other controller of Business User account, or to the minimum extent required for legal, safety, or security reasons, as discussed below. The Services process User Content solely to deliver the Services to the users who you permit to access it, such as in a meeting or when you download a recording. We do not use User Content to improve the Services or develop new ones.
We otherwise use personal information to conduct the following activities:
1. To provide the Services to you
→ Create and manage your account
→ Provide you with customer support and respond to your requests
→ Complete your orders
→ Communicate with you about our services
2. To manage your account or enable your communications
→ Register you on the services and remember your devices and settings
→ Administer your account on new features and apps
3. To improve our services and develop new ones
→ Troubleshoot products and services
→ Review interactions with customer teams to improve our quality of service
→ Develop new content and services
4. To operate advertising and marketing campaigns
→ Message you, after you have given your consent and only until you withdraw it, about offers, including on a personalized basis.
5. To prevent, detect and fight fraud and other illegal or unauthorized activities
→ Authenticate accounts and activity
→ Find and address ongoing, suspected or alleged violations of our Terms
→ Better understand and design countermeasures against violations of our Terms
→ Retain data related to violations of our Terms to prevent against recurrences
→ Enforce or exercise our rights; for example, those in our Terms
6. To ensure legal compliance
→ Verify copyright or IP claims
→ Comply with legal requirements
→ Assist law enforcement
We rely on the following purposes to collect and use your information as described in this Policy:
» Commercial purposes: The reason we process your information for purposes 1, 2, 3 and 4 above is to advance your economic interests or our economic interests. These purposes include performing the contract that you have with us, as embodied by our Terms, which advances our economic interests and yours. For instance, if you order products from us, we use your information to complete your payment and provide your product to you. Further, as you discover content on the Platform, we may tailor the content to your interests, which increases the usage of the Platform and thereby advances our economic interests.
» Business purposes: We process your information for purposes 1, 2, 5 and 6 above for operational reasons, in a reasonably necessary and proportionate manner (i.e., for business purposes under CCPA). For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you and promote our own services, we process information to help keep our members safe and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.
» Comply with applicable laws and regulations: We process your information for purpose 6 above where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement.
» Consent: From time to time, we may ask for your consent to collect specific information, or use your information for certain specific reasons, like providing your email address or phone number for direct marketing purposes. In general, you may withdraw your consent by changing your settings (such as browser or device settings) or following instructions provided with information we send you based on the consent you gave us (such as texting ‘stop’ to text messages from us). You may always withdraw your consent at any time – just Contact us.
We provides personal data to third parties only with consent or in one of the following circumstances (subject to your prior consent where required under applicable law):
We don’t exchange personal information with third parties for behavioral advertising (i.e., ads targeted to you), or otherwise sell it. Nor have we done so in the past twelve (12) months. Let’s get that out of the way.
We only exchange information about you with third parties for direct marketing purposes if you opt in, and will only do so until you opt out.
We contract with businesses to provide certain services related to the functionality and features of the Services, including payment processing, email and hosting services, software development and data management. We refer to them as “vendors.”
We may disclose information about you, such as Personal Identifiers, Commercial Information, Internet Activity and Device Information, to vendors as necessary for them to perform their services. Our vendors are not permitted to use your information for any other purpose. In the past twelve (12) months, we have disclosed personal information to the following types of vendors:
» Analytics providers, namely Google Analytics, to tell us how the Services is doing, such as which parts interest visitors and how long they visit before leaving. Among other data, they may receive your IP address.
» Various hosting services and data processors to provide the infrastructure of the Services, such as Cloudflare, which ensures that traffic is from real people, not computers. Among other data, they may receive your IP address.
» Payment providers, namely Stripe, to process payments between you and us.
Finally, we may share your information:
» In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us;
» When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with the enforcement of our Terms and other agreements; or
» In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
We may periodically ask for your consent to exchange your information with third parties. Whenever we ask your consent for this reason, we will summarize the purpose and scope of the exchange.
We retain your information only as long as we need it for the purposes described under How we use information , except when longer retention is required by our compliance policies and efforts toward applicable legal, tax, accounting and regulatory requirements.
How long we need information for those purposes varies by category, and even within categories. These retention determinations always consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from its unauthorized use or disclosure, whether we can achieve those purposes without using the personal information.
For example, we delete some Internet Activity at some soon as you exit the Platform, whereas we may retain records of your orders for services for several years as required by law or contract, such as agreements with our payment processors or under our accounting standards.
We want you to be in control of your information, so we want to remind you of the following options and tools available to you:
» Opting Out of Communications
If you have opted in to receive marketing or commercial messages from us, we may use the information we collect from you to send messages to you. If you do not want to receive these messages, you can opt out (as applicable) by using the unsubscribe link at the bottom of our communications, unchecking the applicable box to opt out when prompted, or by simply not opting in when prompted. You may also at any time opt out of receiving communications from us by contacting us.
Please note that even if you unsubscribe from our communications, we may still need to contact you with important information related to your account and your purchases. For example, even if you have unsubscribed from our promotional emails, we will still alert you to changes to our Terms or Privacy Policy.
» Disallowing Background and Location Data Collection
You may limit or restrict the operation of background technologies (such as ‘cookies’ and activity trackers) in your browser, app and/or device-level settings. Check your browser, device or [the App’s settings menu for more information].
This section applies to you only if you reside in a jurisdiction where GDPR applies. When you see italics in this section, it denotes the first time we use terminology defined in GDPR.
The purposes and the legal bases for our collecting and processing of personal data under GDPR are generally described under How we use information. For GDPR purposes, when we process your data as a data controller, we rely on the following legal bases (as applicable in your jurisdiction):
» As necessary for our contract: When we enter into a contract directly with you, we process your personal data on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract (i.e., providing TODA services, features and services to you and/or account owners, and manage our relationship and contract, including billing and compliance). If we do not process your personal data for these purposes, we may not be able to provide you with all products and services.
» Consistent with specific revocable consents: We rely on your prior consent in order to utilize cookies to engage advertising and analytics partners to deliver tailored advertising and analysis of our website usage. You have the right to withdraw your consent at any time through the methods specified in our consent notifications, your browser, app or device settings (as applicable) or by contacting us.
» As necessary to comply with our legal obligations: We process your personal data to comply with the legal obligations to which we are subject for the purposes of compliance with GDPR as applicable to us, including requests from competent legal authorities. This includes detection and cessation of harmful, unauthorized or illegal activity and compliance with privacy laws.
» To protect your vital interests or those of others: We process certain personal data in order to protect vital interests for the purpose of detecting and preventing illegal activity that impacts public safety.
» As necessary for our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms: We process your personal data based on such legitimate interests to (i) enter and perform the contract with you or the account owner providing you with the Platform (which includes billing, compliance with contractual obligations, and related administration and support); (ii) develop, test, and improve our products and services and troubleshoot products and services; (iii) ensure authentication and safety of accounts, activity, and products and services, including detect and prevent malicious conduct and violations of our terms and policies, prevent or investigate bad or unsafe experiences, and address security threats; (iv) send marketing communications and promotions related to the Platform; and (v) comply with non-GDPR law applicable to us, including requests from competent legal authorities.
Depending on your jurisdiction’s enactment of GDPR, you may have these rights:
» Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
» Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
» Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we might not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
» Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
» Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
» Request the transfer of your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
» Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we might not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You may exercise rights under GDPR as described under Requesting information. If you do not provide personal data to us or withdraw consent for processing personal data, we may not be able to provide you with certain aspects of the Services.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
If you reside outside the United States, we transfer information about you for processing in the United States. By providing information about you to enable the Services , you consent to the processing of such data in the United States. The transfer of this information to the United States is necessary for the performance of our contract for use of the Services.
When we transfer personal data subject to GDPR outside of TODA, we use standard contract clauses approved by the EU for this purpose, or another appropriate transfer mechanism.
Note that U.S. law is not equivalent to GDPR. As of the Last Updated date above, the U.S. has not been deemed an “adequate” jurisdiction by the EU for international data transfers. However, the EU and the U.S. are negotiating the terms of an adequacy determination that may go into effect in the years to come.
This section applies to you only if you reside in California or another U.S. state where applicable law provides for some or all of these rights or substantially similar rights. Except as noted in this section, we extend these California rights to residents of those states regardless of whether applicable law in those states includes all of these rights.
The California Consumer Privacy Act (“CCPA”) provides California consumers with additional rights regarding their personal information (as defined in CCPA) (d) .
The categories of personal information we collect are generally described in Information we collect above, and depend on how you use the Platform. For clarity, we have collected personal information for these CCPA categories of business and commercial purposes in the last twelve months:
» Advertising and Marketing
» Error Management
» Internal Research
» Provide Products or Services
» Quality Assurance
» Security
» Short-Term Transient Use
The categories of third parties to whom we disclose personal information are under Our exchange of information with others above. The disclosures under Purposes above supplementally describe with business purpose or commercial purpose for those exchanges of information.
Under CCPA, California consumers have the following rights:
You have the right to request that we disclose, correct and delete personal information about you that we have collected. Your right to know includes the personal information we have sold or shared or disclosed for a business purpose.
Finally, we may deny deletion requests, in whole or in part, with respect to information we reasonably need to:
» comply with a legal obligation
» allow you, other consumers, or us to exercise free-speech rights or other legal rights
» perform our contract with you
» or if we use the information for solely internal purposes reasonably aligned with consumer expectations.
You also have the right to direct us (1) not to share or sell your personal information and (2) limit our disclosure and use of your sensitive personal information to purposes necessary to provide the Platform to you.
We do not sell or share your information, so we do not provide a mechanism to exercise these rights.
As of the Last Updated date, we have no knowledge of any use of personal information we collect from individuals under the age of 16 for ‘sale’ or ‘sharing’ purposes.
CCPA prohibits us from discriminating against you if you exercise rights under CCPA, except when you opted in to a financial incentive involving certain of your personal information, and subsequently restrict our use of that personal information through a CCPA rights request.
Your right of no retaliation doesn’t need to be exercised. We never retaliate against anyone exercising their rights under this Policy or CCPA.
To submit a CCPA request relating to the foregoing rights, please contact us as described under Requesting information . That section generally applies to requests to exercise CCPA rights. However, in addition:
» A California resident's authorized agent may submit CCPA rights request.
→ Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described below. We will also ask for proof that the person who is the subject of the request authorized an agent to submit a privacy request on their behalf.
→ An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 must submit proof of statutory power of attorney, but consumer verification is not required.
» We will confirm receipt of your CCPA request within 10 days, and will substantively respond within 45 days.
» We may initially substantively respond by informing you that we will require up to 45 further days, along with an explanation of why our substantive response is delayed.
» We provide responses in the manner we receive your request (i.e., with an email response to an email request).
Because we only give your information to third parties for direct marketing purposes with your consent, and always allow you to opt out of direct marketing communications after opting in, we believe we are not currently required to comply with California Civil Code Section 1798.83.
To exercise any right described in this Your rights section, please contact us. Your request must:
» provide sufficient information to identify you and the law that applies to you, such as your name, e-mail address, home or work address, or other information we maintain.
» not include social security numbers, driver’s license numbers, third-party account numbers, credit or debit card numbers, or health information.
We verify requests by confirming the source of the request and then by matching the information submitted to the information we maintain. If your request is unclear or we are unable to authenticate your identity, we will respond with direction to remedy the deficiencies, in accordance with law that applies to you.
If we cannot verify the identity of the individual making the request, we may deny it, in full or in part.
We will respond to your request as quickly as we can, taking into account the nature of your request and the volume of pending requests. The content of our response will vary with the nature of your request, but will always respond in accordance with any deadlines or requirements specified by the laws that applies to you.
Under certain circumstances, we may be unable to provide responsive personal information, such as when disclosure would create a substantial, articulable and unreasonable risk to the security of the information, customers’ account with us, or the security of our systems or networks. We do not disclose account passwords or any other non-personal information that enables access to an account.
Please understand, however, that we reserve the right to retain an archive of any information about you, to the extent permitted by law. We may also retain deidentified or aggregate data derived from information about you.
We do not permit children under the age of 16 to sign up for a TODA account. We do not knowingly collect information from anyone under the age of 16. If we learn that we have collected information from a child under age 16, we delete that information as quickly as possible.
» If you are under 16: sorry, but please leave the Services. If you’ve already sent us information, please Contact us first so we can delete it.
If you are a parent or guardian of a child under 16 years of age and you believe your child has provided us with information please contact us.
If you have questions or comments about this Policy, please contact us at help@lmmv.com, with “Privacy” in the subject line.
