Vive Privacy Policy
Welcome to Vive, the world’s best platform for connecting trainers or coaches with clients
(users), anytime and anywhere in the world. As a trainer you are able to create Vive class rooms
and share your expertise with users around the globe via live online video streams. We are
committed to protecting the privacy, confidentiality, and security of your personal data (“Personal
Data”) that we hold by complying with the requirements of applicable laws and regulations. We
are equally committed to ensuring that all our employees, service providers, and agents uphold
these obligations. This policy explains how we manage Personal Data and your rights and
choices regarding our processing of your Personal Data.
● “User”, “Users”, or “You” is all Users of the application
● A User is someone who books, pays for or attends Classes
● A “Trainer” is a User who creates, schedules, streams, and hosts paid Classes
● “Class(es)” is/are offered by trainers and can be for individuals or groups.
● A trainer may, if desired, record a copy of themselves hosting a class but the application
will not record the users video.
Contact details of data controller (as defined in applicable regulations): Level 35, Tower One
Barangaroo, International Towers Sydney, 100 Barangaroo Avenue, Sydney, Australia. E-mail:
accounts@vivelive.ai
Data Protection Contact: accounts@vivelive.ai
Information we collect on our platform
We collect and process the following Personal Data about you, and provide the reasons for
collecting and the retention period we hold this data below. We do not share, sell, rent or trade
Personal Data with third parties for their commercial purposes, except when you have
consented.
a. Personal information processed by Vive
If you use Vive, we process the following data as the data controller:
For all Users:
● Account and profile information. This is data that all Users provide when creating
a Vive account and profile, in order for us to carry out the establishment of the
account and granting access to the application. This can include:
a. Email address
b. User name
c. Password
d. Links to social accounts
e. Class preferences
f. Gender
g. Age
h. Profile photo
i. Biography
j. Course enrollments
● We automatically store any comments or messages you submit on Vive, whether
to us or to another User, and whether via messaging, chat, or email. We also store
some notes of correspondence with you.
● We collect data such as the last time you have used Vive, whether you are a
trainer or a user, and the content you view on Vive, which is used to help optimize
the application’s user experience.
● All User-generated content, including video, thumbnails of videos hosted on third
parties and linked to Vive, and audio (including shared audio from browser tabs),
as well as comments/chat information that a User chooses to provide (including
use of camera and microphone), during a Vive Class is processed by Vive.
● We collect information on the number of Classes instructed/attended, and
information on the aggregate amount received / paid and refunded/credited for
each User.
● We collect aggregated information on Class and trainer preferences for class
type and length.
b. For Users:
● A user is someone who signs up and enrols in a Vive Live course or uses the
application for the shop or metaverse experience..
● We collect information on how many and which Vive Classes a user has joined,
which trainers you attend Classes with, and how often you attend Classes.
● We collect aggregated Class-level analytics for each user.
c. Information automatically collected by Vive
You can visit Vive without telling us who you are. For technical reasons, however, we
collect the following data that your browser transmits to our server when you are
navigating the site or through some third party providers:
● IP address
● date and time of the request
● Time zone difference to Greenwich Mean Time (GMT)
● Content of the request (concrete page)
● Access status/HTTP status code
● amount of data transferred in each case
● Website from which the request originates
● browser
● operating system and its interface
● anonymous website activity logs
● language and version of the browser software
d. We use this data for the legitimate interest of displaying our website to you and providing
stability and security in the operation of our website.
e. We collect / process Personal Data about you in the following ways:
● When you register for Vive or consent to receive emails from us
● When you create an account and profile on Vive
● When you enrol in a course on Vive
● When you order services from us
● When you submit a query or request to us
● When you message or email us, such as for technical or other reasons
● When you respond to a survey that we run or fill in forms on one of our websites
● By tracking your use of our websites such as the Vive Live Shop and Vive Live
Metaverse
How we use your personal data
We use Personal Data that we collect about you for the following purposes and on the following
legal bases:
● When you provide us with consent to the processing of your Personal Data for one or
more specific purposes. Example:
○ To keep you informed about our activities. Upon submission of your request, you
will receive at the specified email address a double opt-in request to confirm the
consent to receive updates from us, which include emails relevant to your usage
of Vive.
● When there is a legitimate interest, meaning the interest of our business in conducting
and managing our business to enable us to give you the best service/product and the
best and most secure experience. We make sure we consider and balance any potential
impact on you (both positive and negative) and your rights before we process your
Personal Data for our legitimate interests. Examples:
○ Handling contact and user support requests
○ When adding a Class to your calendar
○ To improve our website and Classes based on your information and feedback
○ To carry out market analysis and research
○ To monitor the use of our products and services
○ To assess, maintain, upgrade and improve our products and services
○ To carry out education and training programs for our staff
○ To manage and resolve any legal or commercial complaints or issues, or to
prevent fraud and abuse on the Platform
○ To carry out planning and forecasting activities and other internal business
processes
● In the performance of a contract with us. This means processing your data where it is
necessary for the performance of a contract to which you are a party or to take steps at
your request before entering into such a contract. Examples:
○ To verify your identity when you are dealing with us
○ To provide the application, including the Classes, to you
○ To allow you to sign in to your account
○ To allow you to join a Class
○ To process payments through our third party payment processor
○ To send you emails regarding your confirmed Classes, or other emails that are
transactional in nature
● If you have approved (opted-in) receiving marketing materials from us, to send you
marketing materials about products or services that we think you may be interested in
(including in some cases products and services that are provided by a third party). We
may use your following Personal Data for the purpose of direct marketing.
○ identifying information, such as your name and date of birth
○ contact information, such as your postal address and email address
○ products and services portfolio information and demographic data held by us
from time to time
● You can revoke your consent at any time in the following ways:
○ Click the “Unsubscribe” button in the emails you receive from us
○ Sending an email to accounts@vivelive.ai
○ By sending a message to the contact details provided on the vivelive.ai
homepage.
Sharing of personal information
a. Information We Share
We may share Personal Data about you only if it is necessary for the purposes described
above and only on a legal basis. We might share your Personal Data with:
● Your representatives, advisers, and others you have authorized to interact with us
on your behalf
● Our staff who need the information to discharge their duties
● Related entities within our corporate group in order to fulfill the services
● Trainers and other third parties in order to fulfill the services
● Payment system operators and financial institutions in order to fulfill the services
● Government authorities who ask us to disclose that information, or to other
people as required by law
● Advertising partners, who provide you with targeted advertising based on your
browsing activities and interests.
b. Information We Share with Third Parties
We use external service providers for processing of some Personal Data. Within the
framework of a contract for data processing, these service Providers have committed
themselves, among other things, to observing appropriate technical and organizational
measures for data security and act in accordance with instructions on our behalf. Our
main service providers are listed below but are subject to change. We never sell your
Personal Data to third parties.
Amazon Web Services, INC. (AWS), USA
We use AWS to handle our infrastructure, hosted on AWS virtual servers located in
Ireland. We use the following services offered by Google LLC (“Google”):
● GSuite(Google Apps), for all email, documents, forms, and spreadsheet creation.
● Google Analytics for our analysis and tracking needs.
● Google Tag Manager (GTM), is processing data from Google Analytics and
Google Adwords.
● Google Optimize to perform A/B testing on our content and design online. Google
Optimize uses Google Analytics cookies in order to collect information about the
visitors on our websites.
● Google Analytics
c. We use Google Analytics for the legitimate interest of analyzing the use of our website.
Our analytics service provider generates statistical and other information about website
use by means of cookies. Google Analytics is present on the website and software
through the means of Google Tag Manager which through its code snippet delivers the
Google Analytics cookie. You can read more on Google cookies in the Cookies
subsection of the Privacy Policy. Google Analytics’ privacy policies are available here.
The information generated by the cookie about your use of our website (including your
anonymized IP address) will be transmitted to and stored by Google. Google will use this
information for the purpose of evaluating your use of the website, compiling reports on
website activity for website operators and providing other services relating to website
activity and internet usage. Google may also transfer this information to third parties
where required to do so by law, or where such third parties process the information on
Google’s behalf. Google will not associate your IP address with any other data held by
Google.
Google is also used as an advertising partner, and may use certain Personal Data (such
as email address) for purposes of providing you with targeted advertising.
Stripe, USA
We use Stripe as our payment processing service. Stripe allows Attendees to pay for their
Classes and allows Instructors to receive funds. Vive does not collect or store payment
card numbers and all transactions are processed by Stripe. Information collected by
Stripe, including full payment card information, is governed by rigorous data protection
standards that apply to the payment card industry. For more information on how Stripe
processes your data, please refer to their Privacy Policy.
Intercom R&D Unlimited Company, Ireland
Slack Technologies, Inc., USA
Retention of your personal data
We retain your Personal Data for a period of time consistent with the original purpose of
collection. We determine the appropriate retention period for Personal Data on the basis of the
amount, nature, and sensitivity of your Personal Data, the potential risk of harm from
unauthorized use or disclosure, and whether we can achieve the purposes of the processing
through other means, as well as the applicable legal requirements (such as statutes of
limitation).
After the retention period ends, your Personal Data will be deleted. If there is any information that
we are unable, for technical reasons, to delete entirely from our systems, we will put in place
appropriate measures to prevent any further use of the data.
Device and storage data we process
a. Cookies
We use cookies for the legitimate interests of monitoring and observing your use of our
websites, compiling aggregate data about that use, and providing you with a more
effective service on Vive. "Cookies" are small text files that a website saves on your
computer or device when you visit the site. This small text file enables a site to
remember your actions and preferences for a specified period of time so you don’t have
to re-enter your login or settings information each time you visit a new page on Vive
We don’t use cookies for any purposes other than those described here.
We also include web beacons in the emails we deliver to you. We use the data from those
web beacons to understand the aggregate open rate of emails we send to our users.
b. Types of Cookies Used
We currently use the following cookie types:
Security / Authentication:
Vive uses some necessary cookies which are vital to ensuring that Vive works properly
for visitors and Users, such as maintaining the security, safety and integrity of the
application, authentication and logging in (including remembering permissions and
consents you have granted) and ensuring the ability to securely complete transactions.
Performance / Analytics and Research:
Some technologies help provide performance data on how Vive is functioning in order to
make improvements to it. Data collected on site functionality and speed, how Vive is
used and detecting and gathering reporting on bugs helps improve the application. Some
third-party cookies collect and analyze information about your use of Vive and report on
activities and trends. Our analytics cookies are from Vive, as well as Google Tag
Manager, Google Analytics, and Google Optimize, Google Ads, and Pixels from Facebook.
Preferences / Localization:
Cookies enable your personalized views and settings, and provide localized experiences.
If you have any specific questions on the cookies we are using please do not hesitate to
contact us.
Advertising Cookies:
We use third party advertising cookies to present you with targeted advertising while on
other websites, as well as for retargeting.
c. How to manage cookies
Most internet browsers have an option to allow you to disable cookies altogether –
please refer to your browser’s help menu to find out how to do this. You may always go
to your browser history settings and clear your cookies. You also typically have the ability
to accept or decline cookies by modifying the settings in your browser. If you choose to
disable cookies, you may still use Vive, however you may have limited access to some
areas.
International transfer of information collected
Your Personal Data may be collected, transferred to and stored by us in Australia and by our
affiliates in other countries where we operate. Therefore, if you are an EU data subject, your
Personal Data may be processed outside the EEA, and in countries which are not subject to an
adequacy decision by the European Commission and which may not provide for the same level
of data protection in the EEA. In this event, we will ensure that such a recipient offers an
adequate level of protection, for instance by entering into standard contractual clauses for the
transfer of data as approved by the European Commission.
Your rights relating to your personal data
a. Your data rights
Users in certain locations may have rights, including those under the EU General Data
Protection Regulation 2016/679 (“GDPR”), the Australian Privacy Act (CCPA) or other
analogous legislation in other jurisdictions regarding data that Vive controls as a
Controller under the GDPR, CCPA or similar (“Personal Data”), including:
● To request access to Personal Data that we may process about you (right to
access);
● To require us to correct any inaccuracies in your data, free of charge (right to
rectification);
● To erase/delete your Personal Data to the extent permitted by other legal
obligations (right to erasure; the right to be forgotten);
● To restrict/oppose our processing of your Personal Data (right to a restriction of
processing/right to object);
● To transfer your Personal Data to another controller to the extent possible (right
to data portability);
● Where we process your Personal Data for direct marketing purposes (after
explicit opt-in) or share it with third parties for their direct marketing purposes, to
object at any time to this processing without giving a specific reason, including to
opt out of the sale of Personal Data;
● Not to be subject to a decision based solely on automated processing, including
profiling, which produces legal effects ("Automated Decision-Making"; Automated
Decision-Making currently does not take place on our websites or app);
● To withdraw your consent at any time, without affecting the lawfulness of the
processing based on such consent before its withdrawal.
b. We do not discriminate against Users who exercise their privacy rights.
If you submit a request to exercise your privacy rights, you may be asked to verify the
request by logging into your Vive account. If we are unable to verify your request, then for
your protection, we reserve the right to deny the request.
In certain cases, we may charge you an administration fee for providing you with access
to the information you have asked for, but we will inform you of this before proceeding.
There may be cases where we aren’t able to provide the information you request, such as
where it would interfere with the privacy of others or result in a breach of confidentiality.
In these cases, we will let you know.
Even if you do not request access to and/or correct your Personal Data held by us, we
may take reasonable steps to correct Personal Data that is inaccurate, incomplete, out-
of-date, irrelevant or misleading.
c. How to exercise your rights
To exercise your rights, please contact us in accordance with the “Contact Us” section
below.
If you want to exercise your right to have us stop processing your Personal Data for
direct marketing purposes, you can do this via the Unsubscribe link present in every email
from us, or directly via email, in which case you should put your request in writing (an
email with a header that says 'Unsubscribe'); provide us with enough information to
identify you, and if your objection is not to direct marketing in general, but to direct
marketing by a particular channel, please specify which channel.
Deleting your account
If you no longer want to use Vive Live, and would like to delete your account there are two
options available to you:
1. Delete account via the App - on the ‘MY PROFILE’ section of the app there is an option at
the bottom of the screen called ‘Delete Account’, by clicking this and confirming you
delete your account then your profile will be removed from the Platform and we may
delete all of your Personal Data.
2. Delete account via email - if you are unable to access the app to use the in-app delete
account function then, please reach out to us at accounts@vivelive.ai. Our back office
team will then proceed to delete your account. Once your account is deleted, your profile
will be removed from the Platform and we may delete all of your Personal Data.
Storage and security of personal data
The security of your Personal Data is important to us. We generally store the Personal Data that
we collect in electronic databases, some of which may be held on our behalf by third party data
storage providers. Sometimes we also keep hard copy records of this Personal Data in physical
storage facilities.
Vive’s systems do not access your full credit card number. We use a range of physical and
technical security processes and procedures to protect the confidentiality and security of the
information that we hold, and we update these from time to time to address new and emerging
security threats that you become aware of.
We also take steps to monitor access to and modification of your information by our staff, and
ensure that our staff is aware of and properly trained in their obligations for managing your
privacy.
As a User of the Platform, you can help prevent unauthorized access to your account and
information by choosing a strong and unique password which is stored in a password manager.
Please do not engage in any behavior that endangers the security of our website and Users. This
prohibited behavior includes items described in our Terms as well as the following list, which is
not exhaustive:
● Illegal activities
● Distribution of others’ Personal Data, including Users distributing Personal Data of other
Users
● Spam/Malware
● Service Degradation
● Data Mining
● Reverse Engineering
If you do engage in these behaviors or otherwise endanger the security of the application or Vive
desktop site, or Users, we may terminate your Vive account.
Children
Our websites and Services are not directed at children under 13, and children may not create an
account or otherwise use Vive
Australian residents
Australian residents may be entitled to obtain information about Personal Data. The Australian
Privacy Act covers the Australia Privacy Principles (APP) and allows residents to request access
to the specific pieces and categories of Personal Data that the business has collected about the
consumer, the categories of sources for that information, the business or commercial purposes
for collecting the information, and the categories of third parties with which the information was
shared. Vive provides you the right to access your Personal Data by emailing us at accounts@
vivelive.ai.
Australian residents also have the right to submit a request for deletion of information at
accounts@vivelive.ai.
"DO-NOT-TRACK” TECHNOLOGIES
We do not respond to browser “Do-Not-Track” signals.
Complaints
We try to meet the highest standards in order to protect your privacy. However, if you are
concerned about the way in which we are managing your Personal Data and think we may have
breached any applicable privacy laws or any other relevant obligation, please contact us using
the details set out below.
We will make a record of your complaint, will deal with the matter as soon as we can, and keep
you informed of the progress of our investigation.
If we have not responded to you within a reasonable time or if you feel that your complaint has
not been resolved to your satisfaction, you are entitled to make a complaint to the proper
authorities.
Contacting us
This policy is part of Vive’s Terms . If you need any further information from us on privacy
matters, please contact our privacy compliance team at accounts@vivelive.ai.
Or mail us:
Level 35, Tower One Barangaroo, International Towers Sydney, 100 Barangaroo Avenue, Sydney,
Australia. E-mail: accounts@vivelive.ai
Changes to the policy
We periodically update this Privacy Policy. If we make materially different changes that affect
your rights under this policy, we will notify you via email. Continuing to use the Platform after a
change to this policy means you accept the new policy.
