Privacy Policy

• Controller. Febeleven Pty Ltd is the entity responsible for personal information handled through the Service (the “controller” under the GDPR). Contact details are in section 15.
• Customers and their users. This policy covers the people who create and use a Paveo TV account on behalf of a business, and visitors to paveotv.com.
• People on your screens. If your content includes personal information about other people (for example a photo of a staff member, a roster, a booking board), you are the controller of that information and we process it only as your processor to display it on your screens. Your obligations are in section 9 of the Terms of Service.
• The Australian hardware business. Paveo's outdoor A-frame service at paveo.com.au has its own portal and its own privacy notice. This policy applies to Paveo TV only.

Information you give us

• Account details: business name, your name, email address, country, and a password, which we store only as a one-way hash. Optional: two-step verification secret, phone number if you give it, additional user logins you create for staff.
• Billing details: the subscription you hold, the number of screens billed, invoices and payment status. Your card number is entered on our payment processor's (Stripe) secure page and is collected and stored by Stripe, not by us; we receive a token, the card brand and its last four digits.
• Content: the pictures, videos, text and web page addresses you upload or create, the programs and schedules you build, screen names and locations you type in, and any corrections you make to a screen's measured size.
• AI offers inputs: the descriptions, options and any reference photo you provide to generate a picture, and the pictures produced.
• Communications: emails, contact form messages, support requests and feedback you send us, and our replies.

Information each screen reports about itself

• When the Paveo TV app runs it sends us technical facts about the device so that we can fit content to it and show you whether it is working: screen size in pixels, orientation, pixel density, refresh rate, HDR support, an estimate of the diagonal size, the device manufacturer and model, the platform (Android TV, Google TV or Fire OS), the app version, free storage, the device's time zone, its local network IP address, the public IP address it connects from, when it last connected, and which program it is playing.
• The app does not use the device's camera or microphone, does not collect location data, does not read other apps, files or accounts on the device, and does not use advertising identifiers. It can take a screenshot of what it is itself displaying when you ask it to from the portal; that screenshot shows only your content and is kept for a few minutes.
• Each screen holds a unique secret issued at activation, used only to authenticate it to our servers. It is not a device identifier and is revoked when you remove the screen.

Information collected automatically

• Portal and website usage: pages visited, actions taken in the portal (for example, a program sent to a screen, a user added), browser type, operating system, screen resolution, language, referring page, IP address and timestamps, from standard server logs.
• Cookies and browser storage: see section 10.
• Email interaction: whether a service email was delivered or bounced, from our email delivery provider.

Information from others

• Payment status, failed-payment notices and invoice records from Stripe; app installation and crash statistics from Google Play and the Amazon Appstore in aggregate form; fraud and abuse signals from our hosting and email providers.

We do not knowingly collect sensitive information (such as health, religion, political opinions or biometric data) and ask you not to put it into the Service.

We use personal information for the following purposes. Where the GDPR or UK GDPR applies, the legal basis for each is shown.

• To provide the Service (performance of a contract): create and secure your account, activate screens, deliver your content to them, fit it to each screen, run schedules, generate pictures when you ask, send service emails such as sign-up confirmation, password reset, trial and payment notices, and answer support requests.
• To bill you (performance of a contract, legal obligation): manage your subscription, process payments through Stripe, issue invoices and keep tax records.
• To keep the Service safe (legitimate interests in security and preventing abuse): authenticate users and screens, detect and block fraud, credential stuffing, spam, activation-code guessing and misuse, enforce rate limits, keep audit logs, and investigate incidents.
• To run and improve the Service (legitimate interests in operating our business): monitor performance and errors, understand which features and device types are used, fix bugs, plan capacity and develop new features. Where practical we use aggregated or de-identified data for this.
• To communicate with you about the Service (performance of a contract, legitimate interests): important changes to features, prices or terms, security notices and scheduled maintenance. These are service messages, not marketing, and you cannot opt out of them while you hold an account.
• Marketing (consent, or legitimate interests where the law allows it for existing customers): we may send occasional news about Paveo TV to customers. Every marketing email has an unsubscribe link, and we never sell or rent your details for third-party marketing.
• To comply with the law (legal obligation): respond to lawful requests from authorities, keep records required by tax, company and consumer law, and handle complaints.
• To establish, exercise or defend legal claims (legitimate interests).

We do not use personal information for automated decisions that have legal or similarly significant effects on you. We do not use your content, your AI inputs or your generated pictures to train artificial intelligence models, and we require our AI provider not to do so either.

• When you use AI offers, your description, options and any reference photo are sent to a third-party artificial intelligence provider that acts as our processor under a written contract. The provider uses them only to produce your picture and must not use them to train its models or for any other purpose. We do not name the provider publicly and may change it.
• Do not include personal information about other people in a description, and only upload a reference photo of a person with their consent. A picture of a person made from a reference photo is personal information about that person; you are responsible for having the right to make and display it.
• Generated pictures are stored in your media library until you delete them, subject to section 8.

We share personal information only as described here. We never sell personal information and never share it with third parties for their own marketing.

• Service providers (processors) who handle information on our behalf under contracts that restrict them to our instructions and require appropriate security: cloud hosting and object storage for our servers, database and your content; a content delivery network that serves your pictures and videos to your screens; Stripe for payments and invoicing; an email delivery provider for service emails; an artificial intelligence provider for AI offers; and error monitoring and analytics tools that process technical data. A current list of providers and their locations is available on request from privacy@paveotv.com.
• App stores and device platforms. Google and Amazon receive installation and crash data under their own privacy policies when you install the app from their stores. We receive only aggregate statistics.
• Your own organisation. Other users of your account can see the account's screens, content, programs and billing status according to their role.
• Professional advisers such as lawyers, accountants and insurers, bound by confidentiality, where needed.
• Authorities and legal process. Where required by law, court order, subpoena or a lawful request from a regulator or law enforcement, or where we believe in good faith that disclosure is necessary to protect our rights, your safety or the safety of others, to investigate fraud or abuse, or to enforce our Terms.
• Business transfers. If we sell or transfer all or part of our business, or merge, personal information may be transferred to the buyer or successor, who must honour this policy. We will notify you.
• With your consent or at your direction, for anything else.

Paveo is based in Australia. Some of our providers process information outside Australia, including in the United States and, depending on the provider, the European Union, the United Kingdom and other countries. Where we transfer personal information across borders we take steps to ensure it remains protected, including:

• using providers that are subject to privacy laws substantially similar to Australia's, or that are certified under recognised frameworks;
• for information about people in the EEA or UK, relying on adequacy decisions or on standard contractual clauses approved by the European Commission or the UK Information Commissioner, with supplementary measures where needed;
• contractual obligations of confidentiality, security and limited use.

By using the Service you acknowledge that your information may be transferred to and stored in these countries. You can ask us for a copy of the safeguards that apply to a transfer.

Our application servers, database and backups are hosted by DigitalOcean in Sydney, Australia. Your content is stored in DigitalOcean object storage in Sydney and served through its content delivery network, which has edge locations around the world so that screens anywhere load it quickly. Payment information is held by Stripe in its own systems. Service emails are sent through Amazon Web Services.

• Account and content data: for as long as your account is open. When you close your account, or 30 days after your subscription ends without reactivation, we delete your content and account data within 30 days, except as noted below. Content you delete yourself is removed from active systems immediately and from backups within 35 days.
• Screen data: deleted when the screen is removed from your account. The screen's secret is revoked immediately.
• Billing records: kept for 7 years after the transaction, as Australian tax and corporations law require, in a form that identifies the business and the person who paid.
• Support correspondence: up to 3 years after the matter is closed, so that we can handle follow-ups and complaints.
• Technical and security logs: up to 90 days, or longer for logs that form part of a security investigation or legal matter.
• Backups: encrypted backups are kept for up to 35 days on a rolling basis; deleted data may remain in a backup until it expires and is not restored except to recover from a system failure.
• Marketing preferences: we keep a record that you unsubscribed for as long as needed to honour it.

• All connections between your browser, your screens and our servers use encryption in transit (HTTPS and TLS). Content at rest is stored with reputable providers that encrypt their storage.
• Passwords are hashed with a strong, slow algorithm and are never stored or sent in clear text. Password resets and email confirmations use single-use, time-limited links. Two-step verification is available to every user.
• Each screen authenticates with its own unique secret, which is revoked when the screen is removed. Our message broker requires every connection to be authenticated and allows each screen to receive messages for itself only.
• Access to production systems is restricted to staff who need it, protected by strong authentication, and logged. Third-party API keys are encrypted at rest.
• We apply rate limits and monitoring to detect credential stuffing, activation-code guessing and other abuse, keep our software up to date, and review our security regularly.
• No method of transmission or storage is completely secure. If we become aware of a data breach that is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner (and any other regulator whose rules apply) as required by law, and tell you what we are doing about it.

The Service uses only what it needs to work:

• Sign-in storage (essential): after you sign in, the portal keeps a short-lived access token, a refresh token and your user profile in your browser's local storage so you stay signed in. They are removed when you sign out. No third party can read them.
• Preferences (essential): small items such as a draft form or a pending screen activation that is resumed after payment, kept in session storage and cleared when used.
• Payment pages: Stripe's checkout and billing pages set their own cookies under Stripe's privacy policy.

We do not use advertising cookies, cross-site tracking or social media pixels. If we add analytics that use cookies in future, we will update this policy and, where the law requires, ask for your consent first. You can clear or block browser storage in your browser settings; the portal will not work without the essential items.

You can manage most of your information yourself in the portal: update your details and password under Settings, add or remove screens, delete content, change or cancel your subscription under Billing, and close your account. In addition, you have the following rights, subject to the law that applies to you:

• Access: ask for a copy of the personal information we hold about you and how we use it.
• Correction: ask us to correct information that is inaccurate, out of date or incomplete.
• Deletion: ask us to delete your personal information. We will do so unless we need to keep it for a reason set out in section 8 or the law.
• Portability: receive the information you gave us in a structured, commonly used, machine-readable format, and your content as the files you uploaded.
• Objection and restriction: object to processing based on our legitimate interests, or ask us to restrict it, where the GDPR or UK GDPR applies. We will stop unless we have compelling legitimate grounds.
• Withdraw consent: where we rely on consent, withdraw it at any time; this does not affect processing before withdrawal.
• Marketing: unsubscribe from marketing email using the link in any such email or by contacting us.
• Anonymity: you may browse paveotv.com without identifying yourself; an account necessarily requires your details.

To exercise a right, email privacy@paveotv.com from the address on your account, or write to us at the address in section 15. We may need to verify your identity. We respond within 30 days (or sooner where the law requires) and do not charge a fee unless a request is manifestly unfounded or excessive. If we refuse a request we will explain why and how you can complain.

The Service is for businesses and is not directed at children. We do not knowingly collect personal information from anyone under 16 (or under the age at which a person can consent to data processing in their country). If you believe a child has given us personal information, contact us and we will delete it.

paveotv.com links to other sites, and the Service lets you display third-party web pages on your screens. Those sites have their own privacy practices, which we do not control and are not responsible for. When a screen loads a web page you have added, that site may receive the screen's IP address and other technical information directly, in the same way as any browser visiting it.

If you are concerned about how we have handled your personal information, contact us first at privacy@paveotv.com and we will investigate and respond within 30 days. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (oaic.gov.au, 1300 363 992). If you are in the European Economic Area or the United Kingdom you may also complain to your local data protection authority or to the UK Information Commissioner's Office. We would appreciate the chance to resolve your concern before you do.

We may update this policy from time to time. We will post the new version at paveotv.com/privacy with its effective date and, for changes that materially affect how we use your personal information, notify you by email or in the portal before they take effect.

Privacy questions and requests: privacy@paveotv.com
General support: support@paveotv.com
Post: Privacy Officer, Febeleven Pty Ltd (ABN 69 661 429 956), trading as Paveo, 15 Cochranes Road, Moorabbin VIC 3189, Australia