Privacy Policy

Privacy Policy of Roxom TV Platform
Last updated: February 5, 2026

1. Introduction & Scope

This Privacy Policy explains how Roxom TV Ltd. (“Roxom TV,” “we,” “us”) collects, uses, and shares personal data when you interact with our services.

Scope. This Policy applies to: (i) the roxom.tv website; (ii) our streams; (iii) chyrons (on-screen graphics); (iv) our social channels and newsletters; and (v) events (in-person or virtual) hosted by Roxom TV (together, the “Platform”). It also covers communications you send us (e.g., press or contact forms).

Relationship to other notices. Read this Policy together with our Terms & Conditions and Cookie Notice which describe, respectively, the service rules, cookie/SDK details, and how we label sponsored content.

Third parties and embeds. The Platform may include integrations or links to third-party services (e.g., YouTube, X/Twitter, Instagram, or others). We do not control those parties' privacy practices; your interactions with them are governed by their own policies.

This Policy also applies when the Platform is accessed through an installable browser-based application (progressive web app).

2. Who we are & Contact

Data Controller. Roxom TV Ltd. (“Roxom TV”), Cricket Square, Hutchins Drive, PO Box 2681, George Town, Grand Cayman, KY1-1111, Cayman Islands.

How to contact us about privacy. For questions about this Policy or to exercise your data rights, email us at privacy@roxom.tv. You may also write to us at the postal address above.

Operational notes. We may request identity verification before fulfilling your request. We will handle requests within the time limits required by applicable law. For details on your rights and the process, see Section 7 (Your rights & how to exercise them) [Note: Referred to Section 9 in this document].

3. Data we collect

We collect personal and non-personal data when you use the Platform. The main categories are:

3.1 Data you provide

  • Contact & communications: information you submit via contact, press, or newsletter forms (e.g., name, email address, company, message).
  • Content: you voluntarily provide in connection with events (e.g., RSVP, logistics queries).
  • Account and authentication data: when you create or access a user account (including via Google Sign-In or similar third-party authentication), we may collect identifiers such as name, email address, profile image (if provided), and a unique account ID. We do not receive or store your passwords. Authentication credentials are handled directly by the third-party provider.
  • Newsletter preferences: subscription status and communication preferences selected via forms or account settings.

3.2 Data collected automatically

  • Identifiers & technical: IP address, device/OS type, browser type/version, language, time zone, playback settings.
  • Usage & measurement: page views, referring URLs, access timestamps, interaction events (e.g., clicks), video/stream playback and watch time.
  • Error logs/telemetry: via Sentry, we capture technical information about exceptions and failures (e.g., limited traces, URL/route, client version, timestamp) to diagnose issues.
  • Preference and configuration data: interface settings, viewing modes, language or layout preferences, and similar non-financial configuration choices associated with your account.

3.3 Cookies & similar technologies

We use Google Analytics (implemented via Google Tag Manager) and Sentry. Examples of cookies/SDKs:

  • _ga (Google Analytics) – analytics/measurement.
  • _gid (Google Analytics) – analytics/measurement.
  • _gat (Google Analytics) – request throttling.
  • sentry_sid (Sentry) – error monitoring.

Details (purpose, duration, provider) appear in the Cookie Notice.

3.4 Third-party data/embeds

When you interact with embedded content or links from YouTube, X/Twitter, Instagram, or other platforms, those third parties may collect data under their own privacy policies (e.g., cookies, identifiers, playback/engagement events).

3.5 Aggregated and de-identified data

We may produce aggregated or de-identified statistics (e.g., audience metrics) that do not identify an individual. Where applicable, we may use or share such metrics for analytics and service improvement.

3.6 Sensitive Personal Data

In accordance with the Data Protection Act (2021 Revision) of the Cayman Islands, sensitive personal data, in relation to a data subject, includes personal data consisting of:

  1. racial or ethnic origin;
  2. political opinions;
  3. religious beliefs or other beliefs of a similar nature;
  4. membership of a trade union;
  5. genetic data;
  6. physical or mental health or condition;
  7. medical data;
  8. sex life;
  9. commission, or alleged commission, of an offence; or
  10. any proceedings for any offence committed or alleged to have been committed by the data subject, the disposal of such proceedings, or any sentence of a court in the Islands or elsewhere.

Roxom TV does not knowingly process this type of sensitive personal data. If such information is received in error, we will take steps to securely delete it.

3.7 Sources & storage

Data may come from: (i) you (forms/communications); (ii) your device/browser (automatic); and (iii) third parties (embedded platforms/providers). We store and process data, among others, on AWS (US-East) and with the vendors listed in this Policy and in the Cookie Notice.

4. Data Protection Principles

In accordance with the Data Protection Act (2021 Revision) of the Cayman Islands, the processing of personal data carried out by Roxom TV is governed by the following core principles:

  • 4.1. Fair and lawful processing: data is processed transparently and in compliance with the Law.
  • 4.2. Purpose limitation: data is obtained only for specified and legitimate purposes and not used in ways that are incompatible with those purposes.
  • 4.3. Data minimisation: data must be adequate, relevant, and not excessive in relation to the purpose for which it is collected.
  • 4.4. Accuracy: data must be accurate and kept up to date.
  • 4.5. Storage limitation: data is not retained longer than necessary for the purpose for which it was collected.
  • 4.6. Respect for rights: data is processed in line with the rights granted to individuals under this Law.
  • 4.7. Security: appropriate technical and organisational measures are applied to prevent unauthorised access, loss, or damage.
  • 4.8. International transfers: data is transferred only to countries or territories that ensure an adequate level of protection.

The detailed implementation and execution of each of these principles are addressed in the specific sections of this Policy.

5. Purposes & legal bases

We process personal data only for the purposes set out below. For each purpose we specify the applicable legal basis under Cayman data-protection law and other applicable laws, such as GDPR.

5.1 Operating the Platform.

We use data to provide and maintain the roxom.tv website, our streams and chyrons, route traffic, balance load, and manage technical configuration (including Google Tag Manager).

Legal basis: legitimate interests (to provide a stable and useful service).

5.2 Measurement and analytics.

We use Google Analytics (via GTM) to gather aggregate metrics about Platform usage (e.g., page views, plays, watch time) to improve experience and performance.

Legal basis: legitimate interests. Where prior consent is required for analytics cookies/SDKs, the basis will be consent, and we will apply your preferences (see Cookie Notice).

5.3 Error monitoring and diagnostics.

We rely on Sentry to capture minimal technical telemetry about exceptions and failures to detect, investigate, and fix issues.

Legal basis: legitimate interests (service quality and reliability).

5.4 Account Features.

We process personal data to enable account creation, login, authentication, and account-level features (such as preferences and subscriptions).

Legal basis: legitimate interests (to provide requested functionality) and, where applicable, performance of a contract (user request to access account features).

5.5 Advertising and monetization (if applicable).

If we enable advertising cookies/SDKs or campaign measurement, we process data to serve/measure ads or sponsored content.

Legal basis: consent where required by law. Details and controls are provided in the Cookie Notice.

5.6 Legal compliance, security, and abuse prevention.

We may process data to comply with legal requests, enforce our Terms, and prevent fraud/abuse or unlawful use.

Legal basis: legal obligation and/or legitimate interests.

5.7 Claims handling and defense.

We retain and use necessary information to manage, defend, or assert claims and rights in administrative or judicial proceedings.

Legal basis: legitimate interests and/or legal obligation.

The processing of account or preference data does not result in personalized financial content, recommendations, or advice.

6. Sharing (recipient categories)

We may share personal data with the following recipient categories strictly for the purposes described in this Policy and in accordance with applicable law. Where we engage vendors that process data on Roxom TV's behalf, we require contracts, confidentiality, purpose limitation, and deletion upon service termination.

6.1 Processors (service providers acting on our behalf).

This includes, without limitation: hosting/CDN/infrastructure (e.g., AWS – US-East), analytics (Google Analytics - some regulators may identify its operation as that of a “Joint Controller”.), tag management (Google Tag Manager), error monitoring (Sentry), support and communications tools (e.g., email/CRM if applicable), authentication and identity providers (e.g., Google Sign-In), solely to enable secure login and account access, and professional advisers. These vendors process data under our instructions.

6.2 External platforms and partners.

When we embed or distribute content through third parties (e.g., YouTube, X/Twitter, Instagram or other distributors), such third parties may collect data directly from your browser/device under their own privacy policies. Your interactions with those platforms are governed by their terms.

6.3 Affiliates and corporate transactions.

We may share personal data with other entities within the Roxom TV group, strictly for internal operational purposes that are consistent with this Policy. Depending on the context, such entities may act either as independent data controllers or as data processors on our behalf.

In the event of a merger, acquisition, financing, sale of assets, or corporate reorganization, we may disclose limited personal data as necessary for due diligence or transaction execution. Any such disclosure will be subject to confidentiality obligations and appropriate safeguards, and the recipient will be required to use the information solely for the relevant transaction. Where such recipients are located outside the Cayman Islands, we will ensure that the transfer complies with the Data Protection Act (2021 Revision), including the application of adequacy assessments, standard contractual clauses, or other legally recognized mechanisms.

6.4 Legal compliance and protection.

We may disclose information to authorities or other third parties where we believe in good faith it is necessary to: (i) comply with law, lawful processes, or requests; (ii) enforce our Terms and other agreements; (iii) protect the rights, safety, or property of Roxom TV, users, or the public; or (iv) prevent fraud or abuse.

6.5 Advertising and measurement (if enabled).

If we implement advertising technologies or campaign measurement, we may work with networks, ad-tech, or monetization partners that use cookies/SDKs. In such case, their use will be described in the Cookie Notice.

6.6 Aggregated or de-identified information.

We may share aggregated statistics or de-identified information that does not identify an individual (e.g., audience or performance metrics).

6.7 No sale of personal data.

We do not sell your personal data and do not operate as a data broker. Any transfers occur pursuant to this section and, where applicable, Section 7 (International transfers).

7. International transfers

We may transfer, store, and process personal data outside your country of residence. In particular, we use AWS (US-East) for infrastructure/hosting and work with providers such as Google (Analytics/Tag Manager) and Sentry (error monitoring) that may process data in the United States or other jurisdictions.

Where applicable, we implement recognized transfer mechanisms (e.g., EU Standard Contractual Clauses (SCCs), UK IDTA, and/or equivalent frameworks) and require appropriate contractual data-protection commitments from our vendors.

In accordance with the Eighth Principle set out in Schedule 1 of the Data Protection Act (2021 Revision) of the Cayman Islands, Roxom TV will not transfer personal data to any country or territory that does not ensure an adequate level of protection for the rights and freedoms of data subjects with respect to the processing of their personal data.

Where the destination country does not provide such level of protection, Roxom TV will only carry out transfers when:

  • the data subject has provided explicit consent;
  • the transfer is necessary for the performance of a contract with the data subject or for pre-contractual measures at the data subject's request;
  • the transfer is necessary for reasons of public interest, legal claims, or the protection of rights; or
  • appropriate contractual safeguards are applied, such as internationally recognized Standard Contractual Clauses or other legally valid mechanisms.

All transfers will be carried out under confidentiality and security obligations, and are subject to the oversight of the Ombudsman of the Cayman Islands, the competent authority for data protection matters.

8. Retention

8.1 Data Retention

In accordance with the Fifth Principle of the Data Protection Act (2021 Revision) of the Cayman Islands, Roxom TV will not retain personal data for longer than is necessary to fulfill the purpose for which it was collected or processed.

Retention periods are determined based on:

  1. compliance with legal or regulatory obligations (e.g., retention of tax or accounting records);
  2. the duration of contractual relationships or requested services;
  3. statutory limitation periods for potential legal or contractual claims; and
  4. the need to maintain records for security, fraud prevention, or compliance purposes.

Once the relevant purpose has been fulfilled or the applicable legal periods have expired, personal data will be deleted, anonymised, or securely archived, unless a legal obligation requires extended retention.

8.2 Children's Data

Our services are not directed to individuals under 18 years of age. Roxom TV does not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child without appropriate consent, we will delete such information immediately.

9. Your rights & how to exercise them

Subject to applicable law (including the Cayman DPA), you have the right to:

  1. Access: obtain confirmation and a copy of your data (indicative response: 30 days).
  2. Rectification: correct inaccurate or incomplete data.
  3. Erasure (Cancellation/Deletion): request that we delete your data where applicable (e.g., no longer needed for stated purposes).
  4. Portability: receive the data you provided in a structured, commonly used, machine-readable format and transmit it to another controller; where feasible, request direct transfer.
  5. Objection / stop processing: object to processing based on legitimate interests (including direct marketing). We will stop processing within legal timelines (21 days, unless we have compelling grounds).
  6. Withdraw consent: where processing relies on consent, you may withdraw it at any time (without affecting prior lawful processing).
  7. No direct marketing: you can opt out of newsletters/promotional emails at any time.

How to exercise:

Email privacy@roxom.tv specifying the right and providing enough information for ID verification. We'll respond within statutory timelines (e.g., 30 days for access; 21 days for stop-processing). If a request is manifestly unfounded or repetitive, we may charge a reasonable fee or decline it as permitted.

10. Information Security

In accordance with the Seventh Principle of the Data Protection Act (2021 Revision) of the Cayman Islands, Roxom TV shall adopt and maintain appropriate technical and organisational measures to protect personal data against:

  • unauthorised or unlawful processing, and
  • accidental loss, destruction, or damage.

Such measures include, among others, the use of access controls, encryption, periodic security audits, restricted access to authorised personnel only, and regular staff training on data protection.

11. Personal Data Breach Notification

In accordance with Section 16 of the Data Protection Act (2021 Revision) of the Cayman Islands, Roxom TV shall notify, without undue delay and no later than five (5) days after becoming aware, with the exercise of reasonable diligence, of a personal data breach, both the affected data subject(s) and the Ombudsman.

The notification shall include, at a minimum:

  1. the nature of the breach;
  2. the consequences of the breach;
  3. the measures proposed or taken by Roxom TV to address the breach; and
  4. the measures recommended to the affected data subject(s) to mitigate any possible adverse effects.

12. Changes to this Policy

Roxom TV may modify or update this Privacy Policy on a regular basis to reflect legal, regulatory, technical, or operational changes. We encourage users to review this Policy periodically to remain informed about how we protect their personal data. Changes will take effect from the date of publication on this site, unless otherwise expressly stated.

13. Contact

If you have questions or wish to exercise your rights, contact privacy@roxom.tv or write to:

Roxom TV Ltd., Cricket Square, Hutchins Drive, PO Box 2681, George Town, Grand Cayman, KY1-1111, Cayman Islands.