STUDIO PRIVACY POLICY

Effective October 7, 2015:

Table of Contents:

  1. INTRODUCTION

1620 Media, LLC (“Studio” or “we”), which operates the 1620media.com website, has developed this Privacy Policy to describe how we collect, use and disclose information from and about you. This Privacy Policy describes our practices in connection with information collected through services such as websites, mobile sites, applications (“apps”), widgets, and other content and services that are linked or otherwise refer to or provide the URL to this Privacy Policy (collectively, the “Studio Services”).  By providing personal information to us and/or using the Studio Services, you agree to the terms and conditions of this Privacy Policy.

As set forth in our Terms of Use, the Studio Services are for a general audience, are not targeted to children, and do not knowingly collect personal information from children under 13 years of age.

This Privacy Policy applies to all users, including both those who use some of the Studio Services without being registered with or subscribing to a Studio Service and those who have registered with or subscribed to a Studio Service. This Privacy Policy applies to Studio’s collection and use of your personal information (i.e., information that identifies a specific person, such as full name or email address). It also describes generally our practices for handling non-personal information (for example, interests, demographics and services usage).

  1. INFORMATION COLLECTION

Studio and our service providers collect the following information from and about you:

Registration Information is the information you submit to register for a Studio Service, for example, to create an account, post comments, receive a newsletter, or enter a contest or sweepstakes. Registration Information may include, for example, name, email address and gender.

Public Information and posts consist of comments or content that you post to the Studio Services and the information about you that accompanies those posts or content, which may include a name, user name, comments, likes, status, profile information and picture. Public Information and Posts are always public, which means they are available to everyone and may be displayed in search results on external search engines.

Social Media Information and Content. If you access or log-in to a Studio Service through a third party social media service or another website, app, service or log-in (“Other Service”), or connect a Studio Service to another service, the information we collect may also include your user ID and/or user name associated with that Other Service, any information or content you have permitted the Other Service to share with us, such as your profile picture, email address or friends’ lists, and any information you have made public in connection with that Other Service (collectively, “Social Media Information and Content”). When you access the Studio Services through Other Services, or when you connect a Studio Service to Other Services, you are authorizing us to collect, store, and use any and all Social Media Information and Content in accordance with this Privacy Policy.

Authenticated Content Access.  To access certain video content via the Studio Services, you may be redirected to your television content provider’s registration page where you will be required to sign in using your television content provider account.  Please contact your television content provider directly with questions concerning your account, including how to access, update and manage your personal account information.

Activity Information. When you access and interact with the Studio Services, Studio and our service providers may collect certain information about those visits.  For example, in order to permit your connection to the Studio Services, our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, authentication identifiers, and other software or hardware information.  If you access the Studio Services from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data (including your precise location), or other transactional information for that device in order to provide the Studio Services to it.

Cookies and other tracking technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology including cookies), which are comprised of small bits of data that often include a de-identified or anonymous unique identifier may also be used. Websites, apps and other services send this data to your browser when you first request a web page and then store the data on your computer or other device so the website, app or other service may be able to access information when you make subsequent requests for pages from that website, app or other service. These technologies may also be used to collect and store information about your usage of the Studio Services, such as pages you have visited, the videos and other content you have viewed, search queries you have run and advertisements you have seen. Cookies may also be used by us or by our service providers to collect and store information on your use of other companies’ websites or services, such as sites you visit and materials you view.  We may merge this with other data we collect about you from third parties to assist us in our ability to provide the Services, including, without limitation, to advertise and provide content to you.  Our work in this respect is compliant with the Digital Advertising Alliance’s Principles for the Self-Regulation of Online Behavioral Advertising.  To learn more, visit www.aboutads.info/choices.

Third parties that support the Studio Services by serving advertisements or providing services, such as allowing you to share content or tracking aggregate Studio Services usage statistics, may also use these technologies to collect similar information when you use the Studio Services or third party service. Studio does not control any of these third party technologies and their use is governed by the privacy policies of the third parties using such technologies. For more information about third-party advertising networks and similar entities that use these technologies, including your choices with respect to them, see the section entitled “To deliver relevant advertisements,” below.

Most browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies). Users can manage the use of Flash technologies, with the Flash management tools available at Adobe’s website, see http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. Please note that by blocking any or all cookies you may not have access to certain features, content or personalization available through the Studio Services.

Information from Other Sources. To improve the quality of the Studio Services, Studio and our service providers may supplement the information we collect with information from other sources, such as publicly available information from social media services, commercially available sources and information from our other business partners.

Do Not Track Signals. At this time we do not respond to browser ‘Do Not Track’ signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted.

  1. USE AND DISCLOSURE

We use the personal information and other information we collect from and about you for the following purposes:

To provide and manage the Studio Service.

Studio and our service providers use the information we collect from and about you to provide the Studio Services to you, including to measure and improve those Studio Services and features; to improve and personalize your experience by delivering content you will find relevant and interesting, including advertising and marketing messages; to allow you to comment on content, and participate in online games, contests, or rewards programs; to provide you with customer support and to respond to inquiries.  In order to provide you with content and advertising that is more interesting and relevant to you, we may use the information from and about you to make inferences and predictions about your potential areas of interest.  We may also use aggregated or anonymous data about your use of and activity on the Studio Services to assist us in this regard.

To allow service providers to assist us in providing and managing the Studio Services.

Studio may elect to make the information we collect from and about you available to certain third party service providers, such as agents or sponsors, who help us analyze and understand your use of the our services, and manage and/or provide the Studio Services.

To deliver video content.  In the ordinary course of our business, we may share information that we collect from or about you with third parties in order to process your requests and fulfill your orders for video content offered through the Studio Services, including, to provide you with video content recommendations.

To allow social sharing functionality. If available and if you log in with or connect your social media service account with Studio Services, we will share your social media information, including your user name, picture, and likes, as well as your activities and comments with other Studio Services’ users and with your friends associated with your social media account service. We will also share the same information with your social media account service provider. By logging in with or connecting your Studio Services account with a social media service, you are authorizing us to share information we collect from and about you with the social media service provider, other users and your friends and you understand that the social media service’s use of the shared information will be governed by the social media service’s privacy policy. If you do not want your personal information shared in this way, please do not connect your social media service account with your Studio Services account and do not participate in social sharing on the Studio Services.

To provide co-branded services and features. We may offer co-branded services or other features, such as contests, sweepstakes or other promotions with a third party (“Co-Branded Services”). These Co-Branded Services may be hosted on Studio Services or on the third party’s services. By virtue of these relationships, we may share the information you submit in connection with the Co-Branded Service with the third party. The third party’s use of your information will be governed by the third party’s privacy policy.

To deliver relevant advertisements. We and our service providers may use the information we collect from or about you, and information that our service providers collect from your use of other websites and services through cookies and other technologies, to assist us in delivering relevant ads to you when using Studio Services or other services. As noted above, third party advertising networks and advertisers may use cookies and similar technologies to collect and track information such as demographic information, aggregated information, and your activity to assist them in delivering advertising that appears more relevant to your interests. To find out more about third-party advertising networks and similar entities that use these technologies, see www.aboutads.info.

To contact you. Studio may periodically send promotional materials (e.g., newsletters or email updates) or notifications related to the Studio Services to the email address you provided to us at registration or for your account. If you want to stop receiving promotional materials from us, follow the unsubscribe instructions at the bottom of each email.  There are certain service notification emails that you may not opt-out of, such as notifications of changes to our policies.

To share with business partners. We may share your information with business partners to permit them to send you marketing communications consistent with your choices.

To protect the rights of us and others. There may be instances when we may use or disclose your information without providing notice or choice, including situations where we have a good faith belief that such use or disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of Studio, our employees, agents and contractors (including enforcement of our agreements and our Terms of Use); (ii) protect the safety, privacy, and security of users of the Studio Services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process; or (v) respond to requests from public and government authorities.

To complete a merger or sale of assets. If we sell all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business (including, without limitation, in connection with bankruptcy or a similar proceeding), Studio may transfer your information to the party or parties involved in the transaction as part of that transaction.

When the information collected from or about you does not identify you as a specific person, we may use that information for any purpose or share it with third parties.

  1. SECURITY

Studio uses commercially reasonable administrative, technical, personnel and physical measures to safeguard information in its possession against loss, theft and unauthorized use, disclosure or modification. However, no one can guarantee the complete safety of your information.

  1. USER ACCESS AND CONTROL

If you would like to access, review, correct, update, suppress, or otherwise limit our use of your personal information you have previously provided directly to Studio – contact us by email at legal@1620media.com. We will try to comply with your request as soon as reasonably practicable.

If you are an eligible registered user of a Studio Service and under 18, you may ask us to remove content or information that you have posted to our service by emailing us at legal@1620media.com. We will try to comply with your request(s) as soon as reasonably practicable.  Please note that your request does not ensure complete or comprehensive removal of your content or information, as, for example, some of your content may have been reposted by another user.

If you are a California resident, you may request that we not share your personal information on a going-forward basis with unaffiliated third parties for their direct marketing purposes by sending us an email to legal@1620media.com We will try to comply with your request(s) as soon as reasonably practicable.

  1. Data Retention.

We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by applicable law.

Remember that even after you cancel your account, copies of some information from your account may remain viewable in some circumstances where, for example, you have shared information with social media or Other Services. Because of the nature of certain technology, your account may not be instantly inaccessible to others and there may be a delay in the removal of the content from elsewhere on the Internet and from search engines. We may also retain backup information related to your account on our servers for some time after cancelation for fraud detection or to comply with applicable law or our internal security policies. It is not always possible to completely remove or delete all of your information due to technical constraints, contractual, financial or legal requirements.

  1. OTHER IMPORTANT INFORMATION

Means of Notice and Choice. This Privacy Policy and your account settings are the primary means by which we provide you with notice and choice regarding its collection and use of your personal information.

Updates to Privacy Policy. We may modify this Privacy Policy. Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when the revised Privacy Policy is posted.

Location of Data. The Studio Services are hosted in and managed from the United States. If you are a user located outside the United States, you understand and consent to having any personal information transferred to and processed in the United States. United States data protection and other relevant laws may not be the same as those in your jurisdiction. This includes the use of cookies and other tracking technologies as described above. As a result, please read this Privacy Policy with care.

Linked Services. The Studio Services may also be linked to sites operated by unaffiliated companies, and may carry advertisements or offer content, functionality, games, newsletters, contests or sweepstakes, or applications developed and maintained by unaffiliated companies. We are not responsible for the privacy practices of unaffiliated companies, and once you leave the Studio Services via a link, enable an unaffiliated service or click an advertisement you should check the applicable privacy policy of the unaffiliated service.

In addition, Studio is not responsible for the privacy or data security practices of other organizations, such as Facebook, Tumblr, Twitter, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including in connection with any information you disclose to other organizations through or in connection with the Studio Services.

Collection of Personal Financial Information by a Payment Service. In some cases, we may use an unaffiliated payment service to allow you to purchase a product or make payments (“Payment Service”). If you wish to purchase a product or make a payment using a Payment Service, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service’s privacy policy, rather than Studio’s Privacy Policy. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service.

Sensitive Information. We ask that you not send us, and you not disclose, any sensitive personal information (such as social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Studio Services or otherwise.

  1. CONTACT US

If you have questions about this Privacy Policy please contact us by email at legal@1620media.com or contact us by mail at:

1620 Media, LLC

Legal Affairs

12020 Chandler Blvd. – 2nd Floor

North Hollywood, CA 900679