EFFECTIVE DATE: 2/7/2024

Subscription Video Track (“SVT,” “Company,” “we” or “us”) is provided to you by Circana, LLC. Circana has been conducting market research for over 50 years. Circana’s clients encompass over 2,000 businesses, including many Fortune 500 companies. SVT is a consumer research platform of Circana that gathers the content viewing information of consumers located in the United States. 

In addition to being a committed leader in market research, we are committed to protecting the privacy and security of your information. This Company Privacy Policy (“Policy”) describes how the Company collects, uses, discloses and otherwise processes the personal information described in this Policy, as well as the rights and choices individuals have regarding such personal information. 

For information about the privacy choices you have regarding your personal information, review Section 7. Your Privacy Choices below, as well as Section 12. Additional Privacy Information for Certain Jurisdictions, which includes additional information about privacy rights for residents of certain states. If you are a resident of California, please also refer to Section 12.B Additional Privacy Information for California Residents below for information about the categories of personal information we collect and your rights under California privacy laws. 

Your use of our Services (defined below), and any dispute over privacy, is subject to this Policy and our Terms of Service, available here.

1.    Scope
Except as otherwise noted below, this Policy applies to the personal information that SVT processes related to:   
●    users of our website where this Policy is posted, including https://www.svodvoice.com/privacy, and the services we provide through the website (collectively, the “Services”). Our Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
●    current, former and prospective customers 
●    individuals who are subscribed to receive news, information and marketing communications from us related to the Services; 
●    individuals who participate in contests, sweepstakes, surveys and research conducted by us 
●    related to the Services; and
●    individuals that communicate with us or otherwise engage with us related to our Services.

Not In Scope. This Policy does not apply to the personal information that we collect and process outside of the Services, about Company employees and personnel, or about job applicants and candidates. Additionally, this Policy does not apply to vendors and partners of Company; however, vendors and partners can view information regarding the collection and use of their personal information in Circana’s privacy policy here.

Additional Notices. In some cases, additional or supplemental privacy notices (each an “additional notice”) may be provided and will apply to certain personal information collected and processed by us. For example, we may provide an additional notice in order to provide more specific information about how we use and disclose personal information if you choose to take advantage of a particular partner promotion. The additional notice will control to the extent there is a conflict with this Policy, with respect to your personal information that is subject to that notice.

 
2.    Personal Information Collected 
As further described below, we collect personal information directly from individuals, from third parties, and automatically when such data relates to the use of our Services or other interactions with us.

Personal Information Collected Directly. The personal information we collect from you depends upon how you use our Services or otherwise interact or engage with us, but generally includes: 

●    Registration and account information. When you register for an account with us, we collect certain personal information from you, such as your age, gender, zip code, race, ethnicity, household size, household income range and age of children in household and certain viewing information, such as the viewing services to which you subscribe (e.g., streaming services, cable, satellite, etc.), any premium channels to which you subscribe, and your movie-going and DVD-buying frequency. Based on this information, we will determine if you are eligible to become a Subscription Video Track panelist. If so, we will ask you whether you will provide us with your streaming services username and password. If not, you will not be eligible to become a Subscription Video Track panelist, we will not collect any additional information from you other than what we have already collected, and the information we automatically collect via our Website.

●    Viewing Account Information. After you have provided the Subscription Video Track Panelist Eligibility Information, we will ask you to identify the platform(s) you use to view streamed video content (the "Viewing Account") and provide information concerning your Viewing Account(s), including but not limited to the steaming service access credentials ("Viewing Account Information"), which we will use to automatically collect information directly from your Viewing Account ("Viewing Information"). "Viewing Information" includes account and profile ID number (and whether the profile ID is tagged as belonging to a child), titles and episodes viewed including names, dates, times and how much content was viewed, whether the streaming account is ad supported or includes additional channels, viewer Internet Protocol (IP) address, and the date you subscribed to the service. We will continue to collect your Viewing Information, including your current and historical View Information until you tell us you no longer want us to do so, which you may do at any time (see How To Opt Out). Please note that we may use a service provider to collect the Viewing Information on our behalf.

●    Surveys. You may choose to participate in optional surveys, and we will collect your responses for market research. Survey questions may ask about things such as purchases you have made and your opinions about products or services.  

●    Communications and interactions. When you email, call, or otherwise communicate with us and with members of our team, we collect and maintain a record of your contact details, communications and our responses. We also maintain records regarding information you provide to us related to any customer support requests.

●    Sweepstakes, contests and promotions. If you participate in sweepstakes, contests and promotions that we offer, we may collect your name, age, email address, and other registration information related to contests, sweepstakes and promotions. Your participation in such may be subject to separate terms and conditions or policies.

●    Other requests. We collect and maintain records of your requests, such as when you sign up for our mailing lists or otherwise request information from us.

Personal Information from Third Parties. We may collect personal information about you from third party sources, such as public databases, joint marketing partners, social media platforms or other third parties. 

•    In order to use certain features of the Services, you may be requested to share content from third party accounts. If you grant us permission to access this data by enabling this sharing, we will access and download this Viewing Information from the streaming service for which you have provided Viewing Account Information as described above.

•    We may receive lead and prospect information from third parties about prospective customers that may be interested in our Services. We may also engage with third parties to enhance or update our customer information.

•    We may work with third party vendors and service providers to gather deidentified or aggregated information about how users interact with the Services. This may include information such as demographic information, preference information, what you watch or buy, or your exposure to advertising. These sources include, for example: census data, the manufacturers or sellers of the products you purchase or use, organizations that collect online data, data suppliers, companies that combine purchase information, and other entities that have a legal right to provide such information to us.

Personal Information Collected Automatically. We automatically collect personal information related to your use of our Services and interactions with us and others, including information we collect automatically (e.g., using cookies and pixel tags), as well as information we derive about you and your use of the Services. Such information includes: 

●    Device information. We use cookies, log files, pixel tags and other tracking technologies to automatically collect information when users access or use our Services, such as IP address, the source that brought you to our site, device type, device ID, Internet service provider, operating system, language, and similar device and usage information. For more information, see Section 6. Cookies and Analytics, below.

●    Activities and usage. We also collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, time spent within the Services, and images uploaded.

●    Location information. We may collect or derive location information about you, such as through your IP address. 

3.    Purposes of Use and Processing
Generally, we collect, use, disclose and otherwise process the personal information we collect for the following purposes:

•    Services and support. To provide and operate our Services, communicate with you about your use of the Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your requests, and for similar service and support purposes. 

•    Analytics and improvement. To better understand how users access and use the Services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop services and features, and for internal quality control and training purposes. 

•    Customization and personalization. To tailor content we may send or display on the Services, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.

•    Marketing and advertising. For marketing and advertising purposes. For example, to send you information about our Services, such as offers, promotions, newsletters and other marketing content, as well as any other information that you sign up to receive. We also may use certain information we collect to manage and improve our advertising campaigns so that we can better reach customers and potential customers.

•    Rewards program. To offer you rewards in connection with your use of the Services.

•    Research and surveys. To administer surveys and questionnaires, such as for our market research business, which helps clients and commercial partners better understand consumer behavior.

•    Developing insights and enhancing data. We may combine personal information collected through the Services with other information that we or third parties collect about you in other contexts, such as market research, our communications with you, or your customer service records. 

•    Security and protection of rights. To protect the Services and our business operations; to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use. 

•    Compliance and legal process. To comply with the law and our legal obligations, to respond to legal process and related to legal proceedings.  

•    General business and operational support. To consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions. 

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4.    Disclosures of Personal Information 
We may disclose the personal information that we collect for the purposes described above, in order to provide our Services to you, to respond to and fulfil your orders and requests, as otherwise directed or consented to by you, and as follows:  

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•    Vendors and service providers. We may disclose personal information we collect to our service providers, processors and others who perform functions on our behalf; these may include IT service providers, campaign managers, analytics providers, consultants, auditors and legal counsel. For example, we use service providers to help us fulfill our contests and sweepstakes and to extract and process the purchase information from receipts.

•    Our affiliates. We may disclose personal information we collect to our corporate affiliates or subsidiaries, who will use and disclose this personal information in accordance with the principles of this Policy. 

•    Third party platforms, providers and networks. We may disclose or make available personal information to third party platforms and providers that we use to provide or make available certain features or portions of the Services, or as necessary to respond to your requests. We may also make certain information that includes personal information available to third parties in support of our marketing, analytics, advertising and campaign management (see Section 6. Cookies and Analytics for more information).

•    Data partners and business customers. We may disclose information that you provide through the Services to help our data partners and business customers to better understand consumer behavior. For example, we may combine and/or aggregate purchase information or survey responses that you allow us to collect with the responses of others to produce reports. We may also create aggregated reports based upon deidentified modeled information. “Modeled information” is data based upon demographic and behavioral characteristics (e.g., gender, age, and purchasing habits) to predict what people with similar or matching characteristics would buy. We may also provide your information, including your purchase information and your personal information, to commercial partners and other third parties, such as retailers or brands, for marketing research and analytics purposes (for example, to create modeled information). We will not, however, allow such third parties to use this information for the purposes of individually marketing to you or to contact you.

•    Rewards program purposes. If you are a member of our rewards program, we may disclose your personal information to third parties that we work with to bring you special offers.

•    In support of business transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. We may also share certain personal data as necessary prior to the completion of such a transaction or corporate transactions such as financings or restructurings, to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for a transaction.

•    Compliance and legal obligations. We may also disclose personal information to third parties to comply with our legal and compliance obligations and to respond to legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. This may include regulators, government entities, and law enforcement as required by law or legal process. In addition, it may include certain disclosures that we are required to make under applicable laws, such as the names of sweepstakes and contest winners.

•    Security and protection of rights. We may disclose personal information where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property and safety of others. For example, we may disclose personal information in order to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety or legal rights of any person or third party, or (iii) enforce, and detect, investigate and take action in response to violations of, our Terms of Use. We may also disclose information, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.

5.    Aggregate Data and Non-identifiable Data
We may also receive, use, and disclose aggregate and other non-identifiable data related to our business and the Services for quality control, analytics, research, development, and other purposes. Some of this information may be considered “deidentified” under U.S. privacy laws (i.e., data that is no longer linked or reasonably linkable to an identified or identifiable consumer). Where we rely on data that has been “deidentified” as defined by U.S. privacy laws, we will maintain and use such information in deidentified form and will not attempt t reidentify such information, except in order to determine whether our deidentification processes are reasonable and adequate or as otherwise set forth by applicable law.

6.    Cookies and Analytics 
We and our third-party service providers use cookies, pixels, local storage objects, log files, APIs, and other mechanisms to automatically collect information browsing, activity, device and similar information within our Services. We use this information to, for example, analyze and understand how users access, use our Services, as well to identify and resolve bugs and errors in our Services and to assess secure, protect, optimize and improve the performance of our Services. When you use SVT to connect to a third party online or email account, such third party will likely employ cookies on your computer or device to assist with the signing into such third-party account. From time to time, we may redeploy these third party cookies on SVT for a better user experience by maintaining account connectivity to such third-party online or email account. You have certain choices about our use of cookies and tracking within the Services, as described in this section. For more information on the types of personal information we collect via cookies and similar mechanisms, please see Section 2. Personal Information Collected.
 

Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within Service.  

Pixel tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, help us manage content and compile usage statistics. We may also use these in HTML e-mails we send, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Local storage objects. Local storage is a web storage mechanism that allows us to store data on a browser that persists even after the browser window is closed. Local storage may be used by our web servers to cache certain information in order enable faster loading of pages and content when you return to our websites. You can clear data stored in local storage through your browser. Please consult your browser help menu for more information. 

Third-Party Analytics and Tools. We may use third party tools, such as Firebase, which are operated by third party companies. These third-party analytics companies may collect usage data (using cookies, pixels and similar tools) about our Services in order to provide us with reports and metrics that help us to evaluate usage of our Services and improve performance and user experiences. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Custom Lists and Matching. We may share or make available certain participant list information (such as your name, email address and other contact information) with third parties for analytical and research purposes.

Managing Your Preferences. We make available ways for you to manage your preferences regarding cookies within our Services. These are browser and device specific, which means that you need to set the preference for each browser and device you use to access our Services; in addition, if you delete or block cookies, you may need to reapply these preferences. 

•    Browser settings. If you wish to prevent cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Services who disable cookies will be able to browse the Site, but some features may not function. 

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7.    Your Privacy Choices
We make available a number of ways that you can manage your privacy choices and submit privacy requests related to your personal information. These include:

•    Account. You can review and update much of the personal information we maintain about you, by logging into your account and updating your profile information online.  

•    Marketing communications. You can opt out of receiving marketing emails from us by using the unsubscribe link in the footer of each marketing email we send to you, and you can opt out of receiving marketing and other texts from us by replying OPT OUT to any text we send to you. You can also submit a support ticket by contacting streaming.support@circana.com to unsubscribe.
Residents of certain jurisdictions have additional rights, as set forth below, in Section 12. Additional Privacy Information for Certain Jurisdictions. Further, if you are a California resident, please review Section 12.B Additional Privacy Information for California Residents below, for specific information about your California Privacy Rights and how to exercise them.

For more information about our privacy practices and your privacy choices, you may contact us as set forth in the ‘Contact Us’ section below.

8.    Children/Minors
Our Services are not designed for children, and we do not knowingly collect personal information from children under 16. If we discover that a child under 16 has provided us with personal information in violation of applicable law, we will delete such information from our systems. If you’re a parent and you believe we have collected your child’s information in violation of applicable law, please contact us as set forth below, in Section 11. Contact Us. 

9.    Security

We have implemented safeguards that are intended to protect the personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security. 

10.    Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any updates to this Policy on our Site. If we make material changes to how we collect, use and disclose the personal information we have previously collected about you, we will endeavor to provide you prior notice, such as by emailing you or posting prominent notice through on our website or within the Services.
 

11.    Contact Us
If you have questions about this Policy or our privacy practices, you may contact us at streaming.support@circana.com.

12.    Additional Privacy Information for Certain Jurisdictions 
Residents of certain states have additional rights under applicable privacy laws, as described in this section.  
Please review Subsection A. below for additional information about rights residents of certain U.S. states, including Colorado, Connecticut, Utah and Virginia, may have under applicable state privacy laws.

If you are a resident of California, please review Subsection B. below for additional information about the categories of personal information we collect about you and your privacy rights under applicable California privacy laws.

A.    State Privacy Rights
Residents of certain states, including Colorado, Connecticut, Utah, and Virginia, have additional rights under applicable privacy laws, subject to certain limitations, which may include:

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•    Correction. The right to correct inaccuracies in their personal information, taking into account the nature and purposes of the processing of the personal information.

•    Deletion. To delete their personal information provided to or obtained by us.

•    Access. to confirm whether we are processing their personal information and to obtain a copy of their personal information in a portable and, to the extent technically feasible, readily usable format.

•    Opt-Out. to opt out of certain types of processing, including: 
•    to opt out of the “sale” of their personal information. 
•    to opt out of targeted advertising by us. 
•    to opt out of any processing of personal information for purposes of making decisions that produce legal or similarly significant effects.

You may submit a request to exercise your privacy rights online using our webform. See Section 7. Your Privacy Choices for additional information about the privacy choices we provide and how to exercise them. We will respond to your request as required under the applicable privacy law(s). If we deny your request, you may appeal our decision by selecting the appropriate request using our webform.  

B.    Additional Privacy Information for California Residents
This subsection provides California residents with additional information regarding our collection, use and disclosure of their personal information, as well as their privacy rights, under California privacy laws.  

In this subsection, we provide additional information to California residents about how we handle their personal information, as required by the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information or other personal information that is exempt under the CCPA.  

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Categories of Personal Information Collected and Disclosed. While our processing of personal information varies based upon our relationship and interactions with you, the table below identifies, generally, the categories of personal information (as defined by the CCPA) that we have collected about California residents, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose.  We may also disclose the personal information we collect from you to law enforcement, regulators, government entities, and others, where required by applicable law.

Categories of Personal Information Collected    Categories of Third Party Disclosures