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Spyglass Media Group, LLC Privacy Policy

Updated and Effective November 19, 2019

This Privacy Policy applies to http://www.spyglassmediagroup.com and any other website, pp, feature, or other online service that is owned or controlled by Spyglass Media Group, LLC (“Spyglass”) and that posts a link to the Privacy Policy (collectively, the “Site”). Spyglass Media Group, LLC and its affiliates and subsidiaries are not the same company as, nor are they associated in any way with, Spyglass, Inc. or its parent company, OpenTV, Inc. Further, Spyglass Media Group, LLC and its affiliates and subsidiaries are not the same company as, nor are they associated in any way with Spyglass Entertainment Holdings, LLC or its subsidiaries. This Privacy Policy describes our information and privacy practice with regard to the Site and information we collect offline, which we may combine with online data. By accessing, using, or otherwise interacting with the Site, you agree to be bound by the terms of this Privacy Policy and our Terms of Use [Link], which govern your use of the Site. If you do not agree to the terms of this policy and the Terms of Use, do not access or use the Site or provide personal information to us.

This Privacy Policy covers:

Information We Collect

Our Site is mostly designed to provide you with information about our films, television programs and other content, and you may browse our Site without providing us with personal information. However, through certain features on the Site or otherwise, you may provide or we may collect personal information, which is information that is linked to a specific, identifiable individual (“Personal Information”). We may also collect other information about you, such as information about the device you are using to access the Site, how you use the Site, or certain information about your preferences. The information we collect may be provided by you or a third party, or may be collected automatically. You acknowledge that if you choose to share or post any information publicly (including on our Site, on a third party platform, or through Social Media) about the content on the Site or your film viewing history, the Video Privacy Protection Act of 1998 (18 U.S.C. § 2710) (the “VPPA”) (or any similar state law) does not apply. However, to the extent the VPPA or any similar state law does apply in any manner, you are providing your informed, written consent to the disclosure of that information pursuant to the VPPA and any such state law.

Information You Provide to Us

We may ask you to provide certain information to us when you use the Site or interact with us. For example, we may ask you to provide your email address to subscribe to our mailing list and we collect information from you if you contact us. Our Site is intended for a general audience and is not targeted to persons younger than the age of 16. We do not knowingly collect Personal Information from children younger than the age of 16. If we learn that we have inadvertently collected Personal Information from a user younger than age 16, we will delete that information from our active databases.

Information Collected Automatically

We and third party advertising companies and service providers may use a variety of technologies that automatically or passively collect certain information whenever you visit our Site or otherwise interact with us or our content (“Usage Information”). Usage Information may include the browser and operating system you are using, the URL or advertisement that referred you to our Site, all areas within the Site that you visit, and the time of day you visited the Site, among other information. In addition, we may automatically collect your IP address or other unique identifier (“Device Identifier”) for any computer, mobile phone, or other device used to access the Site. A Device Identifier is a number that is automatically assigned to your device used to access a Site, and our servers identify your device by its Device Identifier. Note that we may be able to collect or infer your approximate location through certain information we collect, such as your IP address. In addition, some mobile service providers may also provide us, or our third party service providers, with information regarding the physical location of the device used to access the Site. We may use Usage Information for a variety of purposes, including enhancing or otherwise improving the Site (such as to help diagnose problems with our server and administer our website) and our products and services (such as by gathering demographic information about how our visitors interact with our content). Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information.

The technologies that may be used to collect Usage Information include the following:

Cookies. A cookie is a small data file placed on your computer or other device when you visit the Site or otherwise access our online content. Cookies may be used for many purposes, such as remembering you and your preferences and tracking your visits to our web pages. We use both session and persistent cookies (which remains on your computer after the browser has been closed). A Flash cookie is a data file placed on your device via the Adobe Flash plugin, which may be built-in to or downloaded by you to your computer or other device. Flash cookies may be used for various purposes, such as enabling a Flash feature and remembering your preferences. If you choose to disable cookies or to adjust your Flash privacy settings on your device, some features of the Site or our content may not function properly. For more information about Flash and the privacy choices Adobe offers, visit: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. You may set up your computer to reject cookies by the privacy settings for your web browser although, in that case, you may not be able to use some of the features on our Site. For further information on cookies visit .

Web Beacons. We may use web beacons (small graphic images or other web programming code, also known as "1x1 GIFs" or "clear GIFs") and similar technologies on our Site and within our communications to you. Web beacons can recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed. Web beacons or similar technologies may be used for a number of purposes, such as to count visitors to the Site, to monitor how users navigate the Site, to count how many e-mails that were sent were actually opened or to count how many particular links were actually viewed and to improve your experience on the Site, including to provide you with content customized to your interests. Our web beacons may collect some contact information (for example, the email address associated with an email message that contains a web beacon).

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter. In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.

Information Provided By Third Parties

We may obtain information about you from third parties, such as if you agree that another website may share information with us. We may also supplement the information we collect with outside records.

We may combine the information we receive from third parties with information we collect through the Site. In those cases, we will apply this Privacy Policy to the combined information.

Social Media Interactions

We may include features on the Site that allow you to interact with third-party interactive websites or similar platforms (“Social Media”), such as enabling you to “like” or “share” content. If you choose to share content or otherwise post information from or through the Site to Social Media, that information may be public and that third party may have access to information about you and your use of the Site. You may also choose to participate on Social Media in a way that connects that third party service with our Site (such as posting to one of our pages on a Social Media site). Doing so may allow us to collect (or the third party to share) information about you, including Personal Information. The information we collect through your Social Media interactions is subject to this Privacy Policy. The information collected and stored by the third party remains governed by the third party’s privacy practices.

How We Use Information

We may use information collected from or about you, including your Personal Information, Device Identifier and Usage Information, to: • Allow you to participate in the Site or features or activities we offer; • Communicate with you (such as sending you email newsletters or responding to a “Contact Us” request); • Help us tailor content and advertisements to you, including personalizing your experience on the Site and advertisements you elsewhere online; • Protect from errors, misuse of the Site, fraud, or any criminal activity; • Improve the Site or our products and services, such as troubleshoot problems, resolve disputes, resolve applicable agreements and policies, and for legal, regulatory, and internal business purposes; and • Fulfill any other purpose consistent with this Privacy Policy, for purposes disclosed to you at the time of collection, and any other purpose with your consent.

How We Share Information We Collect

We may share non-personal information, such as Usage Information and aggregated user statistics, with third parties in our discretion. We do not share your Personal Information with unaffiliated third parties for those third parties’ own direct marketing purposes unless you consent (opt-in or opt-out) to such sharing. We may share the information we have collected about you (including Personal Information) in the circumstances described below or elsewhere in this Privacy Policy, as disclosed at the time you provide information or otherwise with your consent.

Third Parties Providing Services on Our Behalf

We may use third-party service providers to perform certain services on our behalf, such as hosting the Site or Site features, providing website usage analytics, sending email or other communications, or performing other administrative services. We may give these service providers access to your information (including Personal Information) so that they can carry out the services they are performing for you or for Spyglass.

Sweepstakes, Contests, and Promotions

We may offer sweepstakes, contests, or other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you agree to the conditions or official rules that govern that Promotion, which may involvement specific requirements (including allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing materials, except where prohibited by law). If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with administering the Promotion, such as in connection with winner selection, prize fulfillment, as required by law, or as permitted by the Promotion’s terms or official rules.

Administrative and Legal

Spyglass reserves the right to use or disclose any information (including Personal Information) as needed to satisfy any law, regulation or legal request; to protect the integrity of the Site; to fulfill your requests; to cooperate in any law enforcement investigation, an investigation on a public safety matter, or an investigation into claims of intellectual-property infringement; to protect and defend the legal rights or property of Spyglass, our affiliates, subsidiaries, and shareholders, the Site or its users, or any other party; or, in an emergency, to protect the health and safety of our users or the general public.

Business Transfers and Transitions

In the event Spyglass goes through a transition (such as a merger, acquisition, bankruptcy or sale of all or a portion of its assets, such as during the course of any due diligence process), your information (including your Personal Information) will likely be among the assets transferred. By providing your Personal Information, you agree that we may transfer such information to the acquiring entity without your further consent.

Online Advertising and Analytics Providers

Spyglass may work with network advertisers, ad agencies, analytics service providers, and other vendors to serve our advertisements online and to provide us with information regarding use of and traffic on the Site (such as information about the pages viewed and the actions users take when visiting the Site) and the effectiveness of our advertisements. The advertisements you see may be served by one or more third parties, who may set and access their own tracking technologies on your device (including cookies and web beacons). These third parties collect and use information about your activities on the Site, and other websites and services you visit across the various devices you use, to provide you targeted advertising based upon your interests. We and our third party vendors may collect Personal Information over time when you visit the Site or other online websites and services.

Cookies and web beacons, including those set by third-party network advertisers, may be used to (among other things): target advertisements, prevent you from seeing the same advertisements too many times, and conduct research regarding the usefulness of certain advertisements to you. We may share certain information such as Device Identifiers, Usage Information, and de-identified information with third-party advertising companies, analytics providers, and other vendors for advertising and analytics purposes.

We use a variety of service providers to perform advertising and analytics services, and some of these companies may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”). You may wish to visit optout.networkadvertising.org, which provides information regarding targeted advertising and the opt-out procedures of NAI members. You may also want to visit optout.aboutads.info, which provides information regarding targeted advertising and offers an opt-out for participating companies.

We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Site and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online services. You can learn about Google’s practices by going to <google.com/policies/privacy/partners>, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at <tools.google.com/dlpage/gaoptout>.

Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive non-targeted advertisements while online.

How We Respond to “Do Not Track” Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, our Site does not alter its practices when we receive a “Do Not Track” signal from a visitor’s browsers. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Third Party Links & Content

The Site may link to or incorporate websites or content hosted and served by third parties over which we have no control and which are governed by the privacy policies and business practices of those third parties. Spyglass is not responsible for the privacy practices or business practices of any third party.

Security

We employ commercially reasonable security methods and technologies to help secure your Personal Information, including physical, technological, and organizational protections. However, no system can be guaranteed 100% secure. We therefore cannot ensure or warrant the security of any information that you transmit to us, or that we transmit to you, or guarantee that it will be free from unauthorized access by third parties. You use the Site and provide us with information at your own initiative and risk.

Consent to Transfer and Storage in the United States

Spyglass is a United States company. Please be aware that information we collect will be transferred to and processed in the United States and other countries. By using the Site, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing, and storage of your information in the United States and other jurisdictions, the privacy laws of which may not be as comprehensive as those in the country where you reside and/or are a citizen.

Your Choices

You can unsubscribe from marketing emails through the opt-out mechanism included in each marketing email we send you. Note that even if you opt-out from marketing emails, we reserve the right to send you transactional account messages, such as notices of changes to this Privacy Policy or other terms.

Changes to this Privacy Policy

We reserve the right to change or modify this Privacy Policy in our discretion at any time and will notify you of material changes by posting the changed or modified Privacy Policy on our Site. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any changes will be effective immediately upon posting the posting of the revised Privacy Policy unless otherwise specified, and your continued use of the Site after the effective date of the Privacy Policy (or such other act as specified in the revised Privacy Policy) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.

California Privacy Rights

California Civil Code Section 1798.83 permits residents of the State of California to request certain details about how their personal information has been shared during the calendar year with third parties for those third parties’ own direct marketing purposes, unless, as Spyglass does, the business permits California residents to opt-in (or opt-out) of this type of sharing. We will not share personal information about you with third parties for their own direct marketing purposes if you do not opt-in (or if you opt-out) at the time Spyglass offers you that choice. If you are a California resident and have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send us your request to the following email address: privacy ( at ) spyglassmediagroup ( dot ) com or write to us at the following address: Spyglass Media Group, LLC, 1840 Century Park East, 15th Floor, Los Angeles, California 90067. You must put the statement “Your California Privacy Rights” in the subject field of your email or in the address line of your envelope. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

Contact Us

Spyglass Media Group, LLC 1840 Century Park East, 15th Floor Los Angeles, California 90067 privacy ( at ) spyglassmediagroup ( dot ) com Phone: 424-332-5777