Effective Date: June 30, 2020.
1. Introduction and Overview.
2. Information we collect.
A. Information You Provide to Us.
We and our agents, vendors, consultants, and other service providers (collectively, “Service Providers”) may collect information you provide directly to us via the Service. For example, we collect information when you register an account, make a purchase, sign-up for our newsletter, access our content, or otherwise communicate or transact with us through the Service.
The information we collect may include Personal Information. "Personal Information" is information that can be used to identify you by itself or when it is combined with other information, such as your first and last name, e-mail address, postal address, and payment information, such as your credit or debit card number, security code and expiration date.
B. Information Collected Automatically.
The methods that may be used on the Service to collect Usage Information include:
- Log Information: Log information is data about your use of the Service, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, which is stored in log files.
Information Collected by Tracking Technologies: Cookies, web beacons (also known as "tracking pixels"), embedded scripts, location-identifying technologies, device fingerprinting, and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about your interactions with the Service or e-mails, including information about your browsing and activity behavior.
- Cookies: A cookie is a small text file that is stored on a user’s device, which may be a session ID cookie or tracking cookie. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies help in understanding how you use the Service, and remain longer. The Service may associate some or all of these types of cookies with your devices. Cookies may remain on your device for extended periods of time.
- Web Beacons (“Tracking Pixels”): Web beacons are small graphic images, also known as "internet tags" or "clear gifs," embedded in web pages and e-mail messages. Web beacons may be used to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.
- Embedded Scripts: An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your device from our web server or a Service Provider, is active only while you are connected to the Service, and deleted or deactivated thereafter.
- Location-identifying Technologies: Location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.
Some information about your use of the Service and certain Third Party Services (defined below in Section 6 (“Third Party Services, Features, and Devices”) may be collected using Tracking Technologies across time and services and used by us and our Service Providers for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third Party Services.
C. Information from Other Sources.
3. How we may use your information.
- Manage our Service, including your registration and account;
- Process and facilitate your transactions, including purchases made through our online store;
- Provide access to free and/or purchased downloads and other similar content;
- Respond to your comments, questions, and requests, and provide customer service;
- Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
- Prevent and address fraud, breach of policies or terms, and threats or harm;
- Monitor and analyze trends, usage, and activities;
- Conduct research, including focus groups and surveys;
- Improve the Service or other A24 websites, applications, marketing efforts, products and services;
- Send you advertisements and communicate with you regarding our and third party products, services, offers, promotions, rewards and events we think you may be interested in (for information about how to manage these communications and marketing efforts, please see “Third Party Services, Features, and Devices” and “Your Choices” below); and
- Fulfill any other purpose disclosed at the time you provide Personal Information.
4. How we may share or disclose your information.
We may share your information, including Personal Information and Usage Information, with our Service Providers in order for them to perform the activities listed above in Section 3 (“How We May Use Your Information”) at our instruction or on our behalf. These Service Providers are prohibited from using or disclosing your Personal Information for any other purpose, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.
- To comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements;
- To protect the rights, property, life, health, security and safety of us, the Service or any third party;
- In connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another company;
- With our affiliates for internal business purposes;
- For purposes disclosed at the time you provide Personal Information; and
- With your consent or at your direction.
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose.
5. Sweepstakes, Contests, Promotions.
We may offer sweepstakes, contests, surveys, and other promotions (each, a “Promotion”) jointly sponsored or offered by third parties that may require submitting Personal Information. If you voluntarily choose to enter a Promotion, your Personal Information may be disclosed to third parties for administrative purposes and as required by law (e.g., on a winners list). By entering, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.
6. Third Party Services, Features, and Devices.
Our Service contains content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties (“Third Party Services”). In addition, our Service contains features that allow you interact with, connect to, or access our Service through certain Third Party Services and third party devices (“Third Party Features”). For example, you interact with a Third Party Service when you “like” or “share” content over social media through our Service, or when you purchase merchandise from our online store. Remember that third parties may use Tracking Technologies to independently collect information about you and may solicit Personal Information from you. Also, if you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature.
Our Service also contains Tracking Technologies operated by third parties. For example, analytics services, such as Google Analytics, may use Tracking Technologies on our Service to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide other services relating to Service activity and internet usage. Similarly, ad serving services, advertisers, and other third parties may use Tracking Technologies on our Service and Third Party Services to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on a Third Party Service or third party device after you have left the Service (“Interest-based Advertising”).
7. Your Choices.
A. Accessing Your Information.
You may access, update, or remove certain account information that you have voluntarily submitted to us through the Service by sending an e-mail to us here. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
B. Tracking Technologies Generally.
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Please be aware that if you disable or remove cookies some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
C. Analytics and Advertising Tracking Technologies.
You may choose whether to receive Interest-based Advertising by submitting opt outs. Some of the advertisers and Service Providers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). A24 is not responsible for effectiveness of, or compliance with, any third-parties’ opt out options or programs or the accuracy of their statements regarding their programs.
You can opt out of receiving certain promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link or by sending an e-mail to us here with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that your opt out is limited to the e-mail address used and will not affect subsequent subscriptions or non-promotional communications, such as those about your account, transactions, servicing, or A24’s ongoing business relations.
8. Your California Privacy Rights.
A. Shine the Light.
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing.
A24 may share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please e-mail us here or send us a letter to 31 W. 27th Street, 11th Floor, New York, NY 10001. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that A24 is not required to respond to requests made by means other than through the provided e-mail address or mail address.
Any California residents under the age of eighteen (18) who have registered to use the Service and who have posted content or information on the Service, can request that such information be removed from the Service by sending an e-mail to us here. Requests must state that the user personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view.
B. California Consumer Privacy Act.
The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their personal information. This section describes those CCPA rights and explains how to exercise those rights.
The categories of information, including Personal Information, that we collect from you can be found in the “Information We Collect” section above, which you can access by clicking here.
The business or commercial purposes for which we use the categories of information, including Personal Information, that we collect from us can be found in the “How We May Use Your Information” section above, which you can access by clicking here.
Your Rights Under the CCPA:
- Right to Know: You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (“Right to Know”). You have the Right to Know (i) the categories of Personal Information we collected about you; (ii) the categories of sources for the Personal Information we collected about you; (iii) our business or commercial purpose for collecting that Personal Information; (iv) the categories of third parties with whom we share that Personal Information; and (v) the specific pieces of personal information we collected about you.
- Right to Delete: You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (“Right to Delete”). Once we receive and confirm your verifiable request, we will delete your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us to: (i) complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) debug products to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another party to exercise their free speech rights, or exercise another right provided for by law; (v) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (vi) comply with a legal obligation; or (vii) make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Your Rights under the CCPA
To exercise your Right to Know or Right to Delete, please submit a verifiable request to us by either calling us at 855-550-0007 or by sending an email to CCPArequests@a24films.com.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your Personal Information. The verifiable request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We may need to contact you to request additional information in order to verify you are the person about whom we collected Personal Information or that you are an authorized representative. We will not use any information provided as part of a request, including any contact information you provide or that we request in order to respond to or verify a request, for any purpose other than to respond to or verify your request.
Where your only interaction with A24 is through our websites, and you do not sign up to receive any information from us, we have access to a minimal amount of your information and we do not directly track your online movements. As described above, there are third parties that may collect information from you through your use of our websites, but we do not store any of your personal information and do not have access to your personal information unless we have made a specific request for it from these third parties. In these cases, we do not have a reasonable method to verify your identity, as we do not have a mechanism to confirm your identity solely through the information we have access to and we will be unable to respond to your request to know or delete.
We will make an effort to respond to your verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing either by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period before our receipt of the verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights by (i) denying you goods or services; (ii) charging you a different price or rates for goods or services; or (iii) providing you a different level of quality of goods or service.
For additional information regarding your rights under the CCPA, or how to exercise them, you may contact us at CCPArequests@a24films.com.
The Service is intended for a general audience and not directed to children under eighteen (18) years of age. A24 does not knowingly collect personal information from children under eighteen (18).
10. Data Security.
We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information collected through our Service.
11. International Transfer.
13. Contact Us.
If you have any questions or comments about this policy, please e-mail us here or send us a letter to 31 W. 27th Street, 11th Floor, New York, NY 10001.