Effective as of July 8, 2019
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1. WHAT IS AND ISN’T PERSONAL INFORMATION?
“Personal information” is information from which you can be personally identified. This includes your name, email address, location, job title and company or employer, your user ID and password when you access the Services, and other information you tell us about yourself if such information is tied to other information that identifies you. In the European Union, personal information also includes other information that identifies you, including your subscriber ID and your IP address.
Personal information does not include “anonymous information”, which is data collected as part of the Services from which we cannot identify an individual or from which individual identities or other personal information has been removed. It may include information that has been aggregated.
2. INFORMATION THAT WE COLLECT
Information Collected by Conviva through the Site
We collect personal information when you use the Site, including IP address, internet service provider (ISP), referring/exit pages (where you go from our Site), date/time stamp, clickstream data (how you came to our Site) as well as your browser and operating system types. If you wish to contact us through our Site, we will collect personal information such as your first and last name and email address and retain a record.
Information Collected by Conviva through the Services
As part of the Services provided to our Customers, we automatically compute and record anonymous information from the Conviva-enabled media player on your computer, cellphone, tablet or other mobile device, such as internet service provider (ISP), information about content being viewed on the Customer’s platform, viewing device type, service quality and statistics, non-specific geolocation information browser and operating system types. Customers may also decide to provide other personal information, such as viewer ID numbers, unique device and advertising identifiers, and specific geolocation information, however we cannot identify individuals using this information. We store the information described above in log files and provide this to our Customers.
We may require our Customers to provide certain personal information about their employees when they become our Customers, so we may have received your personal information directly from your employer, such as your first and last name, email address and phone number.
3. INFORMATION USE AND DISCLOSURE
How we use your personal information
Conviva uses information we collect for the following general purposes in the performance of our legitimate interests as a business: to provide the Services to our Customers, including to train machine-learning algorithms that are part of our Services; to enhance your video viewing experience; to improve our Services; to contact you; to conduct innovative research; and to provide anonymous intelligent analytic and benchmark reporting for our Customers.
In addition, we also use personal information for the following specific purposes:
- Newsletters and Opt-out Preferences
If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or you can contact us at email@example.com.
We may also send you service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature.
We display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent we may post your testimonial along with your name. You may ask us to update or delete your testimonial by contacting us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Our Site offers publicly accessible blogs or community forums. In order to provide this to you, you may choose to post personal information on such blogs or community forums which we will host for your benefit. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
- Social Media Widgets
Some of the pages on our Site utilize framing techniques to serve content to or from our partners while preserving the look and feel of our Site. Please be aware that, when you view such content, those third parties may be collecting personal information from you about your viewing of that content.
- Links to Other Sites
The Site contains links to other sites that are not owned or controlled by Conviva. Please be aware that we are not responsible for the privacy practices or use of your personal information by such other sites. We encourage you to be aware when you leave our Site and to read the privacy policies of each and every website that collects personal information.
How Conviva Shares Your Personal Information and Who We Share It With
Whether the personal information is obtained through the Site and/or Services, we may disclose it under the following circumstances:
- Third-party service providers: When we share personal information with third-party service companies to facilitate or to provide certain services on our behalf. This will include:
- IT infrastructure companies that facilitate our provision of the Services to you, such as AWS, AT&T, and Google;
- IT support service providers; and
- Other third-party service providers, for the purpose of tracking our Customers’ use of the Services and the Site.
These companies are authorized to use your personal information only as necessary to provide these services to us.
- Merger or acquisition: When we need to transfer information about you if Conviva is acquired by or merged with another company. If Conviva is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified afterwards via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
4. COOKIES AND OTHER TRACKING TECHNOLOGIES
Technologies such as cookies, beacons, tags and scripts are used by Conviva and our partners, affiliates, and service providers. These technologies are used in analyzing trends, administering the Site and other websites used to provide Services (collectively “Conviva Websites”), tracking users’ movements around the Conviva Websites, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies from our partners or service providers on an individual as well as aggregated basis.
5. CONFIDENTIALITY AND SECURITY
We follow generally accepted industry standards to protect the personal information submitted to us through the Site and our Services, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. Access to your personal information is limited to our employees who are required to handle such information as part of their jobs to either improve the Site and/or provide the Services to you.
6. OUR POLICY TOWARD CHILDREN
We do not knowingly collect personal information from children under 13 through our Site or our Services. If you become aware that a child under 13 has provided us with personal information without the consent of their parent or guardian, you should contact us. If we become aware that a child under 13 has provided us with personal information, we will delete such information from our files.
7. INTERNATIONAL TRANSFER
The personal information you provide us through the Site or our Services may be transferred to, and maintained on, computers located outside of your state, province, country or other government jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside of the United States and choose to provide your personal information to Conviva, please be advised that we transfer all information including personal information to the United States and process it in the United States. If you are using the Services in the European Economic Area (the “EEA”) or the United Kingdom, then we will transfer your personal information outside of the EEA or the United Kingdom, as the case may be, in accordance with applicable law, through the use of data transfer agreements authorized by the European Commission, the United Kingdom or other applicable supervisory authority.
8. ABILITY TO CHANGE OR DELETE YOUR INFORMATION AND EXERCISE OTHER RIGHTS
If Requesting Changes to Personal Information Obtained Through the Site
Upon request and within 30 days (unless we tell you that we need to extend this period), Conviva will grant individuals reasonable access to find out what personal information (if any) we process about you and how we are processing such personal information. On request, we can also provide you with a copy of any of your personal information that we hold. We may require additional information in order to verify your identity before we can respond to your request.
In addition, Conviva will permit individuals to correct, amend, or delete information (in accordance with applicable data protection laws). Please contact firstname.lastname@example.org to change your personal information gathered on our website.
If you want us to stop using or to delete your personal information, you can contact us and tell us why. In certain circumstances we may not be able to stop using your personal information but, if that is the case, we’ll let you know and tell you why.
If Requesting Changes to Personal Information Obtained Through the Services
If your personal information has been previously shared with a Customer or was obtained through the rendering of our Services, then you will need to contact the Customer directly to request your personal information be removed from their database.
9. DATA RETENTION
Data Retention of Personal Information Obtained through the Site
We will retain your personal information about your use of the Site for marketing purposes until you request to be removed from our marketing lists, in which case we will delete it except where we need to keep any personal information about you to prevent marketing to you again without your permission, comply with our legal obligations, resolve disputes, or enforce our agreements.
Data Retention of Personal Information Obtained through the Services
We will retain your personal information collected in connection with your use of the Services, such as account login information, for as long as your account or your employer’s account is active (whichever is longer) or as needed to provide you or your employer with the Services. Once you and your employer have closed your account we’ll delete your account information (including any personal information) within one month after account closure except where we need to keep any personal information to prevent fraud or other misuse of the Services, as necessary to comply with our legal obligations, resolve disputes, or enforce our agreements. We retain anonymous information, such as service statistics.
10. COMPLAINTS, QUESTIONS AND SUGGESTIONS
If you have any complaints about our Site or Services, please contact us at:
989 East Hillsdale Boulevard, Suite 400
Foster City, CA 94404 USA
Conviva’s EU-based representative, Conviva Ltd., also can be contacted at:
2-7 Clerkenwell Green
London, EC1R 0DE
Attention: General Manager
In the EEA or the United Kingdom, you may make a complaint to our supervisory body for data protection matters (for example, the UK Information Commissioners’ Office) or seek a remedy through local courts if you believe your rights have been breached