Date: October 15, 2015
Thank you for visiting SnagFilms. Your privacy is important to us and we know that you care about how we protect your information. This Policy covers information SnagFilms collects when you use our service, as well the nature of our relationships with certain third parties that provide services in connection with SnagFilms. We invite you to review this Policy explaining how your information is collected, used and shared by SnagFilms.
SnagFilms provides a video service offering a selection of videos and other content (collectively, “Content”) available on the SnagFilms.com website including any mobile versions thereof (the “SnagFilms Site” or “Site”), SnagFilms’s applications on mobile and connected-television devices, smart televisions, and gaming consoles (collectively, “Apps”), and SnagFilms’s affiliates and other websites where users may embed the Content (“Distribution Sites”) (collectively, the “Sites”). Our video service, including the Content, video player, and any other features, tools, applications, materials or other services offered from time to time by SnagFilms in connection with its business on any of the Sites are referred to collectively as the “SnagFilms Services” or “Services.”
I. INFORMATION WE COLLECT
Through the SnagFilms Services, users can, among other things, view streaming videos, grab embeddable players and post comments. We may collect the following categories of information.
Information you provide directly to us:
· your first and last names, user name, email address, photo, password (hashed), and birthday;
· your Facebook and/or Twitter user name;
· information posted in interactive online features (for example, video comments and/or “favorite” content); and
· emails you send to us.
Information automatically collected when you visit and interact with the Sites:
· your usage behavior, such as the dates and times of your visit(s) to the Site, the pages and ads viewed, links clicked on, videos streamed, search queries, and the embeddable players grabbed;
· the type of browser you are using (e.g., Firefox, Internet Explorer, Chrome);
· the type of operating system you are using (e.g., Microsoft Windows or Mac OS);
· the domain name of your internet service provider (e.g., AOL, Earthlink);
· your computer’s internet protocol (IP) address and bandwidth speed;
· the web pages you were visiting immediately before and after you came to the Site and search terms you used to reach the Site;
· aggregated data about email click-through rates and user video viewing; and
· information collected via cookies, web beacons, and similar technologies.
“Web beacons” or clear .gifs are small pieces of code placed on a web page to monitor the behavior and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. We and third parties may use web beacons on the Site from time to time for this and other purposes.
Information we may collect from other sources:
· Facebook and Twitter ID;
· non-personally identifiable demographic data collected by Google Analytics (such as age range, gender and interests);
· advertisement interaction and viewing data;
· unique identifiers, including mobile device identification numbers, that can identify physical location of such devices in accordance with applicable law; and
· information from other commercially available sources, such as data aggregators, public databases, online marketing firms, ad targeting firms, or our business partners, which may include your age, gender, interests, purchasing behavior and your online activities, such as websites visited and advertisements viewed.
II. INFORMATION COLLECTED BY OTHERS
Some of our pages contain links to other sites whose information practices may be different than ours. Visitors should consult the other sites’ privacy notices. Please be aware that SnagFilms does not warn you when you have chosen to link through to another website from the SnagFilms Site or Apps.
SnagFilms sometimes may offer content that is sponsored by or co-branded with identified third parties. By virtue of these relationships, the third parties may obtain personally identifiable information that visitors voluntarily submit to participate in the Site activity. We have no control over use of this information by these third parties.
III. HOW WE USE THE INFORMATION WE COLLECT
We may use the information we collect in order to establish and enhance our relationship with you and to improve the user experience we provide.
To Customize the Advertising You View.
To Communicate With You.
We sometimes use your information to communicate with you, such as to notify you when we make changes to the SnagFilms Site or to fulfill a request by you to receive our newsletter(s). We may also use your information to provide you with promotional information about SnagFilms’s features, services, and other offerings that may be of interest to you, or to provide information or offers to you that are related to the SnagFilms Services on behalf of our business partners.
To Improve Our Services.
While using the SnagFilms Sites you will have the opportunity to comment on Content (“User Content”). If you choose to submit User Content for publication, we may publish your name and other information you have provided to us, such as your photo. Please understand that when you post such User Content, it is made public and is not subject to this Policy. If you remove User Content, copies may remain viewable in cached and archived pages or if other users have copied or stored your User Content.
To Analyze Data.
We sometimes use the non-personally identifiable information that we collect to improve the design and content of our Site and Apps and to enable us to personalize your experience. We also may use this information in the aggregate to analyze Site and Apps usage, as well as to offer you products, programs, or services.
We may use anonymous data for purposes of research or analysis. Anonymous data is information (whether it was originally personally identifiable or non-personally identifiable) that subsequently is used in aggregate form. We may conduct research on our customer demographics, internet usage, and interests and behavior based on personal data we gather. Although anonymous data may be based in part on such personal data, it does not identify you personally. SnagFilms may share this type of anonymous data with a variety of third parties, including its affiliates, advertisers and other current and prospective business partners.
We also may use anonymous data for website administration, advertising and promotional purposes, and we may share such information with various affiliated and unaffiliated entities for such purposes. IP addresses also are used to provide anonymous aggregated data to advertisers about the volume of use on the SnagFilms Services. Anonymous usage and demographic information also may be shared with our advertisers and business partners.
SnagFilms has implemented Google Analytics. We use the data collected by Google Analytics to better understand who our users are. SnagFilms will not facilitate the merging of your personally identifiable information with the non-personally identifiable information collected from this feature.
Finally, SnagFilms stores information about which videos you view. This information may be used to determine Site usage patterns.
To Enforce Our Rights.
IV. HOW WE SHARE THE INFORMATION WE COLLECT WITH THIRD PARTIES
We value your privacy, and we share information about our users only under certain circumstances. We may make information about you available to other companies, applications, or people in the circumstances listed below.
For Legal Purposes.
If We Sell Our Business.
As we develop our business, we have the right to buy or sell assets or business offerings. Customer, email and visitor information is generally one of the transferred business assets in these types of transactions. Accordingly, we may transfer personally identifiable information about you if we, or one of our business units, are acquired by, sold to, or merged with another company.
With Our Agents and Contractors.
We may share aggregated information or information that does not directly identify you with third parties to help us develop content, services, and advertising that we hope you will find of interest.
Public Activities on Site.
If you choose to engage in public activities on the site, such as posting comments, any information you submit can be read, collected, or used by others. Please exercise caution when deciding to disclose any personal information in public activities or submissions.
Once we share your information with another party, the information received by that party becomes subject to the other party’s privacy policies. Please note that third parties may independently collect data about you, including your IP address and information about the websites you visit and the links you click, through cookies, clicks on links, or other means when you visit or view ads on the Sites.
Please also note that we do not consider any companies that are within our “family” of companies to be “third parties” for purposes of this Policy. Thus, we also may share information provided with SnagFilms affiliates. Any of these companies may use and further share this information in the same ways we do. However, if we pass on personal information to an affiliate, we require that it protect such information in a manner that’s consistent with this Policy.
V. HOW WE WORK WITH THIRD-PARTY SOCIAL NETWORKS
To customize your experience on the Site and Apps and to simplify our registration process, we may provide you with the opportunity to access or interact with third-party social networks such as Facebook and Twitter. When you connect to the Site and Apps through such third-party services, we may share information about you with them and they may share data about you with us, including as follows:
· If you connect with a third-party service, you may be able to publish information about some of your activities on the SnagFilms Services, such as the videos you watch, to that service. Please note that when you choose to publish your information from SnagFilms to social networking services, that information will be visible to users of those services, in accordance with applicable law and the privacy policies of those services.
· If you visit SnagFilms while logged into one of these services, the third-party service may be able to identify you and to associate the technical information provided by your web browser with other information the service already has about you.
Please remember that we do not control the privacy practices of these third-party services. We encourage you to read the privacy policies of all third-party service providers.
VI. HOW YOU CAN CONTROL YOUR INFORMATION
At certain parts of the SnagFilms Site, only persons who provide us with the requested personally identifiable information will be able to order services or otherwise participate in the relevant activities and offerings.
If you have a SnagFilms user Account, you may be able to:
· Edit your Account information, such as first and last names (optional), email address, password, “favorites” and (videos viewed) history.
· Deactivate your SnagFilms Account at any time. When you deactivate your Account, we’ll close it. However, some information, such as your User Content, will remain visible on the Site and Apps. We may retain archived copies of your information as required by law or for legitimate business purposes (including to help address instances of fraud and/or spam).
You may have choices available to you through the device or software you use to access SnagFilms. For example, your mobile device may provide you with choices around how and whether location or other data is shared with us. To learn more about these choices, please see the information provided by your device or software provider.
You may be able to opt out of Google Analytics, including the Display Advertising feature Demographics and Interest Reporting. For information on opting-out of this feature and customizing Google Display Network ads, please see https://www.google.com/settings/ads.
VII. “DO NOT TRACK” SIGNALS
Some web browsers may transmit “do not track” signals to the websites and other online services with which the browser communicates. There is no standard that governs what, if anything, websites should do when they receive these signals. SnagFilms currently does not take action in response to these signals. If and when a standard for responding is established, we may revisit our policy on responding to these signals.
VIII. CALIFORNIA RESIDENTS
If you are a California resident, you may make a written request to us about how we’ve shared your personal information with third parties for their direct marketing purposes during the prior calendar year. Please send your request (along with your full name, email address, postal address, and the subject line labeled “Your California Privacy Rights”) by email to firstname.lastname@example.org.
California users also are entitled to the following information: The Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 1625 North Market Blvd., Suite N 112, Sacramento CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.
IX. OUR COMMITMENT TO SECURITY
We believe we have in place the appropriate physical and technical procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online.
Unfortunately, no security system can be guaranteed to be 100% secure. Accordingly, we cannot guarantee the security of your personal information and cannot assume liability for improper access to it. By using the Services, or providing personal information to us through any means, you do so at your own risk and you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services.
An important element of our safeguards to protect your personal information is verification of your identity before granting you access to your Account via a unique password. You are responsible for maintaining the secrecy of your unique password and Account information, and for controlling access to your email communications from SnagFilms, at all times.
X. OUR COMMITMENT TO THE PRIVACY OF CHILDREN
Protecting the privacy of young children is important to us. The Services are designed to be of interest and service to users ages 13 and older. If you are under 13 years of age, you may use these Services only with the permission and under the supervision of your parent or guardian. SnagFilms does not knowingly collect or maintain information from persons under 13 years of age. If SnagFilms learns that personally identifiable information of persons less than 13 years of age has been collected on the Sites without verified parental consent, then SnagFilms will take the appropriate steps to delete this information. If you believe that we might have any information from or about a child under 13, please contact us at email@example.com (subject line: “Children’s Privacy”).
XI. USERS OUTSIDE THE UNITED STATES
SnagFilms is an online video service based in the U.S., and our offices are headquartered in the U.S. Please be aware that information you provide to us or that we obtain as a result of your use of the SnagFilms Services may be processed and transferred to the U.S. and be subject to U.S. law. The privacy and data protection laws in the U.S. may not be equivalent to such laws in your country of residence. By using our Site or Apps, participating in any of the SnagFilms Services, or by providing us with your information, you consent to this collection, transfer, storage, and processing of information to and in the U.S.
XII. HOW TO CONTACT US
SnagFilms is located at 1875 Connecticut Ave., N.W., 10th Fl., Washington, D.C. 20009.
XIII. UPDATES & EFFECTIVE DATE