Effective Date: December 1, 2020
- Information We Collect
- Use of Information We Collect
- Sharing Information with Others
- Sharing What You Watch
- Your Controls and Choices, Including Opt-Out Options
- Security and Account Access
- Deleting Your SimulTV Account
- Applicable Law
- Questions/Contacting Us
2. Information We Collect
SimulTV may collect the following information from or about you, including personal information, from the following sources:
Information You Provide to Us. We collect information you provide to us. For instance, when you register to use the SimulTV Services, we may collect identifiers and personal information including your name, email address, credit card or other payment method information, address, ZIP code, characteristics such as your age (birth date) and gender, and other information. In addition, SimulTV may collect similar information you provide to us when you respond to surveys or interactive ad units, contact SimulTV through customer service or communicate with us by other means, or participate in promotions or events. We may also collect information you provide as part of selecting your preferences, including within your account settings, and commercial information, such as the SimulTV plan(s) you purchase. SimulTV allows multiple profiles to be set up under one account, so we may collect information you provide to us if you create a profile.
Usage, Technical and Log Data. We collect information when you use the SimulTV Services or interact with SimulTV, including when you view SimulTV advertising outside of the SimulTV Services. We may collect information from and about the browser or device you’re using and information about your internet or other electronic network activity, including through analytics tools and the technologies described below (“Data Collected Through Cookies and Similar Technologies”). This information may include your IP address, device type, browser and software characteristics (such as type and operating system), geolocation data (which may include precise location data), referral URLs, network state, device identifiers or other unique identifiers such as advertising identifiers (e.g., “ad-ID” or “IDFA”) and identifiers associated with browser cookies (see our description of “Cookies and Local Storage” below), and carrier information. We also collect information about your activity on the SimulTV Services including information about the content you view on SimulTV such as series titles and episode names (“Viewing Information”), page views, and ads you have viewed on SimulTV.
Data Collected Through Cookies and Similar Technologies. Like many online services, we use various technologies to collect usage data and store preferences. These technologies are discussed below.
Cookies and Local Storage. A cookie is a small data file that is transferred to your computer’s hard disk. We may use both session cookies and persistent cookies to better understand how you interact with the SimulTV Services or SimulTV advertising published outside of the SimulTV Services, to monitor aggregate usage by our users and web traffic routing on the SimulTV Services, and to customize Content and advertising. These uses allow us to improve the SimulTV Services. We may create a unique device or user ID for you and store it in a cookie so we can customize your experience based on your preferences.
We may collect information through other kinds of local storage (also referred to as “Flash cookies”) and HTML5 local storage, including in connection with features such as volume/mute settings for the Video Player. Because these technologies are similar to browser cookies, they are sometimes called “browser cookies,” even though they may be stored in different parts of your computer.
You can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.
Please note that disabling cookies or deleting information contained in cookies or Flash cookies may interfere with the performance and features of the SimulTV Services, including not being able to store your preferences or login information.
Web Beacons, Pixels and mobile SDKs. In addition to cookies, we may use other technologies such as web beacons or pixel tags, which can be embedded in web pages, videos, or emails, to collect certain types of information from your browser or device, check whether you have viewed a particular web page, ad, or email message, and determine, among other things, the time and date on which you viewed the Content, the IP address of your computer, and the URL of the web page from which the Content was viewed. We may also use or work with third parties including our business partners and service providers who use mobile Software Development Kits (“SDKs”) to collect information, such as advertising identifiers (e.g., “ad-ID” or “IDFA”) and information related to how mobile devices interact with the SimulTV Services.
The use of these various technologies in connection with advertising on the SimulTV Services is explained further below. To learn about opting out of interest-based or online behavioral advertising, please see the information we have provided in Section 6 (“Your Controls and Choices, Including Opt-Out Options”).
Account and Profile Data from Third-Party Services. If you choose to log-in, access or otherwise connect to the SimulTV Services, or contact SimulTV through a third-party service, we may, for example, collect identifiers including your user ID and user name associated with that service, as well as any information you make public using that service. We may also collect information you have authorized the service to share with us (such as your user ID, billing information, public profile information, email address, birthday, pages you have “liked” and other account and profile data).
Information from Partners and Other Sources. We collect information from companies through which you may access or interact with the SimulTV Services (e.g., distribution partners, including device partners and voice assistant platforms) or through which you pay for the SimulTV Services or otherwise receive access to the SimulTV Services as part of your relationship with such company (e.g., mobile phone carriers or other companies that provide services to you). The information we collect from these partners may include email address and other identifiers that support authentication, activation, and personalization of the SimulTV Services, as well as payment processing and other billing-related matters. We may also collect information about you from other sources, including service providers (e.g., data licensors, research and analytics companies, and payment processors), public databases, our marketing partners, and advertisers.
This may include information (whether identifiable, de-identified or anonymous, and whether collected online or offline) about your interests, demographic data, purchasing behavior, and your activities online (such as websites visited and advertisements viewed).
3. Use of Information We Collect
Use of Payment Information. We use payment information, such as credit card numbers and billing ZIP code, and commercial information, such as the SimulTV plan(s) you purchase, to help provide the SimulTV Services. For example, we use payment information to process payments from a subscriber (we use a third-party payment processor to do this), to retrieve account information for a subscriber, to determine whether a subscriber is eligible for promotions, and to detect abuse of the SimulTV Services.
Use of Precise Location Data. In order to access certain SimulTV Services from your computer or mobile device, you may be required to share your device’s precise location data (e.g., latitude and longitude) with us. In addition to providing you with certain SimulTV Services, this also enables us to serve you Content related to your local area such as news and sports, depending on your subscription. This data may also be used to tailor advertising to you based on your location. To learn more about your choices with respect to our collection and use of precise location data, please see the information we have provided in Section 6 (“Your Controls and Choices, Including Opt-Out Options”).
4. Sharing Information with Others
We may share information collected from or about you with others, including business partners, social networking services, service providers, advertisers, and other companies that are not affiliated with SimulTV, for the purposes described below.
Partners. We work with a number of business partners who help us offer the SimulTV Services, including, for example, our content programmers, distributors and device partners, and corporate owners. We may share information collected from or about you with such business partners, including email address, Viewing Information, information about the ads you view on SimulTV and account or device information (e.g., age, gender, device type, IP address, ZIP code, advertising identifiers). This information may be shared for different purposes depending on the partner, including for reporting and analytics, activating, administering, and improving and personalizing your experience with SimulTV or such partner, including by providing you with more tailored content, features, and ads on SimulTV as well as on other platforms and services. We may also engage with companies from time to time to provide you joint promotional offers and opportunities and may share with these companies data you provide or that is collected in connection with those offers (e.g., name and mailing address to fulfill a giveaway).
Service Providers. We may share information collected from or about you with companies that provide services to us, our business partners, and advertisers, including companies that assist with payment processing, analytics, data processing and management (e.g., to facilitate our targeted advertising and marketing efforts), account management, hosting, customer and technical support, marketing, advertising, measurement, and other services. The categories of information that we share with service providers will vary depending on the types of services they provide. For example, we share payment information with our third-party payment processor to assist us in our billing efforts, email addresses with our marketing service providers to assist with our email campaigns, and IP address, hashed emails, and advertising identifiers with service providers to assist in our advertising and marketing efforts.
Audience Measurement Providers. Our business partners, such as content programmers, as well as our advertisers, seek to measure the performance of their creative material across many platforms, including the SimulTV Services. Accordingly, SimulTV may permit the use of third-party measurement software that enables third parties (such as Nielsen) to use information collected from or about you (e.g., Viewing Information, ad exposure data, IP address, advertising identifiers) to include your viewing on the SimulTV Services in calculating measurement statistics such as TV Ratings. To learn more about your choices with respect to Nielsen measurement software, please see the information we have provided in Section 6 (“Your Controls and Choices, Including Opt-Out Options”).
5. Sharing What You Watch
6. Your Controls and Choices, Including Opt-Out Options
You have the following controls and choices regarding how we and third parties use certain information collected from or about you.
Opt-Out from Promotional Communications. You may opt out of receiving promotional communications from SimulTV by accessing your account and clicking on “Manage Email Notifications” or by clicking the “unsubscribe” link in a particular promotional communication.
Please note that you cannot opt out from receiving all communications from SimulTV, including administrative messages, service announcements, and messages regarding the terms and conditions of your account because those may contain important information. You can choose to receive push notifications from SimulTV on your device and can use your device’s settings to turn them off.
Opt-Out Options for Third-Party Online Behavioral or Interest-Based Advertising. Advertising that is based on information collected from or about you across websites, applications and other platforms over time is known as online behavioral or interest-based advertising. Some of the third parties (e.g., ad networks and partners; data exchanges; marketing analytics, digital advertising and marketing service providers) that collect information from or about you on the SimulTV Services in order to provide more relevant advertising to you participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising and/or may be members of the Network Advertising Initiative (“NAI”). SimulTV is committed to complying with the DAA Self-Regulatory.
Principles for Online Behavioral Advertising and the DAA Application of Self-Regulatory Principles for the Mobile Environment. To learn more and to make choices about the use of information from or about you for online behavioral or interest-based advertising on websites (desktop and mobile browsers), please visit the DAA and the NAI. You may also use the opt-out mechanism in the “About Ads”link at the bottom of the SimulTV Site. For information and choices about online behavioral or interest based advertising within mobile applications, you can download the DAA’s AppChoices application from your mobile device at www.aboutads.info/appchoices or from your device’s app store. You can also exercise controls through the settings available to you through your device(s), such as re-setting your device’s advertising identifier, selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices). Please note that your opt-out choices will only apply to the specific browser or device from which you opt out.
There is currently no consensus among industry participants as to what “Do Not Track” means and how to respond to “Do Not Track” browser signals. As such, we do not respond to such signals. Instead, to opt-out of website-based third-party interest-based or online behavioral advertising, please exercise one of the choices listed above. Opt-Out from Collection of Precise Location Data from Your Mobile Device. You can opt out of our collection of precise location data from your mobile device in your device settings, for example, by disabling “Location Services” for the SimulTV application in your iOS device’s settings. Please note that by opting out of our collection of precise location data, your access to the SimulTV Services on your mobile device may be limited depending on your subscription.
Options for Sharing What You Watch. As set forth in Section 5 (“Sharing What You Watch”), we may ask for your consent to SimulTV sharing your Viewing Information together with certain personal information with our content programmers, service providers, and other third parties. If we have asked for your consent, you may view or change your consent preference by logging into SimulTV on your computer, going to your account settings, and editing your profile. If you would like to consent to SimulTV sharing your Viewing Information together with your personal information, set your “Manage Video Sharing” preference to “Yes.” If you would like to withdraw your consent, set your “Manage Video Sharing” preference to “No.” You can change your consent on a case-by-case basis by changing your “Manage Video Sharing” preference before viewing a video. Please allow us a few minutes to process any changes to your preference. Certain additional rights may be available to you if you reside in Virginia.
7. Security and Account Access
The security of your information is important to us. We use a variety of physical, technical, and administrative measures to safeguard information in our possession against loss, theft and unauthorized use, disclosure, and modification. For example, we take steps to limit access to sensitive information from or about you to those SimulTV employees, agents, and contractors who have a legitimate business reason to access such information. We also use measures like encryption and hashing to help protect sensitive information when in transmission. Despite these efforts, please note that there is always a possibility that a breach in data transmission or storage may occur and we cannot guarantee the security of any information from or about you 100% of the time. Please refer to the U.S. Federal Trade Commission’s website for information on how to protect yourself from identity theft.
Please note that if you allow others to use your account (including others you permit to set up profiles under your account), they may be able to view information about your account or any of the profiles under your account, including information about the videos you view and your email address.
Children under 13 years of age are not permitted to register with SimulTV. The SimulTV Services are not intended to be used by children without involvement and approval of a parent or guardian.
9. Deleting Your SimulTV Account
10. Applicable Law
SimulTV is headquartered in the U.S. and the SimulTV Services are intended for users in the U.S. By viewing any Content or otherwise using the SimulTV Services, you consent to the transfer of information to the U.S. to the extent applicable, and the collection, storage, and processing of information under U.S. laws.
12. Questions/Contacting Us
Attention: Legal Department
PO Box 95
Selma, VA 24474