Privacy Policy

The following SAMPLE Privacy Policy is provided for informational purposes only and should not be used until reviewed by legal counsel.

SAMPLE Privacy Policy

[COMPANY] provides an online video service offering a selection of [description of services] and other content. These video services including our [COMPANY] Premium Service, our video player, and any other features, tools, applications, materials, or other services, offered by [COMPANY] on any website, device or platform are referred to collectively as the "[COMPANY] Services."

Below you will find our Privacy Policy, effective as of [date]. This Privacy Policy covers the information collected from or about you and your activities when you use the [COMPANY] Services. It also provides information about our relationships with certain third parties that provide services in connection with the [COMPANY] Services. If you have any questions about our Privacy Policy, please let us know by emailing us at [sample@email.com].

What kinds of information does [COMPANY] collect from or about me and my activities?

Generally speaking, we may collect the following information from or about you and your activities when you use the [COMPANY] Services:
  • Information you give us, including your name, email address, birth date, gender, and your credit card information;o Information automatically collected when you use the [COMPANY] Services, such as your location, your activity on the [COMPANY] Services, and information collected via cookies, web beacons, or other technologies;
  • Information automatically collected when you use the [COMPANY] Services, such as your location, your activity on the [COMPANY] Services, and information collected via cookies, web beacons, or other technologies;
  • Information from other commercially available sources, such as data aggregators and public databases, or our business partners, which may include your interests, purchasing behavior and your activities online, such as websites visited and advertisements viewed; and
  • If you connect your social networking account with your [COMPANY] account, information from your social networking account as described below.
We may combine all of the information we collect from or about you and use it in the manner described in this Privacy Policy.

Are there other parties collecting information from or about me that I should be aware of while using the [COMPANY] Services?

  • Service Providers. Companies that provide services to us - including companies that assist with payment processing, website, user and business analytics, data processing, account management, advertising, and other services - may collect information on the [COMPANY] Services. However, our agreements with these service providers limit the types of information these companies collect, how they may collect it, and how they may use it.
  • Other Websites and Platforms. The [COMPANY] Services may be provided through Internet websites or other platforms operated by other companies. For example, you can access the [COMPANY] Services currently using Internet connected devices such as your Roku Streaming Player, iPad or iPhone and Android devices. Websites and platforms like these may be co-branded with our name or logo, but they are not operated or maintained by us, and we are not responsible for the privacy practices of the websites or platforms operated by third parties. If you are using the [COMPANY] Services on another website or platform, you should check the privacy policy of the other website or platform to determine how it handles any information it collects from or about you.
  • Social Networking Services. You can use the [COMPANY] Services with social networking services, such as Facebook and connect your [COMPANY] account with your social networking account. With your consent, [COMPANY] may send information about you to these services, including information about your use of the [COMPANY] Services. Social networking services also may collect certain technical information about you, such as the IP address of the device you are using to access the [COMPANY] Services and the URL of the page you are viewing.
  • Advertisers. [COMPANY] may place advertisements both on and off the [COMPANY] Services and also carries advertisements from other companies, often with the ability to click through to websites or properties run by these other companies. Companies that help deliver these ads (including ad networks), and advertisers themselves, may use cookies, web beacons, and other technologies to collect information about your use of the [COMPANY] Services in order to deliver advertisements to you, measure their effectiveness, and personalize advertising content.

How does [COMPANY] use information it collects from or about me?

  • Payment Information. We only use payment information, such as credit card numbers, as necessary for completing a particular transaction or fulfilling a service (for example, processing payments from our [COMPANY] Premium Services) and to prevent abuse of the [COMPANY] Services.
  • Other Information. We use the other information we collect from or about you in order to establish and enhance our relationship with you and to help deliver a first-class user experience. [COMPANY]'s use of this information includes the following general purposes: contacting you; customizing the content and advertising you view; fulfilling your requests for products or services; identifying content you share when you use the [COMPANY] Services; improving our services; conducting research; compiling aggregate data for internal and external business purposes; preventing potentially illegal activities; protecting our rights; other uses in accordance with our Terms of Use; and for any other purpose disclosed to you at the time we collect your information.
  • Promotional Communications. We may use your information to:
    • provide you with promotional information about [COMPANY]'s features, services, and other offerings that may be of interest to you; or
    • provide information or offers to you that are related to the [COMPANY] Services on behalf of [COMPANY]'s business partners.
    • Information about your choices regarding promotional communications you receive from [COMPANY] are described in the "Your Choices" section of this Privacy Policy.

  • Recommendations and Advertising. We (and service providers acting on our behalf) may use information about you, including your use of [COMPANY], to provide recommendations and advertisements on the [COMPANY] Services and elsewhere on the web.

With whom does [COMPANY] share the information it collects from or about me?

  • Other [COMPANY] Users. The [COMPANY] Services include social features that let you interact with other people who use them. Information that you voluntarily make public on the [COMPANY] Services will be shared with other [COMPANY] users. For example, if your Facebook username includes your real name, when you post a comment it will be associated with your real name.
  • Business Partners. Except when they are acting on our behalf or when you have provided your information as part of a co-branded promotion, we will obtain your consent before we share your contact information with advertisers, business partners, or other entities that are not affiliated with [COMPANY] so that they may send you promotional information about their products and services directly.
  • Social Networking Services. You can use the [COMPANY] Services on other social networking services such as Facebook, and connect your [COMPANY] account with your social networking account. With your consent, [COMPANY] may send information about you to these social networking services, including information about the videos you watch and your activities on the [COMPANY] Services.
  • Service Providers. We may also share your information with companies that provide services to us, including companies that assist with payment processing, website, user, and business analytics, data processing, account management, advertising, and other services. Similarly, we may share your information with other people or entities in order to provide goods or services that you have requested or to complete a transaction at your request. We may also enter into agreements with outside companies that possess the technology that allows us to customize the advertising and marketing messages you receive while using the [COMPANY] Services. Your information, including clickstream data about your use of the [COMPANY] Services and other online activities, may be shared with these companies so this customization can be accomplished. However, our agreements with these service providers limit the types of information these companies collect, how they may collect it, and how they may use it.
  • Other Parties When Required By Law or When Necessary to Protect Your Rights or Ours. There may be instances when we may disclose your information without providing you with a choice in order to protect the legal rights of [COMPANY] or its affiliates, and each of their respective investors, directors, officers, employees, agents, and suppliers; to protect the safety and security of users of the [COMPANY] Services or to enforce our Terms of Use; to protect against fraud or for risk management purposes; or to comply with or respond to the law or legal process or a request for cooperation by a government entity, whether or not legally required. If you notify us that you believe your legal rights have been violated by [COMPANY] or another user of the [COMPANY] Services, we may provide the information that you provide to us to others to the extent that we believe it is necessary to evaluate and respond to your complaint. For instance, if you submit a notice of copyright infringement to us, we may send a copy to the person or entity that uploaded, stored, or transmitted the material addressed by the communication.
  • Other Parties In Connection With a Transfer of Assets. If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the unlikely event of bankruptcy, we may transfer your information to one or more third parties as part of that transaction.
  • Other Parties With Your Consent. In addition to the sharing described in this Privacy Policy, and only with your consent, we may share personally identifiable information about you, for example, your name, address, telephone number, or email address, with other parties.

How does [COMPANY] use and share aggregate or non-personally identifiable information?

  • In addition to the specific data use and sharing practices described in this Privacy Policy, we may use or share information collected through the [COMPANY] Service for other purposes in aggregated or non-personally identifiable ways. This means that we will combine information about individuals together, or otherwise anonymize the information, so that no individual person is identifiable.
  • We may use information in these forms for a variety of purposes, including for research or analysis, website administration, advertising, and promotional purposes. We also may share it with various affiliated and unaffiliated entities. For example, we may share aggregate information with advertisers about the volume of use on the [COMPANY] Services, the specific [COMPANY] videos in which users are most interested, and the effectiveness of advertisements viewed on the [COMPANY] Services (as measured by the number of users who clicked on a particular advertisement). Also, we use independent third parties to help measure viewing of our content, and these third parties may report statistics about viewing in an aggregate or other non-personally identifiable form.

Do I have choices about [COMPANY]'s use and sharing of the information it collects from or about me?

You have choices about our use and sharing of certain information that we collect from or about you.
  • Other [COMPANY] Users. Please note that when you choose to connect your [COMPANY] account with a social networking account such as Facebook you may choose to share your information and activities with other users of [COMPANY] and that particular social network.
  • Business Partners: Except as otherwise described in this Privacy Policy, we will obtain your consent before we share your contact information with advertisers, business partners, or other entities not affiliated with [COMPANY] so that they may send you promotional emails. We also may offer co-branded promotions with these business partners. If you request information about or otherwise interact with one of these promotions (such as by entering a contest), we may share your contact information with the business partners identified in the promotion.
  • [COMPANY]'s Use of Your Information to Send You Promotional Materials. By emailing [email@sample.com], you may opt out of receiving alerts or email updates from [COMPANY] promoting our site or the products or services of our business partners, or other notices.
  • Terminating Your [COMPANY] Account. You may terminate your [COMPANY] account, in accordance with our Terms of Use, by emailing [email@sample.com]. [COMPANY] Premium Service users should review our Terms of Use for our policies on cancellations and refunds. Please note that, if you terminate your account, we may retain some information about you.

How does [COMPANY] protect the information it collects from or about me?

We use reasonable physical, technical, and administrative measures to safeguard information in our possession against loss, theft and unauthorized use, disclosure, or modification. For example, passwords and other sensitive information are encrypted in transit. We also take steps to ensure that only those [COMPANY] employees, agents, and contractors who have a legitimate business reason to obtain access to your information are granted access.

When you enter sensitive information (such as credit card information on our order forms), we encrypt that information using secure sockets layer technology (SSL), an industry standard protocol for billing transmission in order to help protect the financial information you send us.

Despite these efforts, please note that no data transmission or storage can be guaranteed to be 100% secure. We want you to feel confident using the [COMPANY] Services but we cannot ensure or warrant the security of any information you transmit to us. Please refer to the U.S. Federal Trade Commission's website for information on how to protect yourself from identity theft.

Do any special considerations apply to visitors from outside the United States?

[COMPANY] 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 [COMPANY] 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 website, participating in any of the [COMPANY] 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.

What happens when [COMPANY] changes its Privacy Policy?

From time to time, we may revise this Privacy Policy to reflect industry initiatives or changes in the law or changes to the scope of the [COMPANY] Services or for other reasons. Therefore, it is important to check the effective date of the Privacy Policy posted at [http://www.sample.com/privacy] each time you visit [COMPANY].com or use any of the [COMPANY] Services to ensure you are familiar with the most updated policies and practices. If we make any material revisions to this Privacy Policy, we will notify you by sending you an email to the email address you most recently provided to us prior to such revisions taking effect. If the material revisions concern practices where we have represented that we will obtain your consent to use or disclose your personally identifiable information, we will obtain your consent before taking any action inconsistent with those representations.

What technologies are used to understand how people use the [COMPANY] Services?

At [COMPANY], we, along with our partners and vendors, use a variety of technologies to learn more about how people use the [COMPANY] Services and the Internet. This section provides more information about some of those technologies and how they work.
  • Cookies. Cookies are small bits of information that are stored in separate files within your computer's Internet browser. Cookies store information about your activities on a website or other platform. For example, cookies can store your session information for easy sign-in to a website or other platform you have previously visited. They enable us to make your use of the [COMPANY] Services more enjoyable.
    • For example, we, along with our partners and vendors, may display targeted advertisements based on your activities and other information about you that we have collected, such as your interests. Cookies are one way that we store this kind of information.
    • We, along with our partners and vendors, may also use cookies and similar technologies to relate your use of the [COMPANY] Services to information we obtain from you or from reputable third parties, and to compile aggregate data. For example, if you have asked us to send you information about our upcoming services or promotions, data about your activities on the [COMPANY] Services, collected using cookies, may allow us to limit the materials we send you to items that we believe will be of interest to you.
    • You can configure your Internet browser to warn you each time a cookie is being sent or to refuse cookies completely. However, unless you accept cookies, you will not have access to certain [COMPANY] Services.
    • Some advertisements displayed in connection with the [COMPANY] Services may also access or place cookies on your Internet browser or use other technologies provided by third-party Internet advertisers and the companies that help them deliver their ads (sometimes called "ad networks" or "network advertisers").
  • Other local storage. We, along with our partners and vendors, use other kinds of local storage, such as Local Shared Objects (also referred to as "Flash cookies???) and HTML5 local storage, in connection with the [COMPANY] Services, including the video player. Sometimes called "browser cookies,??? these technologies are similar to the cookies discussed above in that they are stored on your computers and can be used to store certain information about your activities and preferences, such as your volume/mute settings. However, these objects are stored in different parts of your computer from ordinary browser cookies. Many Internet browsers allow you to disable HTML5 local storage or delete information contained in HTML5 local storage using browser controls. For information about disabling or deleting information contained in Local Shared Objects, please click [here]. Please note that disabling these technologies may interfere with the performance and features of the video player.
  • Web beacons. We, along with our partners and vendors, may also use technologies that communicate information from your Internet browser or the [COMPANY] video player to a web server, including so-called "pixel tags,??? "web beacons," "clear GIFs,??? or similar means (collectively, "Pixel Tags???). Pixel Tags, which can be embedded in web pages, videos, or emails, can allow a web server to read certain types of information from your browser, check whether you have viewed a particular web page or email message, and determine, among other things, the time and date on which you viewed the Pixel Tag, the IP address of your computer, and the URL of the web page from which the Pixel Tag was viewed. We use Pixel Tags to improve your [COMPANY] experience, including to provide you with content customized to your interests.

How does [COMPANY] work with social networks such as Facebook?

  • [COMPANY] and Social Networking. If you choose to link your [COMPANY] account with a social networking service, [COMPANY] and that service may share certain information about you and your activities. With your consent, we also may share information about your activities with that social network???s users.
  • Connecting with Facebook While Using the [COMPANY] Services. Facebook and [COMPANY] have developed a process that allows you to connect your [COMPANY] account with your Facebook account. When you connect your accounts, you authorize [COMPANY] and Facebook to share certain information about you with each other. With your consent, we may also share information about your activities on the [COMPANY] Services with Facebook and its users

How does third-party advertising on [COMPANY] impact me?

[COMPANY] carries advertisements from other companies, often with the ability to click through to websites or properties run by these other companies.
  • Clicking on or Viewing Ads. When you click on or view an advertisement, the advertiser may collect some information from or about you. [COMPANY] is not responsible for the privacy practices of advertisers. You should check the privacy policy of the advertiser whose website you visit to determine how it handles any information it separately collects from you. Please be aware that [COMPANY] does not warn you when you have chosen to click through to another website or property when using the [COMPANY] Services.
  • Use of Cookies in Third-Party Advertising. Companies that advertise on [COMPANY] and the providers that help them deliver their ads may use cookies, web beacons, and other technologies to collect information about your use of the [COMPANY] Services in order to deliver advertisements to you, measure their effectiveness, and personalize advertising content. The information practices of these advertising companies are governed by their own privacy policies and are not covered by this Privacy Policy.
  • Information Shared with Advertisers and Advertising Companies. [COMPANY] may share aggregate information with advertisers and the companies that help them deliver their ads so they can measure the effectiveness of advertisements viewed in connection with the [COMPANY] Services. For example, we may tell advertisers the number of users who clicked on a particular advertisement.

Who can I contact if I have concerns about this Privacy Policy?

If you have concerns regarding this Privacy Policy, including if you believe that [COMPANY] may have incorrect information for you, you may email us at [email@sample.com]. You may also contact us by mail at:

Attention: Legal Department

[COMPANY]

[________________]

[_________], [__] [_____]

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