Effective January 1, 2022

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PRIVACY POLICY

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1. Introduction.
 

This privacy policy (“Privacy Policy” or “Policy“) explains the data protection practices of Origin Media Inc. and its subsidiaries and affiliates (collectively, “ORIGIN MEDIA“, “we” and “us“) when you visit or use the websites and mobile-optimized version of our websites (“Services“). 

For the purposes of data protection laws, ORIGIN MEDIA is the data controller.

This Privacy Policy is incorporated into and subject to the Services’ Terms of Use.  If you do not agree to the Terms of Use and this Privacy Policy, you must discontinue using the Services and all components and features therein.  By using the Services, you acknowledge you have read and understand this Privacy Policy.

2. The Information We Collect.

We obtain information about you through the means discussed below when you use our Services.  The information we collect and the purposes for which we use it will depend to some extent on the specific Services you use and how you interact with ORIGIN MEDIA.  For example, we collect the information you provide when you subscribe to newsletters, promotional correspondence, or send us an email or feedback.  If you elect to participate in our social networking features or other community boards that may be offered on our Services, then such materials will be collected and some information, including your posted pseudonym, may be publicly available for others to view.  We, or our service providers on our behalf, may collect the following information about you or your use of the Services:

A. Information You Provide to Us:

• Demographic, statistical, and interest information such as your age, date of birth, gender, interests, lifestyle information, and hobbies.

• User-generated content such as comments on articles, photos, videos, audio, any information you submit in public forums or message boards, reviews and feedback or testimonials you provide about our Services.

• Social media information (which may include contact information, photos, location, user generated content, demographic information) if you link your account or access the Services through a third-party connection or log-in, we may have access to any information you provide to that social network depending on your privacy settings such as your name, email address, friend list, photo, gender, location, and current city; and information you provide to us directly through our pages on social networking and blogging platforms (e.g., Facebook, Instagram, Snapchat, WordPress, and Twitter).

• Other information any other information you choose to directly provide to ORIGIN MEDIA in connection with your use of the Services.

B. Information we collect automatically:

• Device information and identifiers such as IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers.

• Internet network and device activity data such as information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, the URL that referred you to our Services, the web sites you visit after this web site; if you share our content to social media platforms; and other web usage activity and data logged by our web servers, whether you open an email and your interaction with email content, access times, error logs, and other similar information.

• Geolocation information such as city, state, and ZIP code associated with your IP address or derived through Wi-Fi triangulation; and precise geolocation information from GPS-based functionality on your mobile devices, with your permission in accordance with your mobile device settings.

3. How We Use the Information We Collect.
 

Depending on the Services you use and how you use them, we, or our service providers, may use your information to:

 

• communicate with you and provide customer service;

• personalize your experience;

• improve the Services and develop new services;

• audit consumer interactions on the Services; and

• bug detection and error reporting.

4. How We Share the Information Collected.

ORIGIN MEDIA may (and you authorize us to) share or disclose information collected from and about you on the Services to other companies or individuals as set forth below.

• Our Affiliates: We may share information we collect within the ORIGIN MEDIA family of companies to deliver products and services to you, ensure a consistent level of service across our Services, internal management and administrative purposes on our behalf and enhance our products, services, and your customer experience.

• Information You Disclose Publicly: You may submit photographs, user profiles, written material, music, video, photos, comments and other content, which may include information relating to individual users (collectively, “UGC“) on the Services.  We do not control who will have access to the UGC you choose to make public or how they will use it and take no responsibility for ensuring such UGC remains private or is secure. The UGC is not subject to this Privacy Policy. We are also not responsible for the accuracy, use or misuse of any UGC that you disclose or receive through the Services. Please see our Terms of Use for further information about the terms that govern the UGC you post.

• Third Parties for Legal Purposes: By using the Services, you acknowledge and agree that we may access, retain, and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of ORIGIN MEDIA, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.

• Social Networks: As noted above, if you use your login credentials from a social media networking service on a Website, we may receive information from such service in accordance with its terms and privacy policy and your settings. If you elect to share your information with these social networking sites, we will share information with them in accordance with your election.  The terms and conditions of these social networking sites will apply to the information we disclose to them.

• Sales or Transfer of Business or Assets: In connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock, or otherwise, including via bankruptcy) of all or a portion of the business conducted by the Website to which this policy applies, in which case the company will possess the information collected by us and will assume the rights and obligations regarding your information as described in this Privacy Policy (the “Acquisition Use“).

5. Legal Grounds for Using (Processing) Your Information.

If you are a visitor from the European EconOrigin Mediac Area, our legal basis for collecting and using the information described above will depend on the information concerned and the context in which we collect it. We collect information from you:

 

• where we need it to perform our contract with you (i.e. our Terms of Service);

• where the processing is in our legitimate interests (provided that these aren’t overridden by your interests or rights) (such as personalizing our services and marketing for example); or

• if we otherwise have your consent.

If you have questions about or need further information concerning the legal basis on which we collect and use your information, please contact us using the contact details provided under the “Contact Us” section below.

6. Your Rights & Your Choices Marketing Emails.

If you want to stop receiving promotional e-mails from us, click on the “unsubscribe” link in any promotional email from us.  Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective.  We may still communicate with you from time to time if we need to provide you with transaction information about the Services you are using, or for other legitimate non-marketing reasons, for example, if we update this Privacy Policy or our Terms of Service.

SMS Text Communications. You may opt-out of SMS messages from us by following the instructions provided in the message or by texting back STOP to the number we send the text from for that particular SMS message.  When we receive an opt-out message from you for SMS messages, we may send a message confirming our receipt of your opt-out.

Privacy Information for California Residents. If you are a California resident, California law requires us to provide you with some additional information regarding your rights with respect to your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). We describe the categories of personal information we collect, the sources and uses of such information and the entities to which we share such information in our California Privacy Notice.

A. California Data Access & Deletion Rights.

If you are a California resident, the CCPA allows you to make certain requests about your personal information.  Specifically, the CCPA allows you to request us to:

• inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information;

• provide access to and/or a copy of certain personal information we hold about you.

• delete certain personal information we have about you; and

• provide you with information about the financial incentives that we offer to you, if any.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you.

Verification: We will take reasonable steps to verify your identity before responding to a request, which may include, depending on your request and relationship with you verifying your name, email address, address, and/or having you respond to an email from us.

You are also permitted to designate an authorized agent to submit certain requests on your behalf.  In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney.  We may also follow up with you to verify your identity before processing the authorized agent’s request.

B. International Users.  Some international users of our Services have certain legal rights to access certain information we hold about them and to request its deletion. For example, your local laws may permit you to request that we:

• provide access to and/or a copy of certain information we have about you;

• prevent the processing of your information for direct-marketing purposes;

• update information which is out of date or incorrect;

• delete certain information which we have about you;

• restrict the way that we process and disclose certain of your information;

• transfer your information to a third-party provider of services; and

• revoke your consent for the processing of your information.

We will consider all requests and provide our response within the time period stated by applicable law. Certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation.  We may request you provide us with information necessary to confirm your identity before responding to your request.
If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Contact Us” section below at any time.

7. Retention of Your Information.

We keep your information for no longer than necessary for the purposes for which it is processed.  The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

8. Cookies and Other Tracking Technologies.

We use and allow certain other companies to use certain tracking technologies, including cookies, web beacons, and other similar technologies (collectively, “Cookies“) on the Services.  This section (“Cookie Notice“) explains what these technologies are and why we use them, as well as your rights to control our use of them.  We endeavor to adhere to the Digital Advertising Alliance’s (DAA) self-regulatory principles governing interest-based advertising.

What are Cookies?
 

Cookies are text files that contain a certain amount of information and are downloaded to your computer or mobile device when you visit a website.  They are useful because they allow websites to recognize a user’s device.  They are then returned to the original website on each subsequent visit or to any other website that recognizes them. For more information on cookies, go to http://www.allaboutcookies.org.  The term “Cookie” is used in this Cookie Notice in the broad sense to include all similar techniques and technology, including web beacons and log files. For more information on these additional tools, see our glossary below.

 

Types of Information We Collect
 

Cookies help us to understand Website usage and to improve the content and offerings on our Services and in other media.  Examples of the types of information that we collect through Cookies include: The number of users visiting Services, the number of times a Website was viewed, the pages viewed, the clicks made on the Services and the total duration of navigation on the Services; The name of the page that referred you to the Website; Whether this is your first time visiting the Website; Your viewing preferences (e.g. layout, sizing preferences, language etc.)
Your user name, your password, the type of browser used and your IP address, so that we can identify you during your next visits.

 

How We Use Cookies
 

Examples of ways that we use Cookies include:

 

• To control the display of ads;

• To track usage patterns on the Services;

• To deliver editorial content;

• To implement our affiliate marketing program; and

• To personalize information.
   

ORIGIN MEDIA (or third party service providers on our behalf) may also use cookies to collect aggregate information about Website users on an anonymous basis (“Anonymous Information”).  We may share demographic and usage information with our prospective and actual business partners, advertisers, and other third parties for any business purpose.

 

Types of Cookies We Use on Our Services

We use first party and third party Cookies for several reasons.  Some Cookies are required for technical reasons in order for our Site to operate, and we refer to these as “essential” or “strictly necessary” Cookies. Other Cookies also enable us to track and target the interests of our users and to enhance the experience on our Services.  Third parties also serve Cookies through our Services for advertising, analytics, and other purposes. 

 

Web Beacons

Small graphic images or other web programming code called web beacons (also known as “clear GIFs” or “pixel tags”) or similar technologies may be included in our web pages and messages. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed. A clear gif may enable us to relate your viewing or receipt of a web page or message to other information about you, including your Personally Identifiable Information.

 

HTML
 

HTML, the language some websites are coded in, may be used to store information on your computer or device about your interaction with and use of the Services.  This information may be retrieved by us to help us manage our Services, such as by giving us information about how our Services are being used by our visitors, how they can be improved, and to custOrigin Mediaze them for our users.

9. Links to Third Party Sites.

When you are on the Services, you may be directed to other websites that are operated and controlled by third parties that we do not control.  We are not responsible for the privacy practices employed by any of these third parties.  If you access a third-party website from the Services, you do so at your own risk, and you understand that this Privacy Policy does not apply to your use of such websites.

10. Security.

We implement appropriate administrative, technical, and security safeguards to help prevent unauthorized access, use, or disclosure of the information we collect.  However, no systems can be completely secure.  Therefore, while ORIGIN MEDIA uses reasonable efforts to protect your information, ORIGIN MEDIA cannot guarantee its absolute security, and your use of the Services indicates your agreement to assume this risk.

11. Special Note For Parents.

The Services are for a general audience and are not designed or intended for use by children, especially those under age thirteen (13) or sixteen (16) in the EU.

12. Transfer Information to the United States.

The Services are operated in the United States of America (USA) and are intended for users located in the USA.  If you are located outside of the USA, please note that the information you provide to us will be transferred to and processed in the USA, where laws regarding processing of personal data may be less stringent than the laws in your country.

13. Changes to This Privacy Policy.

We reserve the right to change this Privacy Policy at any time without prior notice.  Any changes will be effective immediately upon the posting of the revised Privacy Policy.

14. Disputes; No Rights of Third Parties.

If you choose to access the Services, or use any of our Services, any dispute over privacy is subject to our Terms of Use, including limitations on damages, resolution of disputes by binding arbitration, and application of the laws of the United States, and the State of Washington.  This Privacy Policy does not create rights enforceable by third parties.

15. Contact Us: Data Privacy Officer.

If you have any questions or concerns about any aspect of this Privacy Policy, please contact our Data Privacy Officer at the email address set forth below.

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Data Privacy Officer
Origin Media Inc.

jchiang@originmedia.tv

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Last revised on January 30, 2022