ACORN TV PRIVACY POLICY

EFFECTIVE DATE: November 05, 2020

This Privacy Policy (“Policy”) describes the personal information that Acorn TV, an operating division of RLJ Entertainment, Inc. and for customers located in the United Kingdom and Australia, RLJ Entertainment Ltd. and RLJ Entertainment Australia Pty Ltd (“Acorn TV,” “we,” “our,” or “us”) collect about you, how we use and share that information, and the choices you have about our information collection and processing in connection with your use of Acorn TV’s Services (defined below), operating our business, and the offline interactions you may have with us, such as at promotional events.

For the purposes of this Policy, “personal information” means any information that reasonably identifies, relates to, describes, or could be linked directly or indirectly to you or, if you reside in California, your household.

1. WHAT IS THE SCOPE OF THIS POLICY?

The “Services” means the services provided and made available by Acorn TV or its affiliates in connection with your browsing and viewing of Acorn TV multimedia, such as television shows and movies, through the websites, applications, or other interfaces or platforms operated by Acorn TV. The Services also include any other technologies, features, products, and content that we may provide through Acorn TV user interfaces, such as Acorn TV website(s): www.acorn.tv, and any other website or application in which this policy is linked to or appears (“Sites”). This Policy is incorporated into the Acorn TV Terms of Use (“Terms of Use”). This Policy also applies to the personal information we collect offline and from other sources, as described below.

2. WILL THIS POLICY EVER CHANGE?

We may change this Policy from time to time. If we make changes, we will post the new version here and revise the “Effective Date” above. If we determine that the changes may have a material impact on you, we may take additional steps to notify you and, where required by law, obtain your consent. We encourage you to review the Policy whenever you use the Services to stay informed about our information practices and the choices available to you.

3. WHAT INFORMATION IS COLLECTED ABOUT ME?

Personal Information You Provide to Us

When you access, use, or register for the Services, or interact with us in other ways (including at our events or by contacting us directly), you may provide us with personal information. That includes, for example, personal information that you provide when subscribing to the Services, creating or updating an account, customizing your profile, making purchases, signing up to receive newsletters, posting ratings or comments, setting viewing preferences or parental controls within the Services, or communicating with us.

We may sometimes require you to provide personal information in order to access or receive information or Services from us. For example, you may need to provide your payment card information in order to subscribe to certain services, and you will need to provide your email address in order to receive our newsletters or create an account. We will let you know when we require your personal information, and we will inform you of the consequences for not providing the information.

You also may voluntarily share personal information with us, such as when you communicate with us, post comments via the Services, or upload your photograph or other information to personalize your account profile.

The information you provide us includes:

Personal Information We Collect Automatically

When you use, access, or otherwise interact with the Services, we automatically collect certain information using cookies (i.e., small pieces of electronic information stored by your internet browser software on to your computer’s hard drive), web beacons (i.e., small pieces of data embedded in images on the Services), and similar technologies, collectively “Cookies.” The information we collect with Cookies includes:

Please see our Cookies Policy for more information about our use of these technologies and the choices you may have.

Personal Information We Obtain From Third Parties

We also receive your personal information from other sources. The personal information we receive from these third-party sources includes identifiers, demographics, internet or other electronic network activity information, location information, and inferences regarding your preferences or other characteristics. Specifically, we receive such information from these types of third parties:

4. HOW AND WHY WE USE YOUR INFORMATION

We use your personal information, as permitted by applicable law, primarily to:

We may also use your personal information, as permitted by applicable law, for additional purposes, including to:

Please note that in jurisdictions where legitimate interests are not recognized as a lawful basis for processing personal data, RLJE generally obtains consent.

In addition to the data uses identified above, we may aggregate or mask information we have collected so that it no longer reasonably identifies you, and we may use and disclose such information for any purpose, including without limitation in statistical analyses to help us analyze patterns in the use of the Services.

When we process information to further our legitimate interests, we take steps to balance those interests with yours. Please contact us via the channels listed in Section 8 for more information.

Automated Processing

When we analyze the information we collect for advertising, marketing, security, and fraud prevention, we use automated processes to identify or predict potential risks or outcomes. For example, we may use the information you provide us and information about your online activities to infer your interests. And we use those inferences to support automated decisions about the content, recommendations, and offers we present to you on our digital properties. We use automated tools to identify suspicious activities associated with the Services (e.g., multiple logins from different locations within a short period of time). These automated processing activities will not, without human intervention, have legal or similar effects for you.

5. HOW DO WE SHARE INFORMATION?

We share your personal information for our operational business purposes, including with other organizations that act on our behalf in connection with operating our business and the Services. The recipients include:

The disclosures referenced above involve the following categories of information:

We may share any of the information we collect about you to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets. It is in our legitimate interests to manage our business through legitimate corporate transactions.

We share information pursuant to your instructions or to satisfy your requests.

We disclose personal information to third parties that may use the information for their own business purposes. These third parties provide us with services, insights, or other valuable consideration. California law treats these disclosures as “sales” even if no money is exchanged. We disclose the following categories of personal information to marketing service providers, analytics companies, advertising networks, social media platforms and other third parties for valuable consideration:

Sharing and Disclosure of Information:

Categories of Personal Information Categories of third parties to whom we may disclose personal information for our business or other permitted purposes. Categories of third parties to whom this information may be sold.
Identifiers Group Companies

Service Providers

Government Authorities
Advertising and Analytics Partners
Demographics Service Providers None
Online activity information Group Companies

Service Providers

Government Authorities
Advertising and Analytics Partners
Location information Service Providers Advertising and Analytics Partners
Inferences regarding preferences or other characteristics Group Companies

Service Providers
Advertising and Analytics Partners
Transaction information Service Providers None
Payment information Service Providers None
Audio, electronic, visual, olfactory, or similar information Group Companies

Service Providers
None

When we share information to further our legitimate interests, we take steps to balance those interests with yours. Please contact us via the channels listed in Section 8 for more information.

6. RETENTION OF INFORMATION

We retain your personal information for as long as is necessary to carry out the purposes set out in this Policy, unless a longer retention period is required by applicable law or is necessary for us to protect our rights. We keep your personal information for as long you maintain an Acorn TV account or subscription. When your account or subscription is over, we may retain certain personal information for purposes such as complying with our legal obligations, resolving disputes, preventing fraud or misuse of promotions, and protecting our rights and interests. We may be legally obligated, for example by tax and sales laws, to retain personal information related to product or subscription purchases for a period of time specified by law.

7. SECURITY

We use reasonable technical, administrative, and physical security safeguards to protect the information that we collect or receive against loss and unauthorized access, use, modification, or disclosure. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable. Moreover, we are not responsible for the security of information that you transmit to us over networks that we do not control, including Internet and wireless networks.

8. YOUR CHOICES AND RIGHTS

If you no longer wish to receive marketing communications from us, you can let us know at any time by contacting us at support@acorn.tv or by clicking unsubscribe links or using other unsubscribe features that we provide in our marketing communications.

Subject to local law, you may have certain additional rights regarding your personal information. For example, residents of the UK, Member States of the European Union and other countries (such as Mexico) may have rights to: access personal information; correct personal information; request deletion of personal information; restrict our use of personal information; object to certain uses of personal information; receive personal information in a usable electronic format and transmit it to a third party (also known as the right of data portability); lodge a complaint with a local data protection authority; or withdraw any consent supporting uses or disclosures of personal information. If you have questions about the specific rights you may have, please contact us via the channels listed in Section 12.

If you reside in California and we have collected personal information about you, you may have certain rights with respect to that information, including the rights to: know about the processing of (i.e., access) your personal information (including the categories of personal information we collect, the specific pieces of personal information we have collected, the sources of such information, our reasons for collecting the information, and the categories of recipients); request that we delete your personal information (although we may be permitted by law to retain certain information for specific purposes); and to opt out of the sharing of your personal information for monetary or other valuable consideration , which you may exercise by clicking here: Do Not Sell My Personal Information. You may also request and obtain from us once a year, free of charge, a list of the categories of third parties to whom we have disclosed their “personal information” (as defined under California’s Shine the Light law), if any, for their direct marketing purposes in the prior calendar year, as well as the type of “personal information” disclosed to those parties. You may exercise these rights without fear of unreasonably being denied goods or services. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your personal information. If you would like to request access to or deletion of your personal information, please submit your request to support@acorn.tv. In order to honor your request, we will ask that you provide an email address and contact information which allows us to confirm your identity and avoid fraudulent requests. We verify your identity by matching information you provide with our records. Please note that in the case of requests for deletion, we may need to retain certain personal information to comply with our legal obligations or for other permitted purposes. You also have the option to designate an authorized agent to submit a request on your behalf. Your authorized agent can submit your request to support@acorn.tv. For requests through an authorized agent, we require a valid power of attorney or written and signed permission from you. If your authorized agent relies on your written and signed permission, we may need to verify your identity as described above and may contact you directly to confirm that the request is valid.

Please see our Cookies Policy for information about choices you may have regarding the processing of personal information collected via cookies and similar technologies.

9. DO NOT TRACK

We do not respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how we do so in this Policy. Visit www.allaboutdnt.org for more information on this developing area.

10. LINKS TO THIRD PARTY WEBSITES

Certain of our Services may contain links or may link you to other websites that are not owned or controlled by Acorn TV. If you follow a link to or are linked to another RLJE group entity website, please note that the website or related services may be associated with a different privacy policy, in which case that policy will govern the handling of your personal information with respect to that particular RLJE group entity or offering. Links may also take you to unaffiliated third-party websites. For example, we provide links to third-party online platforms that provide access to our content. Third parties may use your information in accordance with their own privacy policies, which may differ from ours. We do not accept, and do disclaim, any responsibility for the privacy policies and information collection, use, and sharing practices of any third party’s website (whether or not such site is linked on or to the Acorn TV Site). These links are provided to you for convenience purposes only, and you access them at your own risk. Please refer to our Terms of Use for further details.

11. WHERE IS INFORMATION PROCESSED?

We process information in and subject to the laws of the United States, which may not provide the same level of protection for your information as your home country. The information may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries.

In some cases, your information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for information under applicable laws (such as those in the European Union and the UK). When we conduct such transfers, we put in place appropriate safeguards (such as standard contractual clauses) in accordance with applicable legal requirements. For more information on the appropriate safeguards in place or to obtain a copy, please contact us at support@acorn.tv.

12. HOW CAN I CONTACT YOU?

If you have questions or concerns about our Policy, please contact us at support@acorn.tv or write to us at:

RLJ Entertainment, Inc.
Attn: Data Protection Officer
6320 Canoga Avenue, 8th Floor
Woodland Hills, California 91367

AMC Networks International - Iberia
C/O AMCNI European Data Protection Officer
Calle Saturno 1 - Pozuelo de Alarcon
28224 Madrid
dpo@amcnetworks.com

For UK customers:

AMC Networks International - UK
111 Salusbury Road
London
NW6 6RG

For Australian customers:

RLJ Entertainment, Inc.
c/o RLJ Entertainment Australia Pty Ltd
Attn: Data Protection Officer
122 Arthur St., Suite 1401
North Sydney, NSW 2060
AUSTRALIA

13. INFORMATION ABOUT SOCIAL MEDIA PLUGINS

The Services may make use of social network plugins. When you use a Service that contains plugins, information may be directly transferred from you to the operator of a social network. For information about the social network operators of plugins used in the Services, please see below:

Facebook: Data Controller: Facebook Ireland Limited, 4 Grand Canal Square, 2 Dublin, Ireland. For more information about Facebook’s privacy practices, please review their privacy policy.

Instagram: Data Controller: Facebook Ireland Limited, 4 Grand Canal Square, 2 Dublin, Ireland. For more information about Instagram’s privacy practices, please review their privacy policy.

Twitter: Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. For more information about Twitter’s privacy practices, please review their privacy policy.

YouTube: Data Controller: Google, Inc., Amphitheater Parkway, Mountain View, CA94043, USA. For more information about YouTube’s privacy practices, please review their privacy policy.