Effective Date: May, 2018.
Introduction and Overview.
Information Collected About You.
Information You Provide.
Information Collected Automatically.
Information from Other Sources.
How We Use the Information We Collect.
Sharing of Information.
Third Party Services, Features, and Devices.
Your Rights and Choices.
Review and Update of Account Information.
Tracking Technologies Generally.
Analytics and Advertising Tracking Technologies.
Your California Privacy Rights.
Your European Privacy Rights.
A. Information You Provide.
We collect information you provide directly via the Service. For example, we collect information when you, register an account, fill in your profile, sign up for a subscription, access videos or other content, conduct a search, participate in a promotion or survey, contact customer support, or otherwise communicate or transact with us through the Service. We may use Service Providers (defined below) to collect this information.
The information we collect may include information that identifies you personally (whether alone or in combination). Some examples of data we collect include the following:
• Name and Contact Data: We collect your first and last name, postal address, e-mail address, telephone number, and other similar contact data.
• Credentials: We collect passwords, password hints, and similar security information for authentication and account access.
• Profile Data: We collect your username and other information you provide through your profile in your account. For more information about how we treat this information, please see the section entitled “Public Information” below.
• Contacts: In some cases, we collect information about other people that you provide to us. If you use our Service to send other people (friends, relatives, colleagues, etc.) messages through our system (such as an invitation to an event), information that may interest them, or products as a gift, we may collect your information, and the information of each such recipient. Such functionality is only intended for United States residents. By using this functionality, you acknowledge and agree that both you and the recipient are based in the United States and that you have the recipient’s consent for us to use his or her contact information to fulfill your request.
• Content: We collect the content of messages you send to us, such as feedback and information you provide to customer service. We also collect the content of your communications as necessary to provide you with the services you use.
You may choose to voluntarily submit other information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.
B. Information Collected Automatically.
We automatically collect certain information about your device and how your device interacts with our Service. We may use Services Providers to collect this information and other third parties may have access to this information as well. Some examples of data we collect include the following:
• Service Use Data: We collect data about the features you use, the subscriptions you purchase, the time of day you browse, and the web pages and e-mails you visit.
• Device Connectivity and Configuration Data: We collect data about the type of device or browser you use, your device’s operating software, your device’s location, your device’s regional and language settings, and other similar information. This data also includes IP address, MAC address, mobile Ad Ids (e.g., IDFA or AAID), and other device identifiers.
Logs, cookies, web beacons (also known as "tracking pixels"), embedded scripts, location-identifying technologies, device fingerprinting, in-app tracking methods, and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about your interactions with the Service or e-mails, including information about your browsing and activity behavior:
• Log Information: Log information is data about your use of the Service, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, which is stored in log files.
• Cookies: A cookie is a small text file that is stored on a user's device for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your device for an extended period of time. When you visit our Service, we may assign your device one or more cookies to facilitate access to our Service and to personalize your online experience. Through the use of a cookie, we also may automatically collect information about your online activity on our Service, such as the web pages you visit, the links you click, and the searches you conduct on our Service.
• Web Beacons (“Tracking Pixels”): Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies which are stored on the user's devices, web beacons are embedded invisibly on the Service and are about the size of the period at the end of this sentence. We may include web beacons in promotional or other e-mail messages or newsletters to determine whether you have opened the messages and the subsequent action taken by you.
• Embedded Scripts: An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your device from our web server or a third party with whom we work, is active only while you are connected to the Service, and deleted or deactivated thereafter.
• Location-identifying Technologies: GPS (global positioning systems) software, geo-filtering, and other location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.
• In-App Tracking Methods: There are a variety of tracking technologies that may be included in mobile apps, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as mobile Ad IDs to associate app user activity to a particular app and to track user activity across apps.
Some information about your use of the Service and certain Third Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third Party Services.
For further information on Tracking Technologies and your rights and choices regarding them, please see “Third Party Services, Features, and Devices” and “Your Rights and Choices” below.
C. Information from Other Sources.
• Social networks when you reference our Service or grant permission to us to access your data on one or more of these services.
• Partners with which we offer co-branded services or engage in joint marketing activities.
• Publicly-available sources such as open government databases or other data in the public domain.
For further information on Third Party Services, see the section entitled “Third Party Services, Features, and Devices” below.
We use information about you for our legitimate interests, including to:
• Manage our Service, including your registration, subscriptions, and account.
• Authorize your access to the Service and enforce content protections.
• Deliver the content and services that you have requested.
• Respond to your comments, questions, and requests, and provide you with customer support.
• Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
• Prevent and address fraud, breach of policies or terms, and threats or harm.
• Perform research and analysis about your use of, or interest in, our and third party content or services.
• Improve the Service or other Electus websites, applications, marketing efforts, products and services.
We also use information about you with your consent, including to:
• Develop and display content, features, and advertising tailored to your interests on our Service as well as on other platforms and services.
• Send you advertisements and communicate with you about our and third party products, offers, promotions, rewards, events, and services that may be of interest to you.
• Fulfill any other purpose disclosed at the time you provide information and with your consent.
We may use information that does not identify you (including personally identifiable information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.
We want you to understand when and with whom we may share information collected about you through your use of our Service:
• Service Providers: We share your information with our agents, vendors, consultants and other service providers (collectively “Service Providers”) that perform certain services on our behalf. These services may include, among other things, fulfilling orders, delivering content to you, authorizing your access to the Service, enforcing content protections, providing customer support and marketing assistance, performing business and sales analysis, personalizing your experience on the Service, supporting our Service functionality and other features offered through our Service. These Service Providers have access to information needed to perform their functions, but are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.
• Content Suppliers: When you view any content on the Service, including videos, we may share your information with the third party companies that provide such content for the Service for purposes of understanding trends and activities and developing better content for the Service. For more information on how we collect, use, and share information about the videos you view on our Service, see “Viewing Information” below and our Video Privacy Notice and Consent.
• Business Partners: We may share your information with the businesses with which we partner to offer you those products and/or services. If you elect to engage in a particular merchant's offer or program, you authorize us to provide your e-mail address and other information to that merchant. In addition, your information may be disclosed to third parties for administrative purposes and as required by law.
• Affiliates: We are part of the IAC family of businesses (go to www.iac.com for a listing of these businesses). We may share information with the IAC companies. Sharing information with our IAC companies enables us to provide you with information about a variety of products and services that might interest you.
• Merger or Acquisition: We may share your information in connection with, or during negotiations of, a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
• Third Parties: We may share your information with third parties for purposes of facilitating your requests (such as connecting your accounts) and providing you with advertisements, including those tailored to your interests.
• Consent: We may share your information for purposes disclosed at the time you provide the information and with your consent or at your direction.
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.
In certain circumstances, we may need to share information about the videos you view on our Service along with other information we have about you, including information you have provided to us (such as your name or address) and information we have automatically collected (such as an IP address, device identifier, or precise location data). By using the Service, you consent to our doing so, including the collection, use, and sharing as described in our Video Privacy Notice and Consent [to be a hotlink]. For more information, please review that policy.
Our Service contains content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties (“Third Party Services”). In addition, our Service contains features that allow you to interact with, connect to, or access our Service through certain Third Party Services and third party devices (“Third Party Features”). For example, you use a Third Party Feature when you connect your account to a Third Party Service, such as through Facebook Connect, or “like” or “share” content over social media through our Service. Likewise, you interact with our Service when you chat with one of our chatbots on a Third Party Service. Remember that third parties may use Tracking Technologies to independently collect information about you and may solicit information from you. Also, if you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature. If you publicly reference our Service on a Third Party Service (e.g., by using a hashtag associated with us in a tweet or post), we may use your reference on or in connection with our Service.
Our Service also contains Tracking Technologies operated by third parties. For example, we may use Tracking Technologies from analytics services, such as Google Analytics, on our Service to help us analyze your use of the Service, compile statistic reports on the Service’s activity, develop and display content and features tailored to your interests, and provide other services relating to Service activity and internet usage. We may also allow advertising agencies, ad networks, and other third parties to display advertisements on our Service, and use Tracking Technologies, such as cookies or web beacons, to collect information about users who view or interact with their advertisements and Tracking Technologies. This information allows them to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on a Third Party Service or third party device after you have left the Service (“Interest-based Advertising”).
We may serve ads on Third Party Services, such as Facebook and Google, that are targeted to reach people (or similar people) on those services that have visited our Service or that are also identified in one of more of our databases (“Matched Ads”). This is done by matching common factors between our data and the data of Third Party Services. If we use Facebook Custom Audiences to serve Matched Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad and find out how to opt-out. We are not responsible for such Third Party Services’ failure to comply with your opt-out instructions.
For further information on Tracking Technologies and your rights and choices regarding them, please see “Information Collected Automatically” above and “Your Rights and Choices” below.
A. Review and Update of Account Information.
B. Tracking Technologies Generally.
Most browsers automatically accept cookies, but you can usually modify your browser setting to decline or remove regular cookies. Browsers offer different functionalities and options so you may need to set them separately. With respect to our mobile apps, you can stop all collection of information via an app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device.
If you choose to decline or remove certain Tracking Technologies, such as cookies, please note that you may not be able to use some of the interactive features offered on our Service. Also, when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
C. Analytics and Advertising Tracking Technologies.
You may exercise choices regarding receipt of Interest-based Advertising by submitting opt outs. Some of the advertisers and Service Providers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Electus is not responsible for effectiveness of, or compliance with, any third-parties’ opt out options or programs or the accuracy of their statements regarding their programs.
You can opt-out of receiving certain promotional communications (e-mails and push notifications) from us at any time by (i) for e-mails, following the instructions as provided in e-mails to click on the unsubscribe link, or sending an e-mail to us at Legal@electus.com with the word UNSUBSCRIBE in the subject field of the e-mail; and (ii) for push notifications or in-app messages, adjusting the permissions in your mobile device.
Please note that your opt-out is limited to the e-mail address and device used and will not affect subsequent subscriptions or, for e-mails, non-promotional communications, such as those regarding service announcements, administrative notices, your account information or transactions, or Electus’ ongoing business relations. Also note that changing information in your account, or otherwise opting out of receipt of promotional e-mail communications will only affect future activities or communications from us. If we have already provided your information to a third party (such as an event provider) before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.
E. Your California Privacy Rights.
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing.
Electus may share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please send an e-mail to us at Legal@electus.com or a letter to us at Electus, LLC, 8800 Sunset Boulevard, West Hollywood, CA 90069. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Electus is not required to respond to requests made by means other than through the provided e-mail address or mail address.
F. Your European Privacy Rights.
If you are a data subject in the European Economic Area (“EEA”), you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, contact us as set forth in the section entitled “Contact Us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority.
Our Service is a general audience service, and not directed to children under thirteen (13) years of age. Electus does not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe Electus has collected such information in a manner not permitted by COPPA, please send an e-mail to us at Legal@electus.com or a letter to us at Electus, LLC, Legal Department, 8800 Sunset Boulevard, West Hollywood, CA 90069, and we will remove such data to the extent required by COPPA.
We implement and maintain reasonable administrative, physical, and technical security measures to help safeguard your information from loss, theft, misuse, and unauthorized access and disclosure. However, no system can be completely secure. Therefore, we do not promise, and you should not expect, that your information will always remain secure.
8800 Sunset Boulevard 7th FloorWest Hollywood, CA 90069
United States of America
For European-specific requests, you can reach our Data Protection Officer at Legal@electus.com
For more information about Electus, please contact: (310) 360-3422