IRIS.TV

Privacy and Data Security Policy

Last Updated: Tuesday May 29, 2018

IRIS.TV respects your concerns about privacy. IRIS.TV is a cloud-based personalized video programming system that allows publishers and content owners to generate more video views and engage users across all devices.

This Privacy Policy describes the types of personal information we collect through our website at www.iris.tv and via our products and services (“Services”) and other tools that reference this Privacy Policy (collectively, the “Online Channels”). This Privacy Policy describes the types of information we obtain, how we use the information we obtain, with whom we may share it and how you may exercise your rights regarding our processing of that information. The Privacy Policy also describes the measures we take to safeguard the personal information we obtain and how you can contact us about our privacy practices.

In connection with our cloud-based video programming platform, IRIS.TV processes certain data (“Customer Content”) on behalf of and at the direction of its publishers and content owners. Customer Content includes data that is maintained and collected by IRIS.TV’s Personalization and Programming Platform that IRIS.TV may access to perform recommendations, programming, content delivery, analytics and supporting services.  This includes personal information about our publishers’ and content owners’ (collectively “Customers”) employees, customers, partners and suppliers. Our use of such data is subject to the terms of our Customer agreements. In contrast, the information we collect through our Customers’ use of our Online Channels (such as names, addresses, billing information and employee contact information) and through our offline interactions with our Customers is subject to the terms of this Privacy Policy.

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Personal Information We Obtain

IRIS.TV obtains personal information about you from various sources to provide our Services and to manage our Online Channels. You may be a visitor to our website (“Site Visitors”), a Customer who uses our Services (such as a publisher or content provider), or an end user of a Customer (“Consumer”). If you are a Consumer, we will generally not collect your personal information directly from you, or we will do so on behalf of and at the direction of our Customers. The terms of our agreement with the relevant IRIS.TV Customer and their respective privacy policies govern how IRIS.TV collects and processes Users’ personal information.

The types of personal information we obtain through our Online Channels include:

• Contact information (such as first and last name, company, email address, job title, telephone number, postal or other physical address);  
• Billing and financial information (such as name, billing address, payment details and bank account information and purchase history);
• Information you submit in connection with a career opportunity at IRIS.TV, such as contact details, information in your résumé (including work history, education and language skills) and details about your current employment;

• Location data (such as data derived from your IP address, country and zip code);
• The precise geolocation of your interacting with IRIS.TV services;  
• Clickstream data and other information about your online activities (such as IP address, information about your devices, browsing actions and video usage patterns), including across the Online Channels and third-party websites, that we obtain through the use of cookies, web beacons and similar technologies;
• Personal information contained in content you submit to us (such as through our “Contact Us” feature); and
• Other personal information we obtain through our Online Channels.

Please note that providing personal information to us is voluntary on your part. If you choose not to provide us certain information, we may not be able to offer you certain products and services, and you may not be able to access certain features of the Online Channels.

How We Use Personal Information

We use the information we obtain to:

• Provide and administer our Services (including using artificial intelligence and machine learning to stream relevant video content and provide Customers with insights about their Consumers);
• Provide Consumers with video content that may be of interest to them;  
• Process payments and fulfill orders in connection with our Services and keep you informed about the status of your order;
• Help you complete a transaction or order and provide customer support;
• Communicate with you about your account and orders (including sending emails relating to your registration, account status, order confirmations, renewal or expiration notices and other important information);
• Conduct marketing and sales activities (including sending you promotional materials, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand);
• Communicate with you about, and administer your participation in, events, programs, promotions and surveys;
• Provide training, support and consulting services;

• Manage career opportunities, including for recruitment purposes, employee onboarding and other Human Resources purposes;
• Operate, evaluate and improve our business (such as by administering, developing, enhancing and improving our Services; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities);
• Perform data analytics (such as research, trend analysis and financial analysis);
• Verify your identity;
• Protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
• Comply with and enforce relevant industry standards, contractual obligations and our policies;

• Maintain and enhance the functionality of our Online Channels and Services; and
• Respond to your inquiries.

We may anonymize or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we specify at the time of collection. We will obtain your consent for these additional uses to the extent required by applicable law.

Depending on the purposes for which personal information is used, and the context in which the data is provided, we may rely on one or more of the following legal bases:

• Performance of a contract or pre-contractual activities with Customers or a relevant party (i.e., we use personal information for the purpose of entering into business relationships with prospective Customers, and to perform the contractual obligations under the contracts that we have with such Customers);
• Our legitimate business interests (i.e., the legitimate business interests for which we balance our interests against the legitimate interests and rights of the individuals whose personal information we process);
• Compliance with a legal obligation, a court order, or to exercise or defend legal claims; or
• Your consent to the processing, which you may revoke at any time.

Cookies and Other Technologies

IRIS.TV uses cookies, web beacons (including pixels and tags), and similar technologies on our Online Channels that collect certain information about you by automated means. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

We use these automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner includes IP address and other identifiers associated with your devices, types of devices connected to our Online Channels, device characteristics (such as operating system), language preferences, referring/exit pages, navigation paths, access times, browser preferences and characteristics, installed plugins, local time zones, local storage preferences, clickstream data and other information about your online activities.

We use information collected through cookies, web beacons, web server logs and other automated means to (1) show you video content and advertisements that may be of interest to you; (2) provide relevant video content on our Customers’ websites and provide Customers with insights about their Consumers; (3) track and understand how you use and interact with our Online Channels and our Customers’ websites and services; (4) learn about your preferences and tailor our Customers’ video content around those preferences; (5) measure the usability of our Services and the effectiveness of our Customers’ content; and (6) otherwise manage and enhance our Services, and help ensure they are working properly.  

We may use third-party online analytics services on our Services, such as those of New Relic Inc., Google Analytics and Amazon Web Services. The analytics providers that administer these services use automated technologies such as cookies, web server logs and web beacons to help us analyze your use of our Services. The information collected through these means (including IP address) may be disclosed to these analytics providers and other relevant third parties who use the information, for example, to evaluate use of the Services. To learn more about these analytics services and how to opt out, please visit the relevant websites listed here:

• Google Analytics: Privacy Policy; opt-out
• New Relic: https://newrelic.com/termsandconditions/privacy
• Amazon Web Services: https://aws.amazon.com/privacy/ and https://aws.amazon.com/compliance/data-privacy-faq/ ·

When you visit our website, both we and certain third parties (such as our advertising networks, digital advertising partners and social media platforms) collect information about your online activities, over time and across third-party websites. We may use such information to provide you with video content and advertising about products and services tailored to your individual interests and preferences. To learn how to opt out of ad network interest-based advertising in the U.S., please visit www.aboutads.info/choices and www.networkadvertising.org/choices. In the European Union, please visit www.youronlinechoices.eu. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.

As indicated above and in the “Your Rights and Choices” section of this Privacy Policy, we offer you certain choices in connection with the personal information we collect about you and our interest-based advertising activities. Certain web browsers allow you to instruct your browser to send Do Not Track (“DNT”) signals to websites you visit, informing those sites that you do not want your online activities to be tracked. Our Online Channels are not designed to respond to the Do Not Track browser option.

How We Share Your Personal Information

IRIS.TV may share personal information with third parties as follows:

• Service providers. We share personal information with our service providers, including those who perform on our behalf payment processing, website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. We authorize such service providers to use or disclose the personal information only as necessary to perform services on our behalf or comply with legal requirements.
• Our Customers and third parties authorized by our Customers.  We share personal information with our Customers as necessary to provide the Services. We share data with parties directly authorized by a Customer to receive personal information. The use of personal information by an authorized third party is subject to the terms of the third party’s privacy policy.
• Corporate transactions.  In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share personal information with third parties for the purpose of facilitating and completing the transaction.
• Compliance and harm prevention. We share personal information as we believe necessary: (i) to comply with applicable laws and regulations; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of IRIS.TV, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

We also may share the information in other ways for which we provide specific notice at the time of collection and obtain your consent to the extent required by applicable law.

International Data Transfers

We transfer the personal information we collect through the Online Channels to, and store such data in, other countries in which IRIS.TV and its service providers operate, including the U.S., which may have different data protection laws than the country in which the information was provided. If we do so, we will transfer the personal information only for the purposes described in this Privacy Policy. To the extent required by applicable law, when we transfer your personal information to recipients in other countries, we will take measures to protect that information including, as appropriate, by executing data transfer agreements based on the European Commission’s Standard Contractual Clauses pursuant to article 46 of the General Data Protection Regulation (GDPR).

Your Rights and Choices

We offer you certain choices in connection with the personal information we obtain about you, such as how we use the information and how we communicate with you. To update your preferences, limit the communications you receive from us or submit a request, please contact us as specified in the How to Contact Us section of this Privacy Policy. You can also unsubscribe from our mailing lists by following the “Unsubscribe” link in our emails.

To the extent provided by the law of your jurisdiction, you may request access to the personal information we maintain about you or request that we correct, update, amend or delete your information, or that we restrict the processing of such information by contacting us as indicated below. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response.

Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward. This will not affect the lawfulness of our use of your information based on your consent before its withdrawal.

With respect to Consumer data, our Customers determine the information that we may collect (such as IP address).  We provide Customers the option to block the deployment of cookies on the relevant Online Channels.

How We Protect Personal Information

We maintain administrative, technical and physical safeguards, consistent with legal requirements where the personal information was obtained, designed to protect against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal information provided to us through the Online Channels.

Retention of Personal Information

To the extent permitted by applicable law, we typically retain personal information we obtain about you for as long as it is needed (1) for the purposes for which we obtained it, i generally means that we will keep your personal information for the duration of our relationship or as long as you keep your account open with us; or (2) to take into account applicable statute of limitation periods and comply with applicable laws, resolve disputes and enforce our agreements. As described in the “Your Rights and Choices” section above, to the extent provided by the law of your jurisdiction, you may request that we delete your information or restrict the processing of such information by contacting us as indicated below.

Additional Information

Notice to California Residents

Subject to certain limitations under California law, California residents may ask us to provide them with (1) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (2) the identity of those third parties. To make this request, California residents may contact us as specified in the How to Contact Us section below.

Children’s Personal Information

The Online Channels are designed for a general audience and are not directed to children under the age of 13. We do not knowingly collect or solicit personal information from children under the age of 13 through the Online Channels. If we become aware that we have collected personal information from a child under the age of 13, we will promptly delete the information from our records. If you believe that a child under the age of 13 may have provided us with personal information, please contact us as specified in the How to Contact Us section of this Privacy Policy.

Changes to Our Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices. We will indicate at the top of this Privacy Policy when it was most recently updated. For significant changes, we will notify you by posting a prominent notice on our website indicating at the top of the Privacy Policy when it was most recently updated. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.

How to Contact Us

If you have any questions or comments about this Privacy Policy or if you would like us to update information we have about you or your preferences, please contact us by email at privacy@iris.tv or write to us at:

IRIS.TV

453 South Spring Street, Los Angeles CA 90013