About This Policy
This Policy, more specifically, is intended to provide consumers with information about how we collect, use, disclose, retain, and safeguard certain of the personal information we gather about them such as through the:
- Use of our websites, including mobile websites, applications (collectively, the “Site”)
- Phone and email communications
- Social media interactions, such as through Instagram and LinkedIn
- Viewing our online advertisements or emails
It also describes options consumers may have concerning their personal information.
Personal Information We Collect
As described below, we may collect or have collected in the preceding 12 months the following categories of personal information (“PI” or “personal information”). We may add to the categories of PI we collect and the purpose(s) we collect and use it. In those cases, we will inform and update this section of the Policy.
- Geolocation data – such as location information while using one of our apps.
- Audio, electronic, visual, thermal, olfactory, or similar information – such as identifiable information obtained about you from voicemail messages.
Personal information does not include certain categories of information, such as publicly available information from government records, and deidentified or aggregated consumer information.
We retain your personal information for as long as necessary to provide you information, products and services and in accordance with the Company’s data retention schedule, unless we have or deidentified or deleted your personal information in response to a request to delete. We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations, or as permitted or required by applicable law. We may also retain your Personal Information in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we process your personal information; and applicable legal requirements.
Purposes We Collect and Use Personal Information
We collect and use your PI for the following business or commercial purposes. We may change or add to the purposes we collect PI. In that case, we will inform you and obtain your consent when required by law.
- To review, improve, and monitor our website.
- To manage our recruiting efforts and employment and workforce relationships. These activities include, for example, sourcing and processing employment applications..
Sources of Personal Information We Collect
You. We may collect personal information that you provide during your interactions with us, such as through our Site, by email, or when you communicate with our associates online or by phone. We collect information when you are an applicant for employment with us and employed by us.
- Certain third parties. In the course of performing our services, we or third parties on our behalf may conduct research and other activities resulting in the collection of PI about you.
Disclosures of Personal Information.
We do not sell or share your personal information to third parties. We also do not use or disclose your sensitive personal information for purposes that, with limited exceptions, are not necessary in order to provide our products and services as are reasonably expected by an average consumer requesting those goods and services. We also do not have actual knowledge that we have sold personal information of minors under age 16.
We may, however, disclose your personal information with services providers and contractors who help us provide the products and services, such as, shipping, payment processing, marketing and advertising, email, text and other communications, applications, sales, business and inventory support, photography, and website, software, platform, cloud, data storage and other technical services.
We may also disclose your personal information if necessary to: (1) comply with federal, state, or local laws; (2) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; or (4) exercise or defend legal claims.
Lastly, we may transfer to a third party personal information as part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of or acquires all or part of the assets of our business.
Of the categories of PI noted above, during the past 12 months, we disclosed the following:
|Categories of Personal Information Disclosed||Categories of Third Parties to Whom Disclosed|
Characteristics of protected classifications under California or federal law
Internet or other electronic network activity
Audio, electronic, visual, thermal, olfactory, or similar information
Professional or employment-related information
Sensitive personal information
Cookies, Tracking, and Certain Communications.
Cookies. As is true of most websites, we gather some PI automatically and store it in log files. Small files called “cookies” may be attached to your Web browser. These files identify your browser and save information such as passwords so that websites can recognize you. This information also may include the Internet Protocol (IP) address, browser type, language, internet service provider (ISP), referring and exit page, operating system, and date/time stamp. In addition to the purposes above, we use this PI to understand and analyze trends, to administer the Site, to learn about user behavior on the Site, and to gather demographic information about our user base as a whole. To monitor use of the Site and improve its quality, we may compile statistical information concerning the use of the Site through analytics services, such as those provided by Google Analytics. Examples of this information may include: the number of visitors to the Site or to sections or pages within the Site, patterns of traffic flowing through the Site, length of time spent on the Site, or in sections or pages of the Site, the other sites that refer visitors to the Site, the pages of the Site that visitors frequently use as entry and exit points, utilization of the browser and operating systems and versions used by visitors to the Site. We also may use this PI in our marketing and advertising services.
Do Not Track. “Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our Site is not configured to detect Do Not Track signals from a user’s computer, we are unable to respond to Do Not Track requests.
Our Sites and Children
We do not knowingly collect or solicit PI from children under 13 years of age. We are concerned about the safety of children when they use the Internet and will never knowingly request PI from anyone under the age of 13. If the parent or guardian of a child under 13 believes that the child has provided us with any PI, the parent or guardian of that child should contact us and ask to have this PI deleted from our files. If we otherwise obtain knowledge that we have PI about a child under 13 in our files, we will delete that information from our existing files so that it is not in retrievable form.
While we use reasonable measures to protect our Site and your information, the Internet is not 100% secure. The measures we use are reasonable for the type of information we collect. We cannot guarantee use of our Site is 100% secure. We encourage you to use caution when using the Internet.
This Policy is governed by the laws of the State of California, without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Policy shall lie exclusively with the state and federal courts within California. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.
Notice to Site Users Located Outside the U.S.
The Company operates in accordance with the laws of the U.S. When you access our Site from outside the U.S., we may transfer the PI that we collect from you to a location outside of your jurisdiction, including the U.S. The data protection laws in these jurisdictions may not provide you with the same protections as those of your jurisdiction. By using this Site, you acknowledge that these laws may provide a different standard of protection and you consent to the transfer of your personal data to other jurisdictions, including the U.S.
If you have additional questions, you may call us at 310.557.5100] or reach us by email at CPRA@saban.com. You can write to us at: 11301 W. Olympic Blvd., Ste #121-601, Los Angeles, CA 90064 USA.
Changes to this Policy
Effective Date: January 1, 2023
From time to time we may change our privacy policies. We will notify you of any material changes to our Policy by posting an updated copy on our website. Please check our Site periodically for updates.
Notice to California Residents
Shine the Light. If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of the Company to third parties for the third parties’ direct marketing purposes. Requests may be made one time per calendar year. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we disclosed customer information for the immediately prior calendar year (e.g., requests made in 2022 will receive information regarding 2021 sharing activities). You may submit your request using the contact information in this Policy.
Eraser Law. If you are a California resident under the age of 18, and a registered user of any Site where this Policy is posted, California law permits you to request and obtain removal of content or information you have publicly posted. You may submit your request using the contact information in this Policy. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
California Consumer Privacy Act. The section concerning the California Consumer Privacy Act (“CCPA Section”) applies solely to individuals who are residents of the State of California (“consumers” or “you”) as required under the California Consumer Privacy Act, as amended (“CCPA”). This CCPA Section describes our policies and practices regarding the collection, use, and disclosure of personal information we collect about you, including personal information we obtain when you access or use the Site, or through other channels including but not limited to visiting one of our locations, phone and email conversations, attending our events, social media interactions on our websites and other third party websites such as social media sites, viewing our emails, or through our authorized services providers.
Please read this CCPA Section carefully before using the Site or submitting information to us. By accessing or visiting the Site, you indicate your understanding that the collection, use, and sharing of your information is subject to the terms of this CCPA Section.
IF YOU DO NOT CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS CCPA SECTION, PLEASE DO NOT PROVIDE US WITH SUCH INFORMATION.
- the categories of personal information,
- the categories of sources from which the personal information is collected,
- the business or commercial purpose for collecting, selling, or sharing personal information, if applicable,
- the categories of third parties to whom the business discloses personal information, and
- the specific pieces of personal information the business has collected about you.
Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
Right To Request Deletion Of Your Personal Information. You have the right to request that we delete the personal information we collected or maintained about you. Once we receive your request, we will let you know what, if any, personal information we can delete from our records, and we will direct any service providers and contractors with whom we disclosed your personal information to also delete your personal information from their records.
There may be circumstances where we cannot delete your personal information or direct service providers or contractors to delete your personal information from their records. Some of these instances include, but are not limited to, if we need to:
- Complete the transaction for which the PI was collected, provide a good or service requested by you, or reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform a contract between the Company and you.
- Help to ensure security and integrity to the extent the use of the consumer’s PI is reasonably necessary and proportionate for those purposes.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- Engage in public or peer-reviewed scientific, historical, or statistical research that confirms or adheres to all other applicable ethics and privacy laws, when the Company’s deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent.
- To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company and compatible with the context in which the consumer provided the information.
- Comply with a legal obligation.
Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
Right to Request Correction. You have the right to request that the Company correct any inaccurate personal information we maintain about you, taking into account the nature of that information and purpose for processing it. Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. We will not discriminate against you for exercising any of your rights under the CCPA, as described above. This includes, but is not limited to: (A) denying good or services to you; (B) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (C) providing a different level or quality of goods or services; or (D) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. It also includes an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of
their CCPA rights.
Submitting Consumer Rights Requests
How to submit. To submit a California Consumer Rights request as outlined in this CA Addendum, please contact the Company by calling us at [310-557.5100] Monday-Friday from 9am – 6pm PST, emailing us atCPRA@saban.com, or using our contact form. We reserve the right to only respond to verifiable consumer requests to know, delete, or correct. A verifiable consumer request is one made by any individual who is:
- the consumer who is the subject of the request,
- a consumer on behalf of the consumer’s minor child, or
- the authorized agent of the consumer.
What to submit. If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of a consumer. In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive PI to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable consumer request does not require you to create an account with us.
Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. We will not use the PI we collect from an individual to determine a verifiable request for any other purpose, except as required or permitted by law.
Our response. We reserve the right to charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will attempt to notify you as to why we made that decision and provide a cost estimate before completing your request. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.
Opt-out preference signals
We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. With respect to personal information collected on and after January 1, 2022, and to the extent expressly permitted by applicable regulation, you may request that such disclosures cover a period beyond the 12 months referenced above, provided doing so would not require a disproportionate effort by us. The response we provide will also explain the reasons we cannot comply with a request, if applicable. To the extent permitted by the CCPA, we will respond to no more than two requests during any 12-month period.
Authorized Agent. You may authorize a natural person or a business (the Agent) to act on your behalf with respect to the rights under this CA Addendum. When you submit a Request to Know, Correct, or Delete, the Agent must provide proof that you gave the Agent signed permission to submit the request, and you either must (i) verify you own identity with the business or (ii) directly confirm with us that you provide permission to the Agent. However, these steps are not required when you have provided the authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.
Questions. If you have questions about this CA Policy, please contact us as described above in the Policy.
4856-7021-9318, v. 1