Effective Date: July 22, 2019
2. Information We Collect
Information you provide directly to us
We collect information you provide to us when you register or pay to use our Service, access various content or features, or directly contact us, including your name, email address, phone number, birth date, credit card information, billing address, ZIP code, and other information. We may also collect information you provide to us when you set your communication preferences, participate in surveys or online promotions, and information you provide to us for publication, including your user name, comments, public profile information, and postings to third-party social media sites through the Service.
Information collected automatically
Like most websites, we automatically receive and record certain information about our users' behavior when using our Service, including your IP address, device, browser type and operating system, location, activity on the Service including information about the videos you watch and links you click, page views, device identifiers or other unique identifiers, referral URLs, ad data, network and carrier information, standard server information, and information collected through cookies, pixel tags, web beacons and other similar technologies. "Cookies" are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device's acceptance of cookies, but this may prevent you from taking advantage of some of our features. We respond to "Do Not Track" signals to the extent possible.
Our advertising partners may also transmit cookies to your browser or device, when you click on ads that appear on the Services.
To the extent permitted by applicable law, we may collect information about you from third parties, including social media services, interactive applications from co-branded partners and websites, and commercially available sources such as data aggregators and public databases. Information we collect from these sources may include your name, contact information, transaction history, demographic data, website navigation data, and your use of certain applications. If you access our Service through a social media service or connect your social media account to our Service, we may collect your user ID and/or username and password for that service, and any information or content the social media service may share with us according to the information sharing practices of that service.
We may combine the information we collect about you to help improve our communications to you and to inform the development of content, products, and features on our Service.
3. Use of Information
We generally use the information we collect about you for the following business purposes:
- Provide the Service
- Communicate with you, including for promotional or customer support purposes
- Customize the content, advertisements, and recommendations you see when using the Service
- Conduct research
- Identify content you share
- Prevent potentially illegal, prohibited, or harmful activities
- Compile aggregate data for business purposes
- Improve the Service
We only use payment information, such as credit card numbers, as necessary for completing transactions, such as processing payments from a subscriber, or as otherwise required by law. We use a third-party payment processor to complete transactions.
4. Sharing of Information
We will not trade, rent, or sell your Personal Information to third parties, unless you ask or authorize us to do so. However, third-party service providers, including business partners, social networking services, advertisers, and other companies that are not affiliated with the Service, may have access to Personal Information as explained further below.
- We may share your contact information with third party marketing partners, but will not do so without either obtaining your consent or providing you with an option to opt-out.
- We may share your contact information and other information about you with third party vendors that help us with specialized services, including customer support, payment processing, account management, email and text message deployment, business analytics, marketing, suppression list management and data processing. These third parties are allowed to use your information to help us provide our services and not for any other purpose.
- Authorized third party service providers may also collect non-contact information about your visits to our Service with cookies, web beacons and other similar technologies that may be used to develop insights and product improvements based on your interests.
- When you choose to enter a promotion, and in accordance with the terms and conditions of the promotion, your information may be disclosed to our sponsors and third parties who help design, administer and implement the promotion. Your information also may be disclosed as required by law, such as on a winners list. Further, by entering a promotion, you are agreeing to the official rules that govern that promotion, including allowing our sponsors to use your name, voice, and likeness in advertising and marketing associated with the promotion in accordance with applicable law. All terms applicable to the particular promotion will be made available to you at the time you enter the promotion.
- We may share anonymized information about our users with advertisers so that they can measure the effectiveness of advertisements viewed on our Service. For example, we may tell advertisers the number of users who clicked on a particular advertisement. We also may use technology to deliver advertising to you on other websites based on email address or other Personal Information you provide to us or through the use of information we received from third parties.
- Information collected about your interactions with audio and video content, including video content that you have watched, may be shared with third parties, including social networking services and audience measurement and market research services.
- We may share your information in connection with a corporate transaction, such as the sale of the Service, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
- We may disclose information about our users, including contact information, to respond to subpoenas, court orders, legal process, and other law enforcement measures, and to comply with other legal obligations, such as FCC requirements, in our sole judgment.
- We may share aggregated or anonymized information with third parties, to help us develop content and services we hope will interest you or to help these third parties develop their own products and service offerings including targeted marketing.
- We may share any information from or about you with any party when we have your consent or when you otherwise choose to share such information. Also, certain functions within the Service may give you the option to share information about your activities on the Service, for example, by email, text message, social networking, or other sharing function.
5. Your Choices
You may access certain content and features on the Service without providing Personal Information; however, in some instances, certain information or services can only be provided to you if Personal Information is provided. If you elect not to provide such information, you may not be able to access certain content or information.
You have various options for expressing your preferences regarding our newsletters and other promotional communications. For example, you may opt out of receiving promotional email or text communications by following the instructions contained in any such communication. Please note that even if you opt not to receive promotional communications, we may still send you communications relating to your use of the Service, such as administrative messages, service announcements, or terms and conditions of your account.
While each browser is different, browsers generally provide you options to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies periodically.
6. Security and Retention
We have adopted a variety of technical, administrative and physical procedures to collect, manage, maintain and store user information in a manner designed to help protect your information from loss, misuse, unauthorized access, and alteration. Despite these efforts, no data transmission or storage can be guaranteed to be 100% secure. We want you to feel confident using our Service, but we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Please refer to the U.S. Federal Trade Commission's website for information on how to protect yourself from identity theft.
7. Account Access
You can access, review, correct, update, delete or modify your registration or subscription profile information and modify your marketing preferences online by signing into your account and visiting the appropriate account management sections of our website or mobile application, or by submitting a request to [email protected] If you are in the European Economic Area ("EEA"), you can also exercise your right to data portability.
For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
8. For California Residents
Beginning January 1, 2020, if you are a resident of California, you will have additional rights under the California Consumer Privacy Act (the "CCPA") with respect to your Personal Information, as outlined below.
For this section, we use the term "Personal Information" as it is defined in the CCPA, but "Personal Information" generally means information that can be used to identify or be linked with an individual or household. For the complete definition of Personal Information, please refer to the CCPA.
Your Right to Request Personal Information: If you are a resident of California, the CCPA provides you certain rights to your Personal Information, including the following:
- The right to request the specific categories of Personal Information that we have collected from you. We will provide this information organized according to the chart below titled "Categories of Personal Information Collected."
- The right to request the categories of your Personal Information that we have collected and sold and the categories of third parties to whom we sold your Personal Information, organized by category or categories of Personal Information for each third party to whom we sold your Personal Information.
- The right to request the categories of your Personal Information that we have collected and disclosed for a business purpose and the categories of third parties to whom we disclosed your Personal Information for a business purpose, organized by category or categories of Personal Information for each third party to whom we disclosed your Personal Information for a business purpose.
Accordingly, to request the categories of your Personal Information that we may have collected, sold, or disclosed for a business purpose, please contact us at [email protected] and provide your name, email address, and mailing address. We will provide this information within 30 days of your request.
Sale of Personal Information
We have not sold or disclosed for a business purpose your Personal Information.
Personal Information of Children: We do not knowingly collect or solicit Personal Information from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Information, please contact us at [email protected]
We Will Not Discriminate against You for Exercising Your Rights under the CCPA: We may not discriminate against you because you exercised your rights under the CCPA. We may not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services. Exercising your rights under the CCPA will not affect the price, rate, or level of quality of the goods or services you receive.
If you have any questions about this section or whether any of the following applies to you, please contact us at [email protected]
9. EEA Visitors
While our Service can be viewed internationally and we welcome visitors and registered users from other countries, our computer systems are currently based in the United States. Therefore, all Personal Data will be processed by us in the United States. Recount Media, Inc. will be the data controller for the Personal Data processing described in this Policy. For this Section, we use the terms "Personal Data" and "processing" as they are defined in the GDPR, but "Personal Data" generally means information that can be used to individually identify a person, and "processing" generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.
Our contact details are:
12 W 21st Street
New York, NY 10010
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our "legitimate interests" or the legitimate interest of others, as further described below.
- Legitimate Interest: We process Personal Data when it is in our, or a third party's, legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, we have a legitimate interest in:
- Providing you with the website and Service
- Notifying you about changes to the website or Service
- Marketing of our products and Services
- Understanding how our customers use our Service
- Understanding and responding to customer feedback
- Researching and analyzing the services our customers want
- Improving our Service
- Customizing our offers
- Providing security over our business and who we trade with
- Developing and maintaining relationships with vendors, partners and other companies and dealing with individuals who work for them
- Consent. In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
- Other Processing Grounds. We may also process your Personal Data when we are required to do this by law. This includes the following circumstances:
- to prevent and detect fraud
- tax related purposes
- disclosures to law enforcement and other regulatory or government agencies in response to a legally binding request or warrant.
- Payment processors
- Fraud prevention service providers
- Ad networks
- Analytics service providers
- Staff augmentation and contract personnel
- Hosting service providers
- Co-location service providers
- Telecommunications service providers
If you have any questions regarding the legitimate interests you can contact us at [email protected]
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email [email protected] Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about the Recount's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
If you wish to exercise these rights, please contact us at:
12 W 21st Street
New York, NY 10010