Privacy Policy

Dated: July 1, 2024

1. YOUR RIGHTS AS A CONSUMER

At iSpot.tv, Inc. (the “Company”) we respect your privacy rights as a consumer (“Consumer”) under the data privacy and security laws including, but not limited to, the California Consumer Privacy Act of 2018, as revised by the California Privacy Rights Act of 2020, and the associated regulations effective March 29, 2023, (the “CCPA/CPRA”). We are committed to protecting your rights to:

1. Delete personal information collected from or about you (“Right to Delete”).
2. Correct inaccurate Personal Information collected and maintained about you (“Right to Correct”).
3. Know what personal information is being collected about them, to access that personal information, and to know what personal information about you is being sold or shared and to whom (together called the “Right to Know”).
4. Depending on your jurisdiction, Opt-out of the Sale or Sharing or Targeted Advertising of your personal information (“Right to Opt-out of Sale/Sharing/Targeting”).
5. Limit use and disclosure of sensitive personal information to what is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests such goods or services (“Right to Limit”).
6. Not be discriminated against for exercising your rights (“Right to No Discrimination”).

This document provides you with a description of our business practices, both online and offline, regarding the collection use, disclosure, and sale of personal information and of the rights of Consumers regarding their own personal information.

The terms used in this policy have the meanings used in the CCPA/CPRA.

2. PERSONAL INFORMATION WE COLLECT, SELL, SHARE, AND OTHERWISE DISCLOSE

The CCPA/CPRA defines personal information as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”

See the chart below for the categories of personal information we have collected over the preceding 12 months, the retention period for each category, and the categories of sources of the information.

Business or Commercial Purpose(s) for Collecting personal information.

We collect the categories of personal information described above for the following business or commercial purposes:

• providing our products and services
• personalizing customer experience
• business operations
• maintaining and servicing accounts
• providing customer service
• processing and fulfilling orders
• processing payments
• advertising and marketing
• recognizing customers across multiple touchpoints
• processing employment applications
• detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity
• troubleshooting, improving service, analyzing performance, fixing errors, and improving the usability and effectiveness of services
• quality control and monitoring
• internal technological research and development
• identity verification
• other similar purposes:
• collection of employment-related information including for administering employment benefits

We may also disclose personal information in the following situations:

• Business transfers as part of a merger, acquisition, bankruptcy, or other transaction: The Company may transfer to a third party personal information as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of the Company.
• Legal compliance and law enforcement: We may be required to disclose personal information in limited circumstances, for example, to respond to a subpoena or similar judicial process, to comply with state, federal or local laws, to exercise or defend legal claims or, to the extent required by law, to provide information to law enforcement agencies.

3. HOW TO EXERCISE YOUR RIGHTS TO DELETE, CORRECT, AND KNOW

1. Submitting Requests

   Your Right to Delete, Right to Correct, and Right to Know can be exercised by submitting a request to us by:

   • sending an email to privacy+ace@ispot.tv.
   • calling the following number 1-855-316-2377

   Our Company uses a two-step process to complete any online Right to Delete request (but not for any other type of verifiable request). If you submit an online Right to Delete request, we will contact you to confirm that you would like your personal information deleted.

2. Requests to Know

   You have the right to request, up to two times per year, that we disclose the following information to you about our collection and use of your personal information:

   • the specific pieces of personal information we have collected about you. You may also request a copy of specific pieces of personal information that we have collected about you. Please note that “specific pieces of information” do not include data generated to help ensure security and integrity or as prescribed by regulation.
3. Verifying Requests to Delete, Correct, or Know

   We may not grant your request if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. We will attempt to verify your request with the information you provide and the information that we already have about you. For this reason, your request must both:

   • provide sufficient information that allows us to reasonably verify you are the consumer about whom we collected personal information or an authorized representative; and
   • describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.

   If you have a password-protected account with our Company, we may require you to verify your identity through our existing authentication practices for the account. As an additional security measure, we shall also require you to re-authenticate yourself before deleting, correcting, or disclosing your personal information.

   We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request. Only you, or your properly authorized agent, may make a request related to your personal information. To be certain that anyone claiming to make a request on your behalf has been properly authorized by you, we may require additional information, including:

   • proof that you gave the agent the signed authorization to submit the request
   • require you to verify your own identity directly with us.
   • otherwise directly confirm with us that you have provided your authorized agent permission to submit the request.

4. RIGHT TO OPT-OUT OF SALE OR SHARING OF PERSONAL INFORMATION

Company name sells or shares personal information to third parties. You have the right at any time to direct us not to sell or share your personal information to third parties (this right is referred to as the “Right to Opt‐out.”). In addition to using the “Do Not Sell My Personal Information,” link on our website or here in our privacy policy link to “Do Not Sell” form, you may submit a request to exercise your Right to Opt-out as follows:

• call us toll-free at 1-855-316-2377
• by email at privacy+ace@ispot.tv
• in person at our place of business at 15831 Ne 8th St. Bellevue, WA 98008
• by mail at 15831 Ne 8th St. Bellevue, WA 98008

Only you, or your properly authorized agent, may make a Right to Opt-out request using the method(s) provided above. If you change your mind after making an opt-out, you may contact us at any time by the method(s) listed above or by our contact information below to request to allow us to sell and share your personal information (this is known as requesting to “opt-in”). We are required by the CCPA/CPRA to use a two-step opt-in process, so that if you submit a request to opt-in, we will contact you separately to request additional confirmation of your request.

5. ADDITIONAL INFORMATION REGARDING CHILDREN UNDER 16 YEARS OF AGE

Exercising Consumer Rights: A parent or guardian may make a Consumer Rights request on behalf of their child under the age of 16. In the case of a request to exercise the Right to Delete or the Right to Know on behalf of a child under the age of 13, we provide additional safeguards to confirm that you are the parent or guardian of that child. If you are making a request for a child under 13, please indicate this in the submission of your request or contact us using our contact information provided below so that we can provide you with further instructions on how to comply with data privacy requirements.

Sale or sharing of children’s personal information: iSpot.tv does not knowingly sell or share the personal information of children under 16 years of age.

6. NON-DISCRIMINATION

We will not discriminate against you for exercising any of your data privacy rights. We will not unlawfully:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
• Retaliate against an employee, applicant for employment, or independent contractor for exercising their rights under this title.

7. CALIFORNIA “SHINE THE LIGHT” LAW

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please follow the instructions found at https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=1798.83.&lawCode=CIV.

8. CHANGES TO OUR PRIVACY NOTICE

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

9. CONTACT INFORMATION

If you have any questions or concerns about our privacy policies and practices, please do not hesitate to contact us as follows:

• by email at privacy+ace@ispot.tv
• in person at our place of business.
• by mail at 15831 Ne 8th St. Bellevue, WA 98008.