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NEW ID Privacy Policy

Last Updated: April 25, 2023

 

This Policy describes how NEW ID and its affiliates (collectively “NEW”, “we”, “our”, or “us”) collect, use, and disclose certain information, including your Personal Information, band the choices you can make about that information.

 

NEW is a media and entertainment company that provides content and experiences for audiences. When you use our streaming services, mobile and online applications or other products and services of our brands, visit our websites, attend our live events, view our content or advertisements, or contact our customer service (collectively, the “Services”), we may collect information from or about you.

 

NEW collects Personal Information that you provide directly, information about how you use our Services and information from third party sources. NEW uses this information to provide you with Services, understand the way you use our Services so we can improve your experience and to develop the most relevant apps, technologies, and content for you. NEW also uses Personal Information to provide customized advertising for your interests. By using any of the Services, you acknowledge the data collection practices and purposes outlined in this Privacy Policy.

 

 

 

What Information Do We Collect About You?

We collect information from and about you in connection with your use of the Services. Some of this information may be considered “Personal Information” or “Personal Data” (as defined under applicable laws) which is any information that identifies you or your device or is reasonably associated with you. We also collect, use, and disclose aggregated or de-identified information that does not reasonably identify you or your device, and is not considered Personal Information.

 

 

1. Information You Provide

Registration Information: When you create an account or profile with us, register for certain Services, complete an application form, enter contests, giveaways or competitions, attend one of our events, participate in promotions, or respond to market research surveys that we sponsor, we may ask for information such as your name, email address and password.

 

Information You Post on our Services: We may collect information when you post comments or other content to our Services, which may include your username or screenname, comments, likes, interests, status, pictures, and references to your online presence.

 

 

2. Information Collected Automatically

Device information: We may collect information from and about you, including your use and activity in our Services, your interaction with us, information about your network data, network device, or devices you use to access the Services. The information includes:

 

  • Your activity on our Services, such as title selections, shows you have watched, ads viewed (if applicable), search queries;

  • Your interactions with us such as emails, texts, and with our messages through push and online messaging channels; and

  • Your interactions with our customer service, such as the date, time and reason for contacting us, transcripts of any conversation with us, and if you call us, your phone number and call recordings;

  • Your device hardware information and other unique device identifiers, IP address, Application version, OS, OS version, cookies, and settings you use to access the Services; and

  • Your location information such as your IP address, which may be used to estimate your approximate location.

 

Log information: Diagnostic, technical, error, and usage information such as the time and duration of your use of the Services, search query terms when you enter search terms into your device in connection with the Services, and any information stored in cookies that we have set on your devices.

 

Viewing Information: We may collect information about your use of the Services and your preference including networks, channels, websites visited, and programs viewed on your devices and the amount of time spent viewing them.

 

Information From Third Parties: We may collect information from trusted third party business partners. These business partners might include companies, such as your TV or internet service provider, or other streaming media device providers who make the Services or content available on their devices, mobile phone carriers, or other companies who provide services to you. We may also collect information about you from other sources, including service providers, data licensors and aggregators, marketing companies, advertising partners, programming distributors, social media platforms, and public databases.

 

The information our business partners provide us varies depending on the nature of their services, and may include IP addresses, device IDs or other unique identifiers, information about your interests, viewing history, and your activities online.

 

 

3. Publicly or Commercially Available Information

We may also collect publicly or commercially available information, including information from social networks, and combine it with other information about your needs, interests, and preferences.

 

 

4. Your Options

You may choose to limit information you provide when our Services request it. If you choose not to provide information that is required for our Services to function, this may limit your ability to use some Services.

 

 

 

How Do We Use Your Information and Why?

We may use the information we collect as disclosed and described here:

 

We may use information to provide you with the Services. We may use your information to create, manage, and authenticate your account with us and provide you with customer support and account updates. We may use your information to complete the transactions you request, to perform our contractual obligations with you, or to ensure that our Services function properly.

 

We may use information for marketing purposes. We may use your information to market our Services, and those of third parties. This may include sending emails, push notifications, or other communications to market or advertise our products, services, features, offers, promotions, news, and events. This also may include ads for our products or services, and/or a third party’s products or services that are personalized based on information we collected from and about you. Please read the section titled “Your Rights and Choices” for information on your choices regarding how we may your information for marketing purposes.

 

We may use information to improve our products and Services. We may use your information to analyze our products and services to enhance our understanding of you for providing you with the most relevant Services. This may also include using information for testing, research, analysis, and development of our Services.

 

We may use information to maintain the safety and security of our Services. We may use your information to protect our rights, privacy, property, or safety, and/or that of our affiliates, business partners, you, or others and to comply with our legal obligations, including to detect, investigate, and prevent fraud and other illegal activities and to enforce our agreements.

 

We may use information as otherwise permitted by law. We may use your information to resolve disputes, enforce our agreements, and as otherwise required by law.

 

 

 

Who Do We Share Your Information With and Why?

We may share information inside of NEW. We may share your information internally within our business, including our subsidiaries and affiliates, to help us provide our Services or to help us process your request.

 

We may share your information in connection with a corporate transaction. We may share your information in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

 

We may share information with third parties who perform Services on our behalf. We carefully selected companies – service providers – who operates on our behalf to perform Services we outsource to them, such as marketing, research, compliance, audits, processing payments, communications, IT development, maintenance, hosting and support, and customer service operation. We may share your information with service providers to help us provide our Service.

 

We may share information with our business partners. Partners may include marketing, advertising, or other partners such as those working with us on co-branded Services or events and digital distribution partners where we make our Services available. Our partners may use your information as described in their privacy policies and procedures. This may, depending on the partner services you use, include:

 

  • Facilitating partner pre-paid promotions or collection of payment for our Services;

  • Suggesting contents and features available in our Services to you in the partner’s user interface. The suggestions are part of our Services for you and may include customized and personalized recommendations for certain contents; and

  • Sharing information from or about you with online and/or offline marketplace to analyze and improve your purchasing experiences.

 

We may share your information with sponsors and other partners for contests, giveaways, sweepstakes, and promotions. We may use your information to verify your entry into and eligibility to participate in contests, sweepstakes, giveaways, or promotions and to inform you if you have won. If your entry information will be used for any other purposes, we will disclose that in the applicable rules governing that sweepstakes, contest, giveaway, or promotion.

 

We may share information to provide advertising based on your interests. Please see the section titled “Your Rights and Choices” for information on your choices regarding our sharing of your information for advertising purposes.

 

We may share information when required by the law or to protect ourselves. For example, we will share information when it is necessary for us to comply with applicable law and rules or legal obligations, to respond to legal claims, or to protect against harm to the rights, property or safety NEW, our users, or the public.

 

We may share your information for reasons not described in this policy. We may share your information for any reasons not described in this Privacy Policy, as long as it is appropriate to carry out legitimate business activities allowed by law. In that event, we will provide prior notifications.

 

 

 

Your Rights and Choices

You have certain choices about how we use your information. We would like to make sure you are fully aware of all of your rights and choices. Every user is entitled to the following:

 

The right to access. You have the right to access, update or delete information we have on you. You have the right to request us a copy of your Personal Information.

 

The right to rectification. You have the right to request us correct any incomplete or inaccurate information we have about you.

 

The right to erasure. You have the right to request us to delete or remove your Personal Information. You can email us at privacy@its-newid.com.

 

The right to restrict processing. You have the right to request us to restrict processing of your Personal Information You have the right to object to the processing of your Personal Information on grounds relating to your particular situation if we process your Personal Information based on our legitimate interest. You have the right to object to the processing of your Personal Information for direct marketing purposes at any time.

 

The right to data portability. You have the right to request us to transmit your Personal Information, which you have provided to us in a structured, commonly used, and machine-readable format, directly to you, or to a third-party you have chosen.

 

The right to withdraw your consent. You have the right to withdraw your consent to use your information. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our Services.

 

Opt out of receiving our marketing emails: If you would like to opt-out of receiving our promotional messages, please contact us at privacy@its-newid.com. You will not be able to opt-out of messages that are considered necessary for our Services.

 

 

 

International Transfer

Please be aware that your Personal Information we collect and process may be transferred and maintained outside your home country, where that information will be processed may have lower standards of data protection than in your home country. We may transfer Personal Information to another country in order to provide our Services. When we do transfer Personal Information to other countries, we ensure appropriate safeguards are in place with appropriate security measures. The transfer of such information will be in compliance with local legislation for the cross-border transfer of data, where applicable. Any international transfer of Personal Information will be accordance with this Privacy Policy and in compliance with applicable laws.

 

 

 

Additional Information if You Are Located in California

California Consumer Privacy Act and California Privacy Rights Act: If you are a California resident, you have specific privacy rights governed by the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA) and applicable implementing regulations (collectively, “CCPA/CPRA”). The statement in this section does not apply to NEW ID employees or job applicants. If you are a NEW employee or job applicant who resides in California, please read the California Employee Privacy Notice  here.

 

Right to Know: You have the right to request us to disclose information to you about a report showing the Personal Information collected, shared, and sold about you in the past 12 months.

 

Right to Opt-Out of Sale of Your Personal Information: You have the right to opt-out of the “sale” or “sharing” of your Personal Information to third parties. “Sale” means the disclosure of personal information to a third party in exchange for money or other value. “Sharing” means the disclosure of Personal Information to a third party for targeted marketing.

 

Right to Deletion: You have the right to request that we delete any Personal Information collected from you.

 

Right to Non-Discrimination: We shall not discriminate against you based on your exercise of any of your CCPA/CPRA rights.

 

 

We may require additional information to verify your identity or to verify that your authorized agent has the authority to make a request on your behalf before responding to a CCPA /CPRA rights request. We will use good faith efforts to respond to your verifiable request within forty-five (45) days after its receipt. If we need more time (up to ninety (90) days), we will inform you of the reason and the needed extension period in writing.

 

 

1. Categories of Personal Information We Collect

We may collect (or may have collected during past twelve (12) months the following categories of Personal Information about you. The categories and examples provided in the list below are those defined in the CCPA. It does not mean that all examples of such category of Personal Information were in fact collected but reflects our good faith belief that to the best of our knowledge that some of that information from the applicable category may have been collected.

 

A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account username, screen name, password, Social Security Number, driver's license number, or other similar identifiers: YES

 

B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)). A real name, signature, Social Security Number, physical characteristics or description, address, telephone number, passport number, driver’s license number, insurance policy number, education, employment, employment history, bank account number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories: NO

 

C. Protected classification characteristics under California or federal laws. Age (forty (40) years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, generic information (including familial generic information): NO

 

D. Commercial Information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies: NO

 

E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, voiceprints, iris or retina scans, key stroke, gait, or other physical patterns, sleep, health, or exercise data.: NO

 

F. Internet or other similar network activity. Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement including user generated content: YES

 

G. Geolocation data. Physical location or movements: NO

 

H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information: NO

 

I. Professional or employment-related information. Current or past job history or performance evaluations: YES

 

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. §1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records: NO

 

K. Inferences drawn from other Personal Information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes: NO

 

 

Under the CCPA/CPRA, Personal Information does not include:

 

  • Publicly available information from governmental records.

  • De-identified or aggregated consumer information.

  • Information excluded from the CCPA/CPRA’s scope, such as:

 

(1) Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPPA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data.

(2) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”), or California Financial Information Privacy Act (“CalFIPA”), and the Driver’s Privacy Protection Act of 1994 (“DPPA”).

 

 

2. Sources of Personal Information

We obtain the categories of Personal Information listed above from the following categories of sources:

  • Directly from you. From forms, subscriptions, or purchase orders you complete on our Services.

  • Indirectly from you. From observing your activities in our Services.

  • Automatically from you. Through cookies we set on your device.

  • From third parties. From marketing and advertising companies, social networking companies, and service providers.

  • From publicly available sources. From online database searches.

 

 

3. Use of Personal Information

As described in more detail in the section titled “How Do We Use Your Information and Why?” of our Privacy Policy, we may use or disclose Personal Information we collect for the following business purposes or commercial purposes:

 

  • To provide our Services

  • For marketing purposes.

  • To provide you with ads or information that may be interest to you.

  • To improve our products and services.

  • To maintain the safety and security of our Services.

  • To carry out our legal obligations.

  • For testing, research, analysis, and development of our product and services.

  • As described to you when collecting your Personal Information or as otherwise set forth in the CCPA/CPRA.

  • For internal administrative and auditing.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

 

 

4. Disclosure of Personal Information

As described in more detail in the section titled “Who Do We Share Your Information With and Why?” of our Privacy Policy, we may use or disclose Personal Information to a third party for the above purposes. We may share your Personal Information with the following categories of third parties:

  • Our affiliates and subsidiaries.

  • Service providers.

  • Business partners.

  • Payment partners.

  • Sponsors and other partners for contests and promotions.

  • In connection with corporate transactions.

  • Third parties to whom you or your agent authorize us to disclose your Personal Information in connection with products or services we provide to you.

  • Law enforcement or others if required by law.

 

 

From the list in the above sub-section titled “Categories of Personal Information We Collect”, we may use or disclose and may have used or disclosed during past twelve (12) months the following categories of Personal Information for the above purposes:

 

  • Category A: Identifiers.

  • Category F: Internet or other similar network activity.

  • Category I: Professional or employment-related information
     

When we disclose Personal Information for a business purpose or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

 

 

5. Sale of Personal Information

The CCPA/CPRA broadly defines the term “sale” or “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information by the business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing Personal Information and it does not necessarily mean we received any money in exchange.

 

As defined by the CCPA/CPRA, we may “sell” or “share” Personal Information to or with our affiliates and subsidiaries, service providers, business partners, payment processors, sponsors, and other partners for contests and promotions, other companies in connection with corporate transactions, and third parties to whom you or your agent authorize us to disclose your Personal Information in connection with products or services we provide you.

 

As required by the CCPA/CPRA, we provide a link on our website, mobile and online application, titled “DO NOT SELL OR SHARE MY PERSONAL INOFORMATRION” or “Your Privacy Choices” button.

 

 

6. Personal Information of Minors Under 16 Years of Age

NEW does not knowingly collect, maintain, disclose, or otherwise process Personal Information from minors under the age of sixteen (16) through our Services.

 

We do not sell your Personal Information if we actually know you are less than sixteen (16) years of age, unless we receive affirmative authorization (the “right to opt-in”) from either you if you are between thirteen (13) and sixteen (16) years of age, or the parent or guardian if you are less than thirteen (13) years of age. If you opt-in to the sale of Personal Information, you may opt-out of future sales at any time. To exercise the right to opt-out, you or your authorized representative may submit a request to us by contacting us.

 

 

7. Do Not Track

Our websites and apps are not designed to respond to “do not track” requests from browsers.

 

 

8. “Shine the Light” and “Online Eraser” Laws

Under the California Civil Code §1798.83 (California’s “Shine the Light” law), California residents may request us once a year, free of charge, information about sharing their Personal Information in the proceeding calendar year with third parties for those third parties direct marketing purposes. If you would like to request more information under the California’s Shine the Light law, you can contact us using the contact information provided below.

 

 

Under the California Business and Professional Code §22581 (California’s “Online Eraser” law), California residents under the age of eighteen (18) who are registered user of online sites, services, or applications where this policy is posted may request and obtain removal of content of information you have publicly posted. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances. If you would like to request more information under the California’s Online Eraser law, you can contact us using the contact information provided below.

 

 

 

How Do We Protect Your Information?

We are committed to protecting your information. We have adopted commercially reasonable technical, administrative, and physical security measures designed to provide protection for your information against loss, misuse, unauthorized access, and alteration. The security of your information is important to us, but please note that no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

 

 

 

Cookies and Other Similar Technologies

We, and our third parties that provide content, advertising, or other functionality in our Services, may use cookies and/or other technologies in certain areas of our Services.

 

1. Cookies

Cookies are small files paced on your device. They enable the entity that put the cookie on your device to recognize you across different websites, services, and browsing sessions. Cookies serve many useful purposes.

  • Cookies can remember your sign-in credentials, so you don’t have to enter those credentials each time you sign-in to our Services.

  • Cookies help us and third parties understand which parts of our Services are the most popular because they help us to see which pages and features visitors are accessing and how much time they spend on the pages. Studying this information helps us to improve our Services.

  • Cookies help us and third parties understand which ads you’ve seen so you don’t get the same ad each time you access a Service.

  • Cookies help us and third parties to provide you with relevant content and advertising by collecting information about your activity in our Services, other websites and apps.

 

When you use a web browser to access the Services, you can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the help menu of your browser to learn how to change your cookie preferences. Your device operating system may contain additional cookie controls. Please note that some of our Services are designed to work using cookies, so disabling cookies may affect your ability to use those Services or certain parts of them.

 

2. Beacons

We and our third parties may use technologies called beacons or pixels that communicate information from your device to a server. Beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you’ve viewed particular content or a particular email message, and determine the time and date on which you viewed the beacon and the IP address of your device. We and certain third parties use beacons for a variety of purposes, including to analyze the use of our Services and, along with cookies, to provide content and ads that are more relevant to you.

 

3. Other Local Storage

We and our third parties may use other kinds of local storage technologies, such as Local Shared Objects (also referred to as Flash cookies) and HTML5 local storage, in connection with our Services. These technologies are similar to the cookies discussed above. They are stored on your devices and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your devices from standard cookies, so you might not be able to control them using standard browser tools and settings.

 

4. GeoIP Location

We and our third parties may use technologies called geoIP that communicate information about the country you are located. GeoIP is the method of locating your device’s geographic location by identifying that device's IP address.

 

 

 

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you if any changes to this Privacy Policy are material and, where required by applicable law, we will obtain your consent. Notice may be made by posting a prominent notice on our websites, applications and Services, or by other means complying with applicable laws. Your continued use of the Services indicates your acceptance of the modified Privacy Policy.

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