Last Updated: April 6, 2020
2. INFORMATION WE COLLECT
Quibi may collect the following categories of personal information from the sources identified below:
a. Information you actively provide to us: We collect the information you actively provide to us, which may include personal information. For example, when you create an account with Quibi, you will be asked to provide your email, year of birth, and gender. . We may also collect information you submit through other means including email lists, customer service, surveys, contests, promotions, comments directed to us, and your settings.
b. Usage and log data: We collect information when you use and interact with the Services. For example, we may collect your IP address, device type, device language setting, screen size, device identifiers, advertising identifiers,mobile carrier, browser type, and your actions in the Services, including what content you watch.
3. USE OF INFORMATION WE COLLECT
a. Use of Personal Information:
We use the categories of personal information listed above for the following purposes:
We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, where we have a legitimate interest in doing so, to protect the vital interests of you, other users’, or Quibi staff, or with your consent.
b. Use of Aggregated or De-Identified Information:
We may collect and use information that is not reasonably linked to an individual, device, or household for any purpose. This includes aggregated or de-identified personal information.
4. SHARING PERSONAL INFORMATION WITH THIRD PARTIES
We may share your personal information as follows:
a. Service Providers: We may share personal information with third-party service providers for them to facilitate services they provide to us, e.g., the use of a vendor’s software, integration with third party platforms, or embedding SDKs or tags in the App or Website. These services include things like website hosting; data storage; data analysis; personalized advertising, ad measurement and verification; conversion tracking, social sharing; payment processing; order fulfillment; information technology and related infrastructure provision; customer service; email and notifications delivery (including marketing messaging); and auditing.
b. For legal reasons: We may share personal information as we believe necessary or appropriate to comply with applicable laws and regulations; to cooperate with law enforcement; to enforce our terms and conditions; to protect our rights, privacy, safety, or property and/or that of our affiliates, you, or others; to prevent or take action regarding possible illegal activities or a violation of our policies; or for other legal reasons. These obligations may arise from laws and requests from authorities outside your country of residence.
c. In connection with a sale or business transaction: We may disclose or transfer your personal information to a potential or actual buyer in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), including any due diligence related to such a transaction, in accordance with applicable law.
d. With your consent or when you otherwise choose to share: We may share personal information with any party when we have your consent or when you otherwise choose to share such information, for example by using our social sharing functions or participating in contests (which may have their own terms).
We use organizational, technical, physical, and administrative data security measures intended to protect personal information within our organization. Note that if you allow others to access your account, they may be able to view information about or stored within your account, including what content you’ve viewed.
a. Ads for Quibi
We advertise Quibi on publishers such as Facebook, Snapchat, and YouTube. When you use Quibi or view a Quibi ad on one of those publishers, whether or not you click on it, Quibi, publishers, and other service providers that perform advertising-related services for us may collect personal information. Publishers may use personal information to optimize the kinds of ads you see and may offer choices about the way they handle personal information. For example, to learn about how Google processes your personal information in relation to serving ads and what choices you may have, visit their site here.
b. Ads on Quibi
If you are subscribed to an ad-supported plan, the ads you see may be tailored for you based in part on the personal information we collect from your use of the Services (e.g. your year of birth), as well as information we receive from third parties. Under these plans, you cannot opt out of seeing ads or from having us measure your engagement with the ads, but you can opt out of certain ad targeting based on your activity outside of the Quibi App or Website. To opt out of that kind of ad targeting, see the Choices section below.
You have the following choices when it comes to our use of your personal information:
a. Ad Targeting
Some of the publishers or other service providers that we work with may use cross-app or interest-based advertising to display ads about Quibi. Below is information on cross-app or interest-based advertising and the choices you have:
b. Ad Measurement
The App includes software that enables third parties to measure ad viewership and similar statistics. When you enable the “Limit Ad Tracking” or “Opt out of ad personalization” option on your device, user-level demographic measurement on the App will be disabled for certain vendors (e.g,. Nielsen). This will not disable ad measurement for aggregate statistical purposes. Details and instructions on how to find these settings on commonly used mobile devices can be found here.
c. Marketing Emails and Text Messages
d. Push Notifications
You can choose to receive or disable push notifications from us by adjusting your device settings. A shortcut to those options is available in the App’s settings.
8. YOUR RIGHTS
If you would like to request to access, correct, update, suppress, restrict, or delete personal information, object to or opt out of the processing of personal information, withdraw your consent for the collection, use, or disclosure of your personal information, or if you would like to request to receive a copy of your personal information (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the Contact Us section below. Please clearly describe your request. We will respond to your request consistent with applicable law.
In your request, please make clear what personal information you would like to have provided or changed, or whether you would like to have your personal information deleted. 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 you will be required to verify your identity before implementing your request. If you do not provide certain information to us sufficient to verify your identity, we may, in some circumstances, be unable to comply with our obligations or provide you with the services that you request.
We will work to comply with your request as soon as reasonably practicable or as required by applicable law. Please note that if you choose to delete Personal Information, we may need to retain certain information for purposes such as recordkeeping, security, fraud prevention,legal requirements, and/or to complete any transactions that you began prior to requesting a change or deletion.
We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods may include:
10. THIRD-PARTY ACCESS POINTS OR LINKS
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any personal information you disclose to other organizations through or in connection with the Services.
11. USE OF THE SERVICES BY CHILDREN
The App is not directed to individuals under the age of seventeen (17) and we do not knowingly collect or sell personal information from children (as defined under applicable law) without involvement and approval of a parent or guardian, unless consistent with applicable law.
12. INTERNATIONAL PROCESSING
Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Services, you understand that your information may be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.
Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA or UK standards (the full list of these countries is available here). For transfers from the EEA or the UK to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your personal information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us” section below.
13. SENSITIVE INFORMATION
Unless we request it, do not send or disclose to us any sensitive personal information (e.g., social security or social insurance numbers, copies of personal identification cards such as drivers licenses, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services, through customer service, or otherwise.
14. THIRD-PARTY PAYMENT SERVICE
16. CONTACT US
Quibi Holdings, LLC
6555 Barton Avenue
Los Angeles, CA 90038
17. ADDITIONAL INFORMATION FOR EEA AND UK RESIDENTS
Our legal bases for processing your personal information are that processing your data is:
On matters relating to the processing of personal data, EEA and UK residents may:
18. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
Effective January 1st, 2020, the California Privacy Protection Act (“CCPA”) provides its residents with certain rights. If you are a California resident, the law permits you to request that we disclose to you the following information covering the past twelve months: the categories of personal information we collected about you and the categories of sources from which we collected such personal information; the specific pieces of personal information we collected about you; the business or commercial purpose for collecting or selling (if applicable) personal information about you; the categories of third parties with whom we shared personal information about you; the categories of personal information about you that we sold and the categories of third parties to whom we sold such personal information (if applicable); and the categories of personal information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or disclosed such personal information (if applicable). Additionally, you may request that we delete personal information we have collected from you as defined under the California Privacy Protection Act (“CCPA”).
To make a request to use one of these rights, please contact us in accordance with the “Contact Us” section above. You must use the email used in your account to make the request. Alternatively, you may designate an authorized agent to make a data request to us on your behalf under the CCPA. In order for such an agent to make a request, they must provide proof of their power of attorney and valid government identification of both the requester and the agent. In some instances, we may decline to honor your request where an exception applies, such as where the disclosure of personal information would adversely affect the rights and freedoms of another California resident. Consistent with California law, we will not charge you different prices or provide a different quality of service if you use your rights unless it relates to the value of the information.
We have not “sold” personal information as defined by the CCPA. We do permit other parties to collect information through the Services and share information with other parties for business purposes. These business purposes are described above.