Last Updated: January 1, 2020
We (Quibi Holdings, LLC, or “Quibi”) collect, use, and otherwise process various kinds of information from or about you or your device (“personal information”) to provide you with our Services. As used in this Privacy Notice, the “Services" means the personalized service provided by Quibi for discovering and watching Quibi content, including all features and functionalities, recommendations and reviews, the mobile applications (“App”), the website (“Website”), user interfaces, marketing campaigns, social features, as well as all content and software associated with our service (collectively, including the App and Website, the “Services”).
We may use all personal information in the manner described in this Privacy Notice or as otherwise permitted by law.
If you do not consent to the collection and use of personal information in accordance with this Privacy Notice, then do not use the Services.
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, if you submit your email address to us to receive updates about our service, we’ll store that email to provide that service. We may also collect information you submit through other means including customer service, surveys, contests, promotions, comments directed to us, or 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, fonts, browser type, your actions in the Services, and viewing data.
d. Data from other parties: We work with other parties to support our services, better reach potential users, to monetize our service, and other reasons as described below. These parties may send us information about you, your device, or browser (such as demographics and online history) for the purposes described in this Privacy Notice. For example, we may receive information on when you click on the links in the emails we send you so we can better optimize our messaging.
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, or with your consent to the extent required by law.
b. Use of Aggregated or De-Identified Information:
We may collect and use information that is no longer reasonably linked to an individual, device, or household for any purpose. For example, we may aggregate or de-identify personal information and analyze the resulting statistical information to improve our services.
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. These services include things like website hosting; data storage; data analysis; personalized advertising, measurement and verification; 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. In general
Advertisers (including Quibi), advertising technology companies, and/or service providers that perform advertising-related services for Quibi and our business partners use personal information in order to tailor ads, measure ad effectiveness, and enable other enhancements. This information may relate to your use of the Services, websites you visited, advertisements you viewed, and your other activities online. Advertising that is based on information collected from or about you across websites, applications, and other platforms over time is known as interest-based or online behavioral advertising. You have some control over how and whether you are subject to such advertising as described below.
b. Ads for Quibi
We advertise Quibi on publishers such as Facebook, Instagram, and YouTube. When you view a Quibi ad on one of those publishers, whether or not you click on it, Quibi, advertising technology companies, and service providers that perform advertising-related services for us and our business partners may collect personal information. The information practices of third parties who display Quibi ads are governed by their own privacy policies and are not governed by this Privacy Notice. 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.
c. Third-party ads on Quibi
If you subscribe 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 age), 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
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 tracking 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
If you no longer want to receive marketing-related emails or text messages from us on a going-forward basis, you may opt out by following the instructions contained in each such email or text message, or by opting out from the Settings page in the App. We will try to comply with your request(s) as soon as reasonably practicable or as required by applicable law. Please note that if you opt out of receiving marketing-related emails from us, we may still send you administrative messages, from which you cannot opt out.
d. Push Notifications
You can choose to receive or disable push notifications from us in your device settings, and you can turn those settings on or off at any time.
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 and 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 suppressed from our database. 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 or as required by applicable law. Please note that if you choose to suppress or delete 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
This Privacy Notice does not address, and we are not responsible for the privacy, security, information, or other practices of any third parties, including any third party operating any website or service to which our Services link. The inclusion of a link in our Services does not imply endorsement of the linked site or service by us or by our affiliates.
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 sixteen (16) 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 standards (the full list of these countries is available here). For transfers from the EEA 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/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
We use third-party payment services (through the Apple and Google app stores) or subscription partners (such as T-Mobile) to process payments. If you subscribe to our Services, your payment information will be collected by such third parties, and will be subject to the applicable third party’s privacy notice, rather than this Privacy Notice. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your personal information. We have no access to your payment information.
15. UPDATES TO THIS PRIVACY NOTICE
The “Last Updated” legend at the top of this Privacy Notice indicates when this Privacy Notice was last revised. We reserve the right to revise this Privacy Notice from time to time. Any changes will become effective when we post the revised Privacy Notice on the Services or as otherwise stated in the revised Privacy Notice.
16. CONTACT US
Quibi Holdings, LLC located at 6555 Barton Avenue, Los Angeles, CA, 90038 is the company responsible for collection, use, and disclosure of your personal information under this Privacy Notice.
If you have any questions about this Privacy Notice, please contact us at firstname.lastname@example.org or:
Quibi Holdings, LLC
6555 Barton Avenue
Los Angeles, CA 90038
17. ADDITIONAL INFORMATION FOR EEA RESIDENTS
Our legal bases for processing your personal information are that processing your data is:
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.
On matters relating to the processing of personal data, EEA residents may:
VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
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.