Last Updated/Effective Date: August 15th, 2022

Table of Contents

1. SCOPE AND APPLICATION: What and who this Policy covers
2. COLLECTION OF INFORMATION: The sources of and methods by which we, our service providers, and our advertisers collect information from and about you, including information about your interaction with the Company Services
3. USE AND DISCLOSURE: How we use the information we collect from and about you, and who we might share it with and why
4. SECURITY: How we protect your information from loss or misuse
5. USER ACCESS AND CONTROL: How you can access and control the information we maintain about you
6. OTHER IMPORTANT INFORMATION: Other things you should know about this Policy and how we handle your information
7. CONTACT US: How to contact us about this Policy
8. CALIFORNIA CONSUMER PRIVACY ACT NOTICE: Other things you should know if you reside in California

1. SCOPE AND APPLICATION

SFL Media Firm, LLC. (“Company” or “we”) wants you to be familiar with how we collect, use and disclose information from and about you. This Privacy Policy describes our practices in connection with information collected through services such as websites, mobile sites, applications (“apps”), and widgets (collectively, the “Company Services”) that link to this Privacy Policy. California residents, please see the California Consumer Privacy Act Notice in Section 8 below. By using Company Services, you agree to the terms and conditions of this Privacy Policy.

As set forth in our Terms of Use, the Company Services are for a general audience, are not targeted to children, and do not knowingly collect personal information from children under 16 years of age.

This Privacy Policy applies to all users, including both those who use the Company Services without being registered with or subscribing to a Company Service and those who have registered with or subscribed to a Company Service. This Privacy Policy applies to Company’s collection and use of your personal information (i.e., information that identifies a specific person, such as full name or email address). It also describes generally Company’s practices for handling non-personal information (for example, interests, demographics and services usage).

2. COLLECTION OF INFORMATION

Company and our service providers may collect the following information from and about you:

Registration Information is the information you submit to register for a Company Service, for example, to receive a newsletter, or enter a contest or sweepstakes. Registration Information may include, for example, name, email address, gender, zip code and birthday.

Public Information and Posts consist of comments or content that you post to the Company Services and the information about you that accompanies those posts or content, which may include a name, user name, comments, likes, status, profile information and picture. Public Information and Posts are always public, which means they are available to everyone and may be displayed in search results on external search engines.

Information from Social Media. If you access or log-in to a Company Service through a social media service or connect a Company Service to a social media service, the information we collect may also include your user ID and/or user name associated with that social media service, any information or content you have permitted the social media service to share with us, such as your profile picture, email address or friends lists, and any information you have made public in connection with that social media service. When you access the Company Services through social media services or when you connect a Company Service to social media services, you are authorizing Company to collect, store, and use such information and content in accordance with this Privacy Policy.

Activity Information. When you access and interact with the Company Services, Company and its service providers may collect certain information about those visits. For example, in order to permit your connection to the Company Services, our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, and other software or hardware information. If you access the Company Services from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data (including your precise location), or other transactional information for that device.

Cookies and other tracking technologies (such as browser cookies, pixels, beacons, local storage, and other mechanisms) use various approaches to collect and store data. Some of these technologies store data in the browser or on your device. Other technologies may use network-related or other information to recognize your device (e.g., IP address). Company’s websites, apps and other services use these technologies, for example, when you first request a web page and data is then stored on your computer or other device so the website or app can access information when you make subsequent requests for pages from that service. These technologies may also be used to collect and store information about your usage of the Company Services, such as pages you have visited, search history, and the video and other content you have viewed.

Other parties that support the Company Services by serving advertisements or providing services, such as allowing you to share content or tracking aggregate Company Services usage statistics, may also use these technologies to collect similar information when you use the Company Services or other parties’ services. Those parties may also use these technologies, along with the activity information they collect, to recognize you across the devices you use, such as a mobile device and a laptop or other computer. The company does not control these technologies and their use is governed by the privacy policies of parties using such technologies. For more information about third-party advertising networks and similar entities that use these technologies, including your choices with respect to them, see the section entitled “To deliver relevant advertisements,” below.

Your browser may be initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, and to block cookies altogether. Please consult the “Help” section of your browser for more information, including on how to clear data from local storage and, depending on your browser, how to turn off other data collection by the browser. To opt out of Google Analytics specifically, go to https://tools.google.com/dlpage/gaoptout. Please note that by blocking any or all cookies you may not have access to certain features, content or personalization available through the Company Services.

Information from Other Sources. We may supplement the information we collect with information from other sources, such as publicly available information about your online and offline activity from social media services, advertising technology companies, advertisers, commercially available sources, and information from our Company Affiliates or business partners.

Do Not Track Signals. At this time we do not respond to browser ‘Do Not Track’ signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted.

3. USE AND DISCLOSURE

We may use the information we collect from and about you to provide the Company Services and features to you, including: to measure and improve those Company Services and features and to develop new products and services; to improve your experience with both online and off-line Company Services by delivering content you will find relevant and interesting, including advertising and marketing messages; to allow you to submit tips, and participate in online games, contests, other promotions, or rewards programs; to provide you with customer support and to respond to inquiries. In order to provide you with content and advertising that is more interesting and relevant to you, we may use the information from and about you to make inferences and predictions about your potential areas of interest. When the information collected from or about you does not identify you as a specific person, we may use that information for any purpose or share it with other parties, to the extent permitted by applicable law.

We use the information we collect from and about you for these additional purposes:

To allow service providers to assist us in providing and managing the Company Services. The information we collect from and about you may be made available to certain service providers, such as contractors, analytics and other measurement companies, agents or sponsors, who help us analyze and understand your use of the Company Services, and manage and/or provide the Company Services.

To allow social sharing functionality. If you log in with or connect a social media service account with Company Services, we may share your user name, picture, and likes, as well as your activities and comments with other Company Services users and with your friends associated with your social media service. We may also share the same information with the social media service provider. By logging in with or connecting your Company Services account with a social media service, you are authorizing us to share information we collect from and about you with the social media service provider, other users and your friends and you understand that the social media service’s use of the shared information will be governed by the social media service’s privacy policy. If you do not want your personal information shared in this way, please do not connect your social media service account with your Company Services account and do not participate in social sharing on Company Services.

To provide co-branded services and features. We may offer co-branded services or features, such as contests, sweepstakes or other promotions together with other companies (“Co-Branded Services”). These Co-Branded Services may be hosted on Company Services or on that other party’s service. By virtue of these relationships, we may share the information you submit in connection with the Co-Branded Service with that party. That other party’s use of your information will be governed by its privacy policy.

To deliver relevant advertisements. Company and our service providers may use the information we collect from and about you as described in this Privacy Policy to deliver relevant ads to you when you use the Company Services or another service (on any of your devices). As noted above, advertising technology companies and advertisers may use cookies and similar technologies to collect and track information such as demographic information, inferred interests, aggregated information, and information about the different devices and/or browsers you use and your activity on such devices and browsers, to assist them in delivering advertising that is more relevant to your interests. To find out more about advertising networks and similar entities that use these technologies, see https://youradchoices.com/. If you wish to opt out of tailored advertising in desktop and mobile browsers, please visit http://optout.aboutads.info/#/ or http://optout.networkadvertising.org/# on each of your devices and browsers. To opt out in mobile apps, you may use your device’s setting to opt out of ads personalization or similar settings or download and use the AppChoices app at https://youradchoices.com/appchoices. To opt out on connected TVs, please use the setting to opt out of ads personalization “Interest-based Ads,” or equivalent settings on your device. Please note that opting-out does not mean that you will stop seeing all ads.

To contact you. Company may periodically send promotional materials or notifications related to the Company Services. If you want to stop receiving promotional materials, you can follow the unsubscribe instructions at the bottom of each email. There are certain service notification and other non-promotional emails that you may not opt-out of, such as notifications of changes to the Company Services or policies. If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app.

To share with our Company Affiliates. Company may share your information with Company Affiliates for the purposes described in this Privacy Policy. A link to a website that lists Company Affiliates can be found at the beginning of this policy. Users who visit Company Affiliates’ services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Policy.

To share with business partners. Company may share your information with business partners to permit them to send you marketing communications consistent with your choices.

To protect the rights of Company and others. There may be instances when Company may use or disclose your information, including situations where Company has a good faith belief that such use or disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of Company, our Company Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); (ii) protect the safety, privacy, and security of users of the Company Services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process; or (v) respond to requests from public and government authorities.

To complete a merger or sale of assets. If Company sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business (including in connection with a bankruptcy or similar proceedings), Company may transfer your information to the party or parties involved in the transaction as part of that transaction.

4. SECURITY

Company uses commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in its possession against loss, theft and unauthorized use, disclosure, or modification. However, no one can guarantee the complete safety of your information.

5. USER ACCESS AND CONTROL

If you would like to access personal information we hold about you or delete your personal information you have previously provided directly to us, please visit https://sfl.media/contact-us/ and submit a request. Please note that, for security reasons, we will ask you to verify your identity in order to proceed with your request. If you would like to review, correct, update, suppress, or otherwise limit our use of your personal information, you may contact us as outlined in Section 7. In your request, please include your email address, name, address, and telephone number and specify clearly what information you would like to change, update, or suppress. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law.

If you are a resident of California, please see the section entitled “California Consumer Privacy Act Notice,” below, for more information about the rights you have under California law.

If you are under 18 and a registered user of the Company Services, you may ask us to remove content or information that you have posted to the Company Services by writing to Ana@SFL.Media. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.

You may request that we not share your personal information on a going-forward basis with Company Affiliates or unaffiliated third parties for their direct marketing purposes by contacting us as outlined in Section 7. We will try to comply with your request(s) as soon as reasonably practicable and consistent with applicable law.

6. OTHER IMPORTANT INFORMATION

Updates to Privacy Policy. Company may modify this Privacy Policy. Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Company Services.

Location of Data. The Company Services are hosted in and managed from the United States. If you are a user located outside the United States, you understand and consent to having any personal information processed in the United States or in any other country in which we have facilities or in which we engage service providers. United States and other countries’ data protection laws may not be the same as those in your jurisdiction. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in the United States may be entitled to access your personal information.

Linked Services. The Company Services may be linked to sites operated by unaffiliated companies, and may carry advertisements or offer content, functionality, games, newsletters, contests or sweepstakes, or applications developed and maintained by unaffiliated companies. Company is not responsible for the privacy practices of unaffiliated companies, and once you leave the Company Services or click an advertisement you should check the applicable privacy policy of the other service.

In addition, Company is not responsible for the privacy or data security practices of other organizations, such as Facebook, Instagram, Twitter, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including in connection with any information you disclose to other organizations through or in connection with the Company Services.

Collection of Personal Financial Information by a Payment Service. In some cases, we may use an unaffiliated payment service to allow you to purchase a product or make payments (“Payment Service”). If you wish to purchase a product or make a payment using a Payment Service, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service.

Data Retention. We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

Remember that even after you cancel your account, or if you ask us to delete your personal information, copies of some information from your account may remain viewable in some circumstances where, for example, you have shared information with social media or other services. Because of the nature of caching technology, your account may not be instantly inaccessible to others. We may also retain backup information related to your account on our servers for some time after cancellation or your request for deletion, for fraud detection or to comply with applicable law or our internal security or recordkeeping policies. It may not always be possible to completely remove or delete all of your information due to technical constraints or contractual, financial or legal requirements.

7. CONTACT US

If you have questions about this Privacy Policy, please contact us at:

Email: Ana@SFL.Media

8. CALIFORNIA CONSUMER PRIVACY ACT NOTICE

This California Consumer Privacy Act Notice Section provides information for California residents in connection with the California Consumer Privacy Act (“CCPA”). Under the CCPA, and for purposes of this Section, “Personal Information” generally means information that identifies, relates to, or describes a particular California resident and includes the categories listed below. This Section 8 provides details about the categories of Personal Information of California residents that we have collected, disclosed, or “sold” during the last 12 months, as well as rights California residents have under California law.

Categories of Personal Information Collected, Disclosed, and/or Sold:

The categories of Personal Information that we collected, disclosed, and/or “sold” are below, along with the categories of third parties to whom each category of Personal Information was disclosed, and/or “sold.” Please note that we disclose some categories of Personal Information in connection with certain types of advertisements, which could be considered a “sale” under the CCPA. Also, depending on the California resident’s interactions with us, Company may not have collected, disclosed, or “sold” each of these categories about each individual. Additionally, we do not knowingly “sell” Personal Information of minors under 16 years of age.

We have collected, disclosed, and/or “sold” to third parties the following categories of Personal Information:

A. Identifiers, such as name, IP address, email address, and online and device identifiers

Categories of Third Parties to Whom Identifiers Is Disclosed – Service providers, Company Affiliates, and other providers or partners that support our operational business purposes

Categories of Third Parties to Whom Identifiers is “Sold” – Advertising technology companies; advertisers

B. Personal information, as defined in the California Customer Records law, such as contact and financial information

Categories of Third Parties to Whom Personal Information Is Disclosed – Service providers, Company Affiliates, and other providers or partners that support our operational business purposes

Categories of Third Parties to Whom Personal Information is “Sold” – Advertising technology companies; advertisers

C. Characteristics of protected classifications under California law, such as age or gender

Categories of Third Parties to Whom Characteristics of protected classifications under California law Is Disclosed – Service providers, Company Affiliates, and other providers or partners that support our operational business purposes

Categories of Third Parties to Whom Characteristics of protected classifications under California law is “Sold” – N/A

D. Commercial information, such as transaction information and purchase history

Categories of Third Parties to Whom Commercial Information Is Disclosed – Service providers, Company Affiliates, and other providers or partners that support operational business purposes

Categories of Third Parties to Whom Commercial Information is “Sold” – N/A

E. Internet or network activity information, such as browsing history and interactions with our websites, mobile, or connected TV applications (collectively, “Company Digital Properties”)

Categories of Third Parties to Whom Internet or network activity information Is Disclosed – Service providers, Company Affiliates, and other providers or partners that support operational business purposes

Categories of Third Parties to Whom Internet or network activity information is “Sold” – Advertising technology companies; advertisers

F. Geolocation data, such as device location

Categories of Third Parties to Whom Geolocation Data Is Disclosed – Service providers, Company Affiliates, and other providers or partners that support operational business purposes

Categories of Third Parties to Whom Geolocation Data is “Sold” – N/A

G. Audio, electronic, visual and other similar information, such as call recordings

Categories of Third Parties to Whom Audio, electronic, visual and other similar information Is Disclosed – Service providers, Company Affiliates, and other providers or partners that support operational business purposes

Categories of Third Parties to Whom Audio, electronic, visual and other similar information is “Sold” – N/A

H. Professional or employment-related information, such as work history and prior employer

Categories of Third Parties to Whom Professional or employment-related information Is Disclosed – Service providers, Company Affiliates, and other providers or partners that support our operational business purposes

Categories of Third Parties to Whom Professional or employment-related information is “Sold” – N/A

I. Non-public education information (e.g., in connection with news or entertainment productions)

Categories of Third Parties to Whom Non-public education information Is Disclosed – Service providers, Company Affiliates, and other providers or partners that support our operational business purposes

Categories of Third Parties to Whom Non-public education information is “Sold” – N/A

J. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Categories of Third Parties to Whom Inferences drawn from any of the Personal Information Is Disclosed – Service providers, Company Affiliates, and other providers or partners that support our operational business purposes

Categories of Third Parties to Whom Inferences drawn from any of the Personal Information is “Sold” – Advertising technology companies; advertisers

Please note that the CCPA definition of “sale” does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other similar transaction involving of all or any portion of our business.

Sources of Personal Information. We collect this Personal Information directly from California residents themselves, as well as from social media platforms (e.g., if the individual has connected a social media account to a Company Digital Property); business partners (e.g., in connection with SFL Media Firm); joint marketing, co-branding, co-promotional, or advertising partners, including advertising technology companies and advertisers; Company Affiliates; and sources of demographic and other information. Depending on the individual’s interactions with us, Company may not have collected Personal Information from each of these categories of sources.

Purposes. We may use this Personal Information for the following purposes:

• to operate, manage, and maintain our business;
• to provide our products and services;
• to accomplish our business purposes and objectives, including
  • developing, improving, repairing, and maintaining our products and services;
  • personalizing, advertising, and marketing our products and services;
  • conducting research, analytics, and data analysis;
  • maintaining our facilities and infrastructure
  • quality and safety assurance measures
  • conducting risk and security controls and monitoring;
  • detecting and preventing fraud;
  • performing identity verification
  • performing accounting, audit, and other internal functions;
  • complying with law, legal process, and internal policies;
  • maintaining records; and
  • exercising and defending legal claims.

Depending on the California resident’s interactions with us, Company may not have used Personal Information collected about that resident for each of these purposes.

California Rights. If you are a California consumer, you have the following rights:

(1) Right to Know. You have the right to request that we disclose to you the following information:

• The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information during the 12 months prior to your request;
• The specific pieces of Personal Information we collected about you during that time period;
• The business or commercial purpose for collecting, disclosing, or selling Personal Information about you;
• The categories of Personal Information about you that we sold and the categories of third parties to whom we sold that Personal Information; 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 that Personal Information.

To make a request for your Personal Information, please click here or call us at 954-740-7900. You will need to provide your name and email address, along with other details about your request. You will then receive verification instructions by email. But you do not need to have an account/profile to submit a request. In some circumstances, we may need additional information from you to verify your identity or proceed with your request.

You can use an authorized agent to submit a request for your Personal Information. When submitting a request online, your authorized agent should select the “Other” option on the form and, in the field provided, include your name, and your email address. In addition to verifying your identity, as described above, we also will need to verify your authorized agent’s ability to act on your behalf (e.g., by receiving a copy of your signed permission). Once verification is complete, we may communicate directly with you for privacy and security reasons.

Please note that, in some instances, we may decline to honor your request, where, for example, we are unable to verify your identity or an exception to this right applies.

(2) Right to Request Deletion. You have the right to request that we delete Personal Information we collected from you.

To make a request for deletion, please click here or call us at 94-740-7900. You will need to provide your name and email address, along with other details about your request. You will then receive verification instructions by email. But you do not need to have an account/profile to submit a request. Please note that you also will be asked to separately confirm that you would like to proceed with your deletion request. In some circumstances, we may need additional information from you to verify your identity or proceed with your request.

You can use an authorized agent to submit a request for deletion. When submitting a request online, your authorized agent should select the “Other” option on the form and, in the field provided, include your name, and your email address. In addition to verifying your identity, as described above, we also will need to verify your authorized agent’s ability to act on your behalf (e.g., by receiving a copy of your signed permission). Once verification is complete, we may communicate directly with you for privacy and security reasons.

Please note that, in some instances, we may decline to honor your request where, for example, we are unable to verify your identity or an exception to this right applies.

(3) Right to Opt-Out of Sale. As noted above in this section, we share some categories of Personal Information in connection with certain types of advertisements. You can exercise your rights to opt-out of “sales” by clicking on the Do Not Sell My Info link in the footer of the webpage or in the Settings section for mobile or other apps. Alternatively, if you wish to opt out of the sharing of your Personal Information in connection with tailored advertising in desktop and mobile browsers, please visit http://optout.aboutads.info/#/ or http://optout.networkadvertising.org/#. To opt out in mobile apps, you may use your device’s “Limit Ad Tracking” or similar settings or download and use the AppChoices app at https://youradchoices.com/appchoices. To opt out on connected TVs, please use the “Limit Ad Tracking,” “Interest-based Ads,” or equivalent settings on your device. Please note that opting out does not mean that you will stop seeing all ads.

Because interest-based advertising relies on cookies and other similar technologies, opting out needs to be controlled at the device and/or browser level.

As noted, you can visit our “Do Not Sell My Info” page by clicking on the link on the website or in the Settings section for apps.

(4) Right to be Free from Discrimination. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.