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Last Updated May 25, 2018

PRIVACY POLICY

This “Privacy Policy” describes our policies, and your choices, regarding the collection, use, and disclosure of certain information about you, including your Personal Information (as defined below), by RLJ Entertainment Inc. and its Affiliates (as defined below) (hereafter collectively referred to as “we”“us”, and “RLJE”). The purpose of this Privacy Policy is to inform you:

  1. what Personal Information we may collect from you when you visit RLJE Sites and/or use RLJE Services;

  2. how we use, process and protect such Personal Information; and

  3. the rights, protections and choices you have regarding our use of, and your ability to review, correct and remove Personal Information.

 TABLE OF CONTENTS

ACCEPTANCE OF PRIVACY POLICY

PERSONAL INFORMATION WE COLLECT

HOW WE USE PERSONAL INFORMATION

HOW WE DISCLOSE PERSONAL INFORMATION

WHERE WE STORE PERSONAL INFORMATION

EDITING, CORRECTING AND DELETING PERSONAL INFORMATION

YOUR CHOICES

PROTECTING CHILDREN

SECURITY

GOVERNING LAW

POLICY UPDATES

RLJE’S DATA PROTECTION OFFICER (FEEDBACK / CONTACT US)

 ACCEPTANCE OF PRIVACY POLICY

By visiting or browsing the RLJE Sites (as defined below), as well as the use of RLJE services, including but not limited to those offered through our websites, emails, and applications (collectively, the “RLJE Service” or “RLJE Services”), you are accepting and actively consenting to the practices described in this Privacy Policy. You are free to choose not to provide certain Personal Information, but then you might not be able to take full advantage of many RLJE Site and RLJE Service features, including account creation, if applicable.

 “RLJE Sites” refer to any website domain name registered to RLJE, including, but not limited to:

https://www.rljentertainment.com/

https://us.rljentertainment.com/

https://www.acorndvd.com/

https://acornmediaau.com/

https://acorn.tv/

https://acacia.tv/

https://umc.tv/

http://www.acornproductionsltd.com/

https://www.acornmediaenterprises.com/

https://www.acornmediainternational.com/

https://www.athenalearning.com/

PERSONAL INFORMATION WE COLLECT

For the purposes of this Privacy Policy, the phrases “personally identifiable information”, “personal information” or “personal data” (hereinafter referred to a “Personal Information”) mean contact information and any other non-public information that is used or intended to be used to personally identify an individual, and any other non-public information that is associated with that information, such as your name, address, telephone number, etc.

We may collect and store Personal Information about you in connection with your use of the RLJE Service, including any Personal Information you transmit to or through an RLJE Site. We receive and store any data you enter on the RLJE Service or provide to us in any other way, including but not limited to signing up for an account, subscribing to one of our channels, using the RLJE Service directly or through one of RLJE’s third-party providers, signing up to our marketing email mailing list, any communication with our customer service, or participating in our surveys, contests, sweepstakes and promotions. Even when we do not retain certain Personal Information, it may be transmitted to our servers initially and stored long enough to process such Personal Information. Some examples of Personal Information we collect are:

 PERSONAL INFORMATION PROVIDED BY YOU:

 As mentioned above, any information you volunteer for the purpose of using an RLJE Site or using an RLJE Service can be collected, including:

  1. Required account set up details such as your name, email address, address or postal code, telephone number, password, birth date, payment authorization and any other information necessary to complete and record purchases and other transactions, as applicable;

  2. Optional information provided during the use of an RLJE Site, including, if applicable, reviews or ratings submitted, taste preferences and personal interests, account/profile settings, and information provided via participation in contests, surveys and/or marketing promotions (including gender, occupation and income level);

  3. Your activity on an RLJE Service, such as title selections, watch history, order history, search queries and schedules of use or information otherwise provided to us through an RLJE Service or elsewhere, if applicable; and

  4. Communication data such as your interactions with our email, push and text messaging, details of your interactions with customer service, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings.

 

  • AUTOMATIC/ANONYMOUS DATA: Some of the above data is collected and logged by us automatically and anonymously (“Anonymous Information”), in order to make an RLJE Site and the RLJE Service more useful to you. Here are some other examples of Anonymous Information we collect which is not directly provided by you:

  1. Data Collected by RLJE Servers: RLJE’s servers (which may be hosted by a third-party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (every device has a unique number, or IP Address, that is automatically assigned to your device when you use the Internet, which may change between sessions of use), your domain name, the date and time stamp of your visit, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, and clickstream data. We use this information to recognize and analyze trends, administer RLJE Services, track our users’ movement throughout RLJE Services, compile demographic information about our overall user base, and adapt RLJE Services to our users’ needs.

  2. Cookies, web beacons, and advertising identifiers: Like most sites, RLJE’s Services may use what are known as “cookies” in certain instances, or similar technology such as web beacons, and advertising identifiers, which may use small text files to store a randomly assigned ID and a website reference ID to make your device recognizable to RLJE. This technology is generally not used to store Personal Information. Cookies and other similar technology, as they now exist or develop, are used by RLJE to help remind us of our users’ identities and tailor RLJE Services to reflect our users’ personal interests, estimate our audience size, process user orders, facilitate and track user involvement in any of our contests, sweepstakes and other promotions, and analyze the visiting patterns of our users.

  3. Mobile Device: If you use an RLJE Service via a computer, phone, tablet or any other electronic device application or “App”, RLJE may choose to collect Personal Information about the device you use to access the App, including your device’s hardware model, the name and version of your operating system, your MAC address, the unique ID of your device, and what mobile network you are using. Please note that RLJE has no control over what Personal Information your device’s platform operator, such as Apple and Google, collects and uses. We suggest in addition to this document, you review your platform operator’s privacy policies to gain a better understanding of their own standards and practices regarding Personal Information.

  4. Advertiser Collected Data: RLJE may use third-party websites (such as social media sites including Facebook) to display ads for an RLJE Service. RLJE collects information from these advertising services about your visits to an RLJE Site via one or more of these advertisements, including but not limited to: your use of an RLJE Service, your IP address, your ISP, as well as the browser you used to visit an RLJE Site or the device you used to engage with an RLJE Service. These ads do not collect any specific Personal Information about you from third-party websites such as your name and contact information. The third-party websites use cookies and other technology to track this data. The information is collected by RLJE for analysis and visiting patterns, and may also be used, should a visitor to an RLJE Site become a user, to deliver targeted advertising based on your interests. This policy will only extend to RLJE’s ads on third-party sites, and no other features on such third-party sites. RLJE is not responsible for third-party sites’ collection, protection or use of your Personal Information. We suggest that, prior to using such third-party sites, you review their privacy policies to learn about their use of your information, as well as their implementation of cookies and similar technologies. If you would like more information about the practice of placing cookies on your device and to learn more about your choices regarding not having this information used by RLJE or any other third-party companies, please click here: http://www.aboutads.info/choices.

  • NOTE REGARDING STATISTICAL DATA/SENSITIVE DATA: RLJE may ask for certain statistical data from you (including age, education and socioeconomic status) while performing surveys which will be purely voluntary and always subject to your express consent. All such information will be collected anonymously by RLJE for marketing demographic knowledge only. At no point will RLJE ask for or process personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, data relating to criminal convictions or data concerning a user’s sex life or sexual orientation.

  • NOTE REGARDING ANONYMOUS VIEWING: In general, you can visit many RLJE Sites without telling us who you are or revealing any Personal Information about yourself. We may track the Internet domain address from which people visit us and analyze this data for trends and statistics, but individual users will remain anonymous, unless you voluntarily tell us who you are.

HOW WE USE PERSONAL INFORMATION

Our principal aim is to protect your Personal Information while utilizing it in lawful, relevant, legitimate, transparent, fair and reasonable ways to provide a wide variety of services at your request and better your experience with RLJE Sites. Specifically, we might use your Personal Information for the following internal purposes:

  1. Performing general services and functionality, such as creating an account for you, enabling you to subscribe to an RLJE Service, managing our email suppression lists, processing your payments, confirming and tracking your order, subscription or registration, analyzing trends and statistics, providing updates and support where needed, administering prize draws and competitions which you choose to enter – including publishing the names of winners, if required, and tailoring the features, performance and support of our services to you (and your personalized recommendations);

  2. Determining your general geographic location and demographic information, providing localized content, providing you with customized and personalized viewing recommendations for programming we think is compatible with your interests, determining your Internet service provider, and helping us quickly and efficiently respond to inquiries and requests;

  3. Communicating with you concerning our service (for example by email, push notifications text messaging, online messaging channels and other methods), so that we can send you news about RLJE Services, updates about new RLJE Service features and/or content, contests, sweepstakes, special offers, promotional announcements and consumer surveys, and assisting you with operational requests such as password reset requests. Please see the “EDITING, CORRECTING AND DELETING PERSONAL INFORMATION” section of this Privacy Policy to learn how to set or change your communications preferences;

  4. Providing technical support and sending service messages (for example, to let you know if a new version of one of our Apps is available, or if there will be any maintenance carried out on an RLJE Service) and responding to your requests, resolving disputes and/or troubleshooting problems;

  5. Enforcing our rights and terms of service and prevent, detecting and investigating potentially prohibited or illegal activities, including fraud, and enforcing our terms (this may include preventing copyright infringement, protecting our customers against abuse, determining free trial eligibility and any number of important actions);

  6. Marketing our products and services (and those of third parties) to you that we believe may be of interest to you based on your browsing and viewing behavior and other demographic information we hold about you. This may also involve sending marketing materials to you, including content recommendations and special offers in accordance with your chosen marketing preferences/choices;

  7. Analyzing your use of an RLJE Service, including user interface experiences, to help us to understand how the services are used, analyze and understand our audience, optimize content selection, recommendation algorithms and delivery, thereby improving the RLJE Service for everyone. This may include inviting you to participate in surveys, user testing and panels;

  8. To serve you better, we may combine Personal Information you give us online via various RLJE Sites and RLJE Services. We use that combined Personal Information to enhance and personalize your experience with us, and to communicate with you about our products and events that may be of interest to you.

  9. In certain instances, we may disclose your Personal Information when we have reason to believe that it is necessary to identify, contact or bring legal action against persons or entities who may be causing injury to you, to RLJE or to others. RLJE may also disclose your Personal Information when we believe the law requires it, as further described in the Necessary Disclosures section below.

  10. We may also use your Personal Information to aggregate or anonymize certain information that we collect from you to create Anonymous Information records by excluding information that makes the information personally identifiable to you. We reserve the right to use Anonymous Information for any purpose, including but not limited to: (i) analyzing reviews and consumption behavior to improve our ratings; (ii) tracking logins to personalize your experience (including by tailoring content to you); and (iii) enhancing the RLJE Sites or RLJE Services and the content of our software.

We will mainly communicate with you via email. You can easily manage the frequency (or opt out completely) of receiving such communication by clicking the “unsubscribe” link at the bottom of any emails we send. Please note that we may send you important RLJE Service-related communication (including information relating to your account or substantive issues that may affect your experience with our services), even if you have unsubscribed to marketing communications.

HOW WE DISCLOSE PERSONAL INFORMATION

Personal Information as supplied by you to RLJE will not be disclosed outside of RLJE except as described below and elsewhere in this Privacy Policy. All of the below Affiliates and third-party partners are contractually obligated to follow at all times the current and applicable practices of data protection as set forth by the law and maintain the standards set forth in this Privacy Policy.

  1. Third-party Service Providers. We may share your Personal Information with our third-party service providers that help us provide an RLJE Service we offer, such as third-party websites that offer an RLJE Service as part of a “bundling” within their own services and third-party companies that help us process payments for goods and services. Please note that while an RLJE Service may be made available for purchase/subscription via third-party websites and the information you provide to them in order to make such transactions will be made available to them (as well as RLJE) for the purposes of facilitating such transaction, any third-party websites are party to their own rules and regulations regarding acquisition, usage and protection of personal information. Please visit that third-party site’s privacy policy for more information.

  2. Third Party Tracking Services: RLJE allows third-party tracking services such as Google Analytics to monitor RLJE Sites and RLJE Services which may involve the collection of Personal Information. If such Personal Information is tracked by third-party services, the information will be anonymous and for statistical and analytics purposes only unless further agreed upon by you. See our Advertiser Collected Data section above.

  3. Affiliates: Since most of our functions requiring Personal Information (including marketing and technical support) are handled in-house throughout various departments in our company, we may share some or all of your Personal Information with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”) in order to best operate the RLJE Sites and RLJE Services and cater and market them to you according to your interests and feedback. If we acquire additional Affiliates in the future, we will require our Affiliates to honor this Privacy Policy.

  4. Corporate Restructuring: In the occurrence of (or negotiation of) a merger, financing deal, sale, dissolution, transfer, divestiture, or disclosure of some or all of our assets, we may share some or all of your Personal Information as is legally or contractually obligated, or as required by virtue of such Personal Information becoming transferred as a business asset in the event of insolvency, bankruptcy, or receivership. If any of the above were to occur, and our company, business and/or assets are acquired by a third party, such third party will assume all right and responsibility to your Personal Information as set forth in this Privacy Policy.

  5. Necessary Disclosures. Please be advised that, regardless of the choices you make regarding your Personal Information, RLJE may be required to disclose such Personal Information as necessary to comply with any current or future state, federal or international laws and regulations, to cooperate with a legal investigation(s), subpoena(s) or warrants served on RLJE, to defend our rights, property (including copyright) or our users (including you) and to investigate or assist in preventing any violation of the state, federal or international law (potential or actual), RLJE’s Privacy Policy, or RLJE’s Terms of Use.

  •  NOTE REGARDING SOCIAL NETWORKING: RLJE does not share your Personal Information with any social networking service or “SNS” (e.g., Facebook or Twitter). You may voluntarily contribute information, feedback and commentary to an SNS. However, please note that if you choose to share information or post content to these sites regarding an RLJE Site or an RLJE Service, you are solely responsible for your use of those websites. It will be your responsibility to follow the terms of use of such third-party website and review their privacy policy. We cannot and will not in any way be responsible for any activity that occurs on such SNS, including your own activity or use of such website.

  • NOTE REGARDING LINKS TO THIRD-PARTY SITES: Further to the SNS note above, An RLJE Site may contain links to web sites operated and maintained by third parties. In addition, such third-party sites may reference, advertise, or link to an RLJE Site. RLJE has no control over these third-party web sites. Privacy policies on such linked sites may be different from our Privacy Policy. RLJE does not endorse or sponsor other web sites, is not responsible for the privacy practices or the content of non-RLJE Sites, expressly disclaims any statements or assertions made on such web sites, and denies all liability associated with your use of, and the content on, such other sites and advertisement. You access such linked sites at your own risk. You should always read the privacy policy of a linked site before disclosing any Personal Information on such site.

WHERE WE STORE PERSONAL INFORMATION

Your Personal Information will be stored in the United States. By visiting or browsing the RLJE Sites and using the RLJE Services, and by providing your Personal Information to RLJE, all users, including, without limitation, users in the member states of the European Union, fully understand and unambiguously consent to the collection, storage, and processing of such information in the United States and the terms of this Privacy Policy.

EDITING, CORRECTING AND DELETING PERSONAL INFORMATION

You can request access to your Personal Information, or correct inaccurate Personal Information by contacting Privacy@RLJEntertainment.com.

RLJE will keep your Personal Information for as long as you use an RLJE Service or visit an RLJE Site and for an amount of time after you have stopped using the RLJE Service or visiting an RLJE Site for administrative and analysis purposes only. Notwithstanding the foregoing, RLJE will immediately delete any personally identifiable Personal Information if you specifically request its immediate deletion at the time you stop using the RLJE Service by contacting Privacy@RLJEntertainment.com; provided that, RLJE may reject requests that are unreasonable or not required by law, including those that could require disproportionate technical effort, would be extremely impractical, could expose RLJE to operational risks such as free trial fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce the RLJE Terms of Use, and take other actions otherwise permitted by law. Notwithstanding the forgoing, RLJE may keep an anonymized form of your Personal Information for a longer period, but such data cannot in any way be connected to you. RLJE’s payment partners will keep certain payment information for as long as required by law.

Please remember that if you delete certain Personal Information you may not be able to continue to use RLJE Services or access certain pages of an RLJE Site without entering additional information.

YOUR CHOICES

You have the following choices regarding how RLJE and third parties use certain Personal Information collected from or about you:

  1. Elect Not to Provide Personal Information. You may always choose not to provide Personal Information, even though it might be needed to make engage or subscribe to RLJE Services, as applicable, or to take advantage of RLJE Site features.

  2. Email and Text Messages. If you no longer want to receive certain communications from us via email or text message, simply click the “unsubscribe” link in the email or reply STOP (or as otherwise instructed) to the text message.

  3. Push Notifications. You can choose to receive mobile push notifications from RLJE. If you subsequently decide you no longer wish to receive these notifications, you can use your mobile device’s settings functionality to turn them off.

  4. Interest-Based Ads. If you are using a browser or a mobile device, tablet, or streaming media device, then cookies, web beacons, and advertising identifiers can be used to collect information to help determine your likely interests via interest-based ads. You can set the preferences of your browser to inform you when cookies or web beacons are sent, which will provide you with an opportunity to either accept or deny them. Please review your browser settings and instructions (generally via a “Help” or “Settings” tab) to gain a better understanding of how to track and manage cookies. However, please take into account that some of RLJE Service operations and RLJE Site pages and may not function properly if you choose to block certain cookies. To opt out of interest-based ads from RLJE in connection with an advertising identifier on a mobile device, tablet, or streaming media devices, please configure the appropriate setting on your device (usually found under “privacy” or “ads” in your device’s settings). Please note that changing any of these settings does not prevent the display of certain advertisements to you that are not interest-based.

  5. Additional Choices for California Residents. We do not disclose your Personal Information to third parties for the purpose of directly marketing their goods or services to you (as compared to when the third party is acting on our behalf or you have provided your personal information as part of a co-promotion by RLJE and the third party) unless you first agree to such disclosure. If you are a California resident, you may be entitled to request certain information regarding our disclosure, if any, of Personal Information (such as your name and contact information) to third parties who wish to contact you or send you promotional information about their products and services directly. If you are a California resident and would like to request a copy of information regarding our disclosure to third parties for their direct marketing purposes in the preceding calendar year, please contact us at Privacy@RLJEntertainment.com.

PROTECTING CHILDREN

RLJE Services as well as RLJE Sites are intended for general audiences and are not directed to children under 13. We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information without parental consent, please contact us at Privacy@RLJEntertainment.com. If we become aware that a child under 13 has provided us with personal information without parental consent, we take steps to remove such information and terminate the child’s account. We urge parents and guardians to participate in their children’s online activities and use parental control or other web filtering technology to supervise children’s access to the web.

SECURITY

We use commercially reasonable encryption and authentication tools to protect the security of your personal information that you share with us. Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee or warrant the security of any information you transmit to or from an RLJE Site, and you do so at your own risk. We urge you to keep your password in a safe place and not to divulge it to anyone. Also remember to sign off your account and close your browser window when you have finished your visit. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place such as a library or Internet cafe. Please refer to the U.S. Federal Trade Commission’s website for information on how to protect yourself from identity theft. Should RLJE experience a data breach involving your Personal Information, we notify you immediately of such breach (to the best of our ability based on your communication preferences) as well as inform you as to and the steps we will take to quickly remedy that breach.

Personal Information about our customers is an important part of our business, and we are not in the business of selling it to others. We will never sell your Personal Information to any third-party under any circumstances without warning you in advance, changing this Privacy Policy, and giving you the option to approve or deny such settings.

GOVERNING LAW

This Privacy Policy and all disputes arising hereunder or relating hereto shall be governed by the laws of the State of California without regard to conflicts of laws principles. You and RLJE irrevocably consent to exclusive personal jurisdiction and venue in the federal and state courts located in Los Angeles County for any action or proceeding arising out of or relating to this Privacy Policy and each irrevocably waives the defense of an inconvenient forum to the maintenance of any such action or proceeding. RLJE may limit RLJE Services’ availability, in whole or in part, concerning any person, geographic area or jurisdiction, at any time in its sole discretion.

POLICY UPDATES

RLJE has the right to update this Privacy Policy at any time. You should check this Privacy Policy each time you provide Personal Information to us. The date of the most recent revision will appear at the top of this page. All changes to this Privacy Policy will go into effect on the date posted at the top of the Privacy Policy. The new policy will apply to all current and past users of the RLJE Sites and RLJE Services and will replace any prior policies which are inconsistent. Your continued use of an RLJE Site or RLJE Services after the posting will constitute acceptance of, and agreement to be bound by, those changes. Additionally, you will be deemed to have consented to the disclosure to, and use by, a subsequent owner or operator of the RLJE Site, of any information about you contained in the applicable RLJE database, if RLJE or one of its companies assigns its rights and obligations regarding any of your information at the time of a merger, acquisition, or sale of all or substantially all of RLJE ‘s or such RLJE company’s assets related to the applicable site or service to a subsequent owner or operator. In the event of such a merger, acquisition, or sale, your continued use of the RLJE Site or Sites or any Service signifies your agreement to be bound by the Privacy Policy and other terms and conditions (if any) of the RLJE Site’s or Service’s subsequent owner or operator.

RLJE’S DATA PROTECTION OFFICER (FEEDBACK / CONTACT US)

For questions specifically concerning this Privacy Policy, to help us improve our Privacy Policy, or to express any questions, concerns or complaints regarding RLJE’s collection and use of your Personal Information please contact us at Privacy@RLJEntertainment.com. Alternatively, you may write to us at the following address:

RLJ Entertainment, Inc.

6320 Canoga Avenue, 8th Floor

Woodland Hills, California 91367, USA

Attention: Data Protection Officer

Phone: 818.407.9100