PRIVACY POLICY


Effective Date : February 1 st , 2019

This Privacy Policy (the “Policy” ) describes how AMC/Sundance Channel Global Networks LLC ( “AMC”, “we”, or “us” ) collects personal information from the user ( “you” or, collectively, “Users” ), as well as the purposes for which it uses and shares such information, and how it does so. This Policy also provides information about the choices Users may have regarding the personal data we collect. This Policy forms part of the terms and conditions of the concrete website, application, service, contest or promotion in which the User is taking part, as applicable.

PERSONAL DATA BASIC INFORMATION

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR DATA?

The data controller is AMC, i.e. the entity AMC/Sundance Channel Global Networks LLC , with registered address 11 Penn Plaza, 17th Floor, New York, NY 10001 . For any privacy related matters, you can contact us (i) locally, via stvshorts@amcnetworks.com , or (ii) via our Data Protection Officer at dpo@amcnetworks.com .

2. WHAT PERSONAL DATA DO WE COLLECT?

Do not provide your personal data if you are under 18 years old. We just ask for such data as necessary to manage your participation in our services, contests or promotions, as well as in our webs, social media etc. Any required data will be expressly designated as such. In addition, if you connect to or access our systems or networks, we automatically collect information about the devices you use and your interactions with our resources. We may also collect information that you have made public via social networks or other platforms, and also we can process anonymous information, from which you may not be identified.

3. HOW DO WE USE THE PERSONAL DATA WE COLLECT?

We use the information we collect mainly to manage your participation in any requested services, contests or promotions, as well as for general promotion and loyalization to our products or services, to offer you the possibility to take part in our services, contests or promotions and later management, as well as to send you communications that may be of your interest.

4. WHY DO WE PROCESS YOUR DATA?

We process your personal data for execution of the terms and conditions that apply to the relationship with us, either to provide you with goods or services, including our loyalization Club, or to make possible your participation in our promotions. Also, relying on our legitimate interest, we can process your data to improve our services, anonymize the information and deliver to you personalized information regarding the requested services that may be of your interest. Also, subject to your consent, we will process geolocalization data and perform publicity actions related with some activity sectors. This consent is not required to be provided the requested services and maybe revoked anytime.

5. HOW IS YOUR PERSONAL DATA DISCLOSED?

We share personal data with trusted third parties as needed to support and manage our activities, either with merely instrumental or technical purposes or to deliver the commercial communications to you. Also, we disclose personal data to subsidiaries, affiliates, and joint venture partners. We may disclose information in connection with a sale or other transfer of our business or assets. And we may share information as necessary to comply with legal requirements, defend the rights and property of us or others, and maintain safety and security. Processing activities take place in the United States and we take steps to protect the data as required by the applicable law.

6. HOW CAN YOU EXERCISE YOUR RIGHTS?

To exercise your rights to access, correct, erase, restrict the use of, transfer, or object to processing of your personal data, as well as to withdraw your consent, if any, send an email to stvshorts@amcnetworks.com . We may require that you provide proof of your identity. You also have the right to register complaints with your local data protection authority.

7. HOW LONG DO WE KEEP INFORMATION?

As long you have not requested otherwise and we are certain about its accurateness, serve the purposes in this Policy and/or the applicable legislation requires so.

PRIVACY POLICY ADIDITONAL INFORMATION

This Privacy Policy (the “Policy” ) describes how AMC/Sundance Channel Global Networks LLC ( “AMC”, “we”, or “us” ) collects personal information from the user ( “you” or, collectively, “Users” ), as well as the purposes for which it uses and shares such information, and how it does so. This Policy also provides information about the choices Users may have regarding the personal data we collect. This Policy forms part of the terms and conditions of the concrete website, application, service, contest or promotion in which the User is taking part, as applicable.

This Policy will apply to the personal data we obtain when Users (i) sign up for any of our channels loyalization club in order to benefit from its activities, or use, access, download or otherwise interact with any AMC applications, mobile applications, games, sweepstakes, products, services, or websites and anywhere else where this Policy is posted, including applications we make available on third party sites or platforms, if disclosed to you in connection with your use of the application (collectively, “Services” ), or (ii) whenever Users apply for any competition and/or promotion organized by AMC (collectively, “Promotions” ). This Policy does not apply to personal data that is collected outside the Services or the application for Promotions. This Policy applies regardless of whether you access the Services or apply for Promotions using a personal computer, mobile device, gaming console or other equipment or device. If you disagree with the terms of this Policy, please do not use the Services or apply for Promotions.

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR DATA ?

AMC is responsible for the processing of your data (i.e. Data Controller) Its contact information is shown below:

Company name:

AMC/Sundance Channel Global Networks LLC

Registered address:

11 Penn Plaza, 17 th Floor, New York, NY 10001

Country of Incorporation: United States
Phone number: +1 646-273-7928
@ stvshorts@amcnetworks.com
Contact information of the Data Protection Officer:

Calle Saturno 1 - Pozuelo de Alarcón
28224 Madrid -SPAIN - dpo@amcnetworks.com

2. WHAT PERSONAL DATA DO YOU COLLECT ?

Without the express authorization of their legal representatives, we do not attempt to collect information about Users who are under 18 (eighteen) years old. Thus, we require all users of the Services and applicants for Promotions to be at least 18 (eighteen) years old. If we obtain actual knowledge that a User is under the age of 18 (eighteen) and no sufficient authorization has been obtained from the relevant representatives, we will promptly delete all information associated with such account.

For Users who are 18 (eighteen) years old or older, we collect the following types of personal data:

INFORMATION PROVIDED BY USERS: We collect personal data that you submit to us. For example, the process of creating or editing your user profile on a Service or applying for Promotions may require you to provide us with personal data such as name, e-mail address, phone number, physical address, including postal code, password of your choice and TV provider. When you personalize your profile and use the features of the Services, we will collect any information you voluntarily provide, and we may also request optional information to support your use of the Services, such as a profile picture and birthday. Additionally, we collect any information that you voluntarily enter into any postings, comments or forums within the Services, including private messages you send to other users of the Services, and any other information submitted in the context of applying for a Promotion. And, if you send an e-mail to us, we will collect your e-mail address and the full content of your e-mail, including attached files and other information you choose to provide to us.

INFORMATION WE COLLECT AUTOMATICALLY FROM YOUR DEVICES: When you use our Services or apply for Promotions, we may collect information about the device you use, including hardware model, operating system and version, IP address and other unique device identifiers (MAC), mobile network information and information about the device’s interaction with our Services or Promotions. We also collect information about how you use our Services or Promotions, including your access times, browser types and language. We may use this data alone or in aggregate form, as a statistical measure, but not in a manner that is intended to identify you personally. This type of data enables us to understand how often individuals use parts of the Services or Promotions so we can analyze and improve them. To collect this information, we use cookies and web beacons, and may in the future use other similar technologies. To learn more about how we automatically receive and record information when you interact with the Services or Promotions, please review our Cookies Policy. This policy covers only our use of cookies. However, options you have to control the use of third party cookies are explained in our Cookies Policy.

INFORMATION COLLECTED FROM OTHER SOURCES : We may, to the extent we are allowed to do so by applicable law, collect Users´ personal data from other sources, such as third-party social networks, employment platforms. The personal data we obtain from those sources will depend on the privacy settings chosen by the User for the platforms and the privacy policies and practices of the third parties, as well as applicable law. You should check the policies and privacy settings with the platforms you use. We can also conduct inquiries to assess your eligibility, as permitted by law. We process the personal data we collect from these platforms in accordance with the provisions of this Policy. Additionally, we may, subject to applicable law, collect Users´ publicly available information that may be of legitimate interest to us. The information we collect from such sources may include name, networks of contacts, interests, contact information, and published content which we can lawfully use to help create your professional profile.

LOCATION INFORMATION : We may collect different types of information about your location, including general information, such as the city, state and/or postal code associated with your IP address, and, if you agree, more specific location information that is provided through the GPS functionality on mobile devices used to access the Services or Promotions. We may use such location information to customize the Services and Promotions, including advertising that is presented to you. For example, if you provide a postal code that indicates that you live in Madrid the Services and Promotions may be customized with Madrid-specific information, features, and advertisements. In order to do this, your location information may be passed along to our affiliates, agents, vendors or advertisers. Please see section 6 of this Policy for detailed information about options you have to control the automatic collection of location information through mobile devices.

INFORMATION FROM SOCIAL MEDIA NETWORKS AND OTHER THIRD PARTIES : We may obtain information about you or your use of the Services and Promotions from third parties and sources, such as our vendors, like web host providers, analytics providers or advertisers. You may also give us permission to access your information, including personal data from services offered by third parties, including social media networks. For example, to access the Services, you may need to link your Facebook account to the Services, which allows us to obtain information from your Facebook account, such as your friends or contacts, profile picture, birthdate, gender, or other profile-related information and any other information you have opted to share with “everyone” on Facebook (or similar third-party platform). The information we obtain from third party services depends on your account/privacy settings with those third parties and the third parties’ privacy policies, so be sure to check those policies and to adjust your settings to meet your preferences. When you access the Services or Promotions through social media networks and other third-party platforms, you are authorizing AMC to collect, store and use such information and content in accordance with this Policy. If we combine or associate information from other sources with personal data that we collect through the Services or Promotions, we will treat the combined information as personal data in accordance with this Policy. Please keep in mind that any information provided to us by a third party may also be subject to that third-party’s privacy policy.

PAYMENT INFORMATION : If you purchase a product or service through the Services, our third-party payment processors will collect the billing and financial information they need to process your charges. This may include your postal address, email address and financial information. AMC does not collect or store your financial information, like credit card numbers. However, AMC´s third-party payment processors may share non-financial information with us related to your purchases, like your name, shipping address and items purchased in order to fulfill your order.

AGGREGATE AND/OR ANONYMOUS INFORMATION: We may aggregate or anonymize certain information that we collect from Users, so we cannot identify them personally.

3. HOW DO WE USE THE PERSONAL DATA WE COLLECT?

We use your personal data for the following purposes:

  1. Management of the concrete Service or Promotion for which the User has provided them for;
  2. Access by the User to the current or future Services and Promotions;
  3. Communication with the User in order to provide information on the Services and/or Promotions (non-marketing communications), including via email, text messages, social media, mail and phone;
  4. to provide, maintain, protect, develop and improve the Services, including through the use of statistical analysis, in order to enhance the user experience;
  5. to customize the content and advertisements you receive from us and our trusted partners as per f) and g) below;
  6. unless you opt out in in accordance with Section 6 below, to offer you by email, text messages, social media, additional information, opportunities, promotions and functionality related to our Services and/or the Promotions you applied for;
  7. provided that you opt in upon collection of your personal data, to offer you by email, text messages, social media, additional information, opportunities, promotions and functionality from us or on our behalf which is not related to our Services and/or the Promotions you applied for; or to offer you by the same means, additional information, opportunities, promotions and functionality from our partners or our advertisers belonging to the following industries: fashion, jewelry and clothing, arts, cinema, audiovisual and entertainment, food and gastronomy, beauty and personal care, collective activities, manufactured goods, energy, telecommunications, electronics, nightlife, home equipment and furniture, astrology and parascience, nutrition and health, leisure, decoration and gardening, education, recruitment, media and publishing, sports, outdoors and fitness, tourism, hospitality and travel, transportation; and
  8. show personalized publicity in our Services about sectors in f) and g) above, should you consent, for instance, to cookies deployment in accordance with Cookies Policy.

4. WHY DO WE PROCESS YOUR DATA?

Our primary purpose for processing your personal data is to execute the terms and conditions that regulate the concrete Service or Promotion requested by the User. Also, AMC will deliver information about news, activities or promotions that are part of such club, requested as part of the membership requested by the User. Also, AMC has a prevailing legitimate interest to carry out certain activities including without limitation in statistical analysis to help us analyze patterns in the use of the Services or the application for Promotions, as well as give notice about contents, promotions, publicity actions as long as those are related with the Services or Promotions in which the user takes part. Delivery of such notifications will include elaboration of a commercial profile of the User in order to be delivered only such notifications as appropriate to the declared tastes or interests.

Also with the Users consent, we will process their geo-localization data obtained through their mobile devices to perform commercial actions as per section 3, points g) and h) above, including personalizing contents due to profiling. The User will be able to access the Services and Promotions even if no such consent is granted and, in any event, it can be revoked anytime.

5. HOW IS YOUR PERSONAL DATA DISCLOSED?

We disclose Users’ personal data only as described below.

WITH CONSENT OF THE USER : We disclose Users´ information whenever they ask for us to do so or otherwise authorize the disclosure. Particularly, subject to consent, we could disclose the personal data, commercial profile included, to our partners or collaborators, as per section 3 g) above;

WITH GROUP COMPANIES : We may share User’s information with our affiliates and subsidiaries in support of the purposes described in section 4, and specifically, with other AMC entities;

WITH TRUSTED PARTNERS: We may share your information with our affiliated and subsidiary companies belonging to the media and entertainment and/or data research industries and joint venture partners belonging to the same industries, for the purposes of processing, analyzing or storing your information or otherwise as needed to provide the Services and Promotions to you, in each case, consistent with the terms of this Policy.

WITH TRUSTED THIRD-PARTY SERVICE PROVIDERS : We engage third party service providers to perform a variety of services and functions for us, such as web hosting technical maintenance, sending of massive emails, couriers, marketing agencies etc. We may share the User’s information with such service providers subject to confidentiality obligations consistent with this Policy and on the condition that the third parties use your information only on our behalf and pursuant to our instructions;

INFORMATION SHARED VIA THIRD-PARTY SOCIAL BUTTONS, WIDGETS AND OTHER EMBEDDED CONTENT : Some of our Services carry embedded content controlled by third parties for services such as social sharing, commenting and displaying video or images. When you interact with these services they may collect information from and about you and your interaction with their content, including the URL of the web page you are visiting. This activity will be subject to the privacy policy of and your settings for the third-party network or service. Please be aware that they may track your activity, including through the use of cookies or similar technology, without you needing to interact with them. If this concerns you, ensure you log out of their services before using ours;

TO COMPLY WITH LEGAL REQUIREMENTS AND TO PROTECT USERS, US AND OTHERS: We disclose your personal data to third parties if we believe, in good faith, that such disclosure is necessary to (a) comply with applicable laws or to respond to subpoenas, warrants or similar process served on us; (b) protect and defend our rights or property, Users, or third parties; or (c) ensure the safety and security of our services, systems and of our customers and third parties;

IN CONNECTION WITH A BUSINESS TRANSFER: If we negotiate or complete a business transition such as a merger, acquisition by another company, reorganization or sale of all or a portion of our assets, Users’ information may be transferred as part of that transaction in accordance with applicable data protection regulation.;

IF THE INFORMATION HAS BEEN ANONYMIZED : We may share or disclose information that has been anonymized, otherwise does not identify you or information that you choose to make public, such as your public user profile information. For example, we may develop information concerning the Services’ users, using anonymization processes to help ensure that identification of you as an individual is no longer possible by any party. This Policy does not limit our use or disclosure of anonymous information in any way, and we reserve the right to use and disclose such information to our partners, advertisers and any other third parties at our discretion;

INTERNATIONAL TRANFERS : processing your personal data takes place in the United States, in the course of such processing your personal data, your personal data may be transferred to other territories, regarded or not as countries that do not provide adequate protections for personal data. These transfers support the processing of personal data described above. When we transfer personal data to such countries, we put in place appropriate safeguards in accordance with applicable legal requirements. For more information about the safeguards in place, please contact our Data Protection Officer.

6. HOW CAN YOU EXERCISE YOUR RIGHTS?

AMC offers some account configuration tools for the Users to manage their data.

EXERCISE OF RIGHTS : Additionally, and in any event, you have certain rights regarding your personal data, subject to local law and the circumstances associated with the processing of the data. These rights include rights to:

  1. Access your personal data that we process;
  2. Request that we correct or delete incorrect or inaccurate personal data;
  3. Request that we delete your personal data when, including when the data is no longer necessary for the purposes for which it was collected;
  4. Request that we limit the processing of personal data (for example pending our assessment of the accuracy of personal data in response to a claim that the data is inaccurate);
  5. Request portability of your personal data (that is, to receive a copy of certain personal data in a structured format for transmission to another organization);
  6. Object to the processing of personal data, where such processing is just based on our legitimate interests, in which case we may be required to cease processing the personal data;
  7. Withdraw any consents provided in support of the processing of personal data; and
  8. Submit a claim to the local data protection authority.

The Users can exercise such rights by evidencing his or her identity by means of a copy of the ID card or other equivalent document, either via (i) email, to stvshorts@amcnetworks.com or (ii) post, to 11 Penn Plaza, 17th Floor, New York, NY 10001

COOKIES . You may opt out of receiving interest-based advertising from us. To find out more about our advertising and how to opt out, please see our Cookies Policy. You may also choose to block cookies. Learn more about cookies, how we use them and how to block them by reviewing our Cookies Policy.

COMMERCIAL COMMUNICATIONS . You have a right at any time to stop us from contacting you for marketing purposes. When you receive promotional communications from us, you may indicate a preference to stop receiving further promotional communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the promotional e-mail you receive or by contacting us directly at stvshorts@amcnetworks.com . Despite your indicated e-mail marketing preferences, we may still send you relationship and/or transactional (non-marketing) e-mails regarding the Services and Promotions, including, for example, administrative confirmations and notices of updates to our Policy, if we choose to provide such notices to you in this manner.

GEOLOCALIZATION If you access the Services or apply for Promotions through a mobile device and you do not want your device to provide us with location-tracking information, do not agree to allow your device to share this information with us or disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. Your device manufacturer should provide instructions on how to disable GPS or other location-tracking functions. If you initially consent to the collection of location information, you can subsequently stop our collection of location information at any time by changing the preferences on your mobile device or by uninstalling the application from your mobile device by following the standard uninstall process to remove applications from your device.

7. HOW LONG DO WE KEEP INFORMATION?

We retain Users’ personal data (i) throughout the Services and/or Promotions are in force and, thereafter (ii) as long as required for legal or regulatory compliance or necessary to support the purposes described in this Policy. When determining the applicable retention period, we consider the purposes described above and take into account the limitation period of the country in which you are based for the establishment and defense of legal claims, as well as our legal and regulatory obligations.

8. OTHER ISSUES

CHANGES IN POLICY. We may change this Policy from time to time. If we make changes, we will notify you by posting the updated policy and revising the “Effective Date” above. Use of the Services or applying for Promotions after the posted Effective Date means you accept the current version of the Policy, including any changes made prior to the posted Effective Date. If we make any material changes to this Policy, we will also notify you by email and ask for your consent, if necessary. We encourage you to review the Policy whenever you use our Services or apply for Promotions to stay informed about our information practices and the choices available to you.

LINKS TO THIRD PARTY WEBSITES . Links to third party websites may be made available through the Services. Clicking on such advertisements and links will direct you to the website or application of a third party. We are not responsible for the privacy practices or the content of such websites. Any personal data you provide via those sites is subject to the Privacy Policies on those websites and is not covered by this Policy. We encourage you to read the privacy statements of each and every website you visit or application you use. This Policy applies solely to personal data collected by us through the Services and Promotions and does not apply to third party websites or applications. The ability to access third party information from the Services and to link to other websites and locations from the Services is for your convenience and does not signify our endorsement of such third parties, their products, their services, their websites and locations or the content they make available on the Services or on their websites and locations.

SECURITY MEASURES: We are committed to protecting the security of your information. We use a variety of industry-standard security technologies and procedures to help protect your information from unauthorized access, use or disclosure. These measures are compliant with the requirements under the law and vary based on the sensitivity of the information that we collect.

OTHER JURISDICTIONS: You choose to access the Services and/ or apply for Promotions on your own initiative, and you are responsible for compliance with local laws if and to the extent local laws are applicable. AMC may limit the Service or Promotion’s availability, in whole or in part, concerning any person, geographic area or jurisdiction, at any time in its sole discretion.