CONSUMER PRIVACY POLICY

Effective Date: 7th March 2017

Alphonso Inc. (Alphonso) owns and operates the website www.alphonso.tv (the Site). Alphonso also develops and distributes certain software applications for automatic content recognition (ACR), which may include applications for set top boxes, smart televisions and mobile devices (Alphonso Apps). Alphonso also develops and distributes a software development kit, including application programming interfaces, software, documentation and related materials (the SDK), which certain website publishers, software developers, device manufacturers and other users (Independent Developers) may elect to utilize in connection with developing and operating their own ACR applications (Independent Applications). The Site, Apps and SDK, together with the data collection, storage, analysis and reporting tools, functions and services that are provided at or by the Site, Apps or SDK, are collectively referred to as the Service.

The following policy explains how Alphonso collects, uses and shares information when consumers interact with the Service, which may occur directly or as the result of interacting with an Independent Application or Host Application. Capitalized terms used herein without definition will have the same meanings as defined in the Terms of Service applicable to the Service, which are available at www.alphonso.tv/terms.html. If you are a developer, publisher, advertiser, or device manufacturer that wants to use the Service in your mobile app or other device, please visit our website at www.alphonso.tv to learn more or email us at info@alphonso.tv.

Information Collected

Site

When you visit the Site, web servers collect information about your visit (such as, for example, traffic data like time, date and the address of the website from which you entered the Site), which is aggregated by us. Alphonso also collects information about you and your use of the Service, either automatically when you use the site or from third parties (such as, for example, demographic data, profile data and frequency or duration of use). Collecting such data (collectively, Traffic Data) may entail the use of software programs, web beacons, pixel tags, Cookies, or other similar technologies (as defined below), IP addresses or other numeric codes used to identify a computer. The same or similar Traffic Data may be collected at other websites or applications and provided to Alphonso when the Service interacts with Independent Applications or Host Applications, which other websites and applications are operated by or for Independent Developers or Authorized Distributors.

Service

Whenever you interact with the Service, which may occur directly or as a result of interacting with an Independent Application or Host Application, a variety of technologies are employed to collect data that may include, but is not limited to:
• Browser or device type;
• Make and model of device;
• Operating system type;
• The time of your interaction with the Service;
• Your use of the Site and what websites you previously viewed;
• Device identifiers, such as IDFA, IP address, MAC address, or other such identifiers;
• Information about the websites you visit and mobile applications you use over time and across various devices and browsers;
• Hashed audio signatures about the viewing histories for television programs and advertisements; and
• Information about your location.

We may also receive information, such as demographic information, about you from certain third parties. We may combine any of the information we collect, and use and share it in the manner described in this privacy policy. The Service collects data to enhance your TV viewing experience, and to increase the relevancy of the advertising that you may see on TV and across various devices you use. However, the Service only operates if you have agreed to participate. If you agree to receive the Service, the Alphonso App, Independent Application or Hosted Application (as the case may be) receives short audio samples from the microphone on the device on which the Alphonso App is installed, or from the audio of content on your television. These raw audio samples are encoded (hashed) into digital "audio signatures" on your device. The audio signatures are then transferred from your device to Alphonso's servers where they are compared to pre-existing, commercial content (e.g., TV and OTT programming, advertisements, music, etc.). If a match is found, then appropriate content recommendations and/or advertisements may be delivered to your various devices. Alphonso's ACR technology is not designed to recognize human conversations or other ambient sounds. The audio signatures are matched against signatures for known, commercial audio content; and the audio signatures are associated with your IP address and/or device ID, but not your name, postal address, or email (PII).

Use & Sharing of Information.

Alphonso may use the various types of information it collects for a variety of purposes, including to:
• Maintain, operate, improve and provide the Service and our business;
• Analyze user trends and behaviors, and to generate reports;
• Deliver marketing materials on our behalf, and for other third parties, that we believe are relevant to you;
• Offer recommendations to you about television programing you may enjoy;
• To provide customer service;
• To monitor the Service for legal compliance, and compliance with your terms of use; and
• As otherwise disclosed at the time of collection.

Alphonso may share any data it collects with a variety of parties, including:
• Service providers, such as email and marketing fulfillment providers;
• With Independent Developers and Authorized Distributors with respect to users of their apps;
• With third parties for their direct marketing purposes;
• With third parties for reporting and analytics purposes;
• With our affiliated companies for their business and marketing purposes;
• As part of a corporate sale, merger, acquisitions, or other transfer of all or part of our assets, including as part of a bankruptcy proceeding. Alphonso’s successor will have all of the rights and be subject to all of the obligations of this Privacy Policy.;
• Pursuant to a subpoena, court order, or other legal process or as otherwise required by law, or to protect our rights, or the rights of third parties; or
• With your consent or as otherwise disclosed at the time of collection.

To learn about how you can control our use and sharing of information we collect, please see the “Your Choices” section of this policy. Alphonso may share data that does not identify you or your device specifically, such as aggregate or de-identified data, without restriction. Cookies.

"Cookies" are pieces of information that a website transfers to your computer’s hard disk for record-keeping purposes. Cookies are used to identify a user’s web browser. If applicable, you may be able to set your web browser to refuse Cookies, which in turn may affect your ability to access and use the Site, Service and, possibly, Independent Applications and Host Applications. Note that if you block cookies we may still collect information from your browser or device using different technologies. Our Business Partners and third parties who provide advertising using the Service may also use Cookies for the purpose of collecting and storing information across this website and other websites over time. Alphonso does not have access to or control over third party advertisers’ use of Cookies.

Your Choices.

Choice on Televisions and Other Video Devices: If you own a television or other device that includes the Service, you can consent to our collection and use of data about the video content you watch on that television to customize advertising in mobile apps, as well as provide you with television content recommendations. If you would like to withdraw that consent at any time, you can do so in the settings menu of your television.

Choice for Device Microphone Data: If you use a mobile application that includes the Service, you can also provide consent for us to access your microphone to collect and use data about the video content you watch on your television or other video viewing device to customize advertising in mobile apps, as well as provide you with television content recommendations. To withdraw that consent, you can use the the platform settings of your device as shown in our mobile opt out guide, available here. You could also withdraw consent at any time from the settings menu of your mobile app.

Interest-Based Advertising: We and certain third parties may collect information about your mobile app use activity and, through our Service, across non-affiliated mobile apps over time and across different devices you may use. We and these third parties may use this information to infer what you are interested in, and deliver more relevant advertising in mobile apps, and across various devices that may be associated with you. Other third parties may also collect data about the websites you visit over time to also provide more relevant advertising to you. This type of advertising is called interest-based advertising. Alphonso adheres to the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Principles regarding interest-based advertising.

To make choices about the collection, use, and, transfer of data from mobile apps on your mobile device, by Alphonso and other companies that participate in DAA’s AppChoices app, download the version of AppChoices for your device at www.youradchoices.com/appchoices. See also our mobile opt out guide, available here, for additional controls that may be available to you through your device platform. To control the collection of precise location data from your mobile device, you can use the location data controls that may be available in your device’s settings.

If you delete cookies, reset your device identifier, or use another browser or device, you may need to repeat your choices made through the tools described above. If you opt out, you will still receive ads, but these ads may be less relevant to you. Also, if you elect to opt out, we may still collect data for other purposes including analytics, reporting, content personalization, and other business purposes.

California Residents.

Under California Civil Code Section 1798.83 (the "Shine the Light" law), California residents who provide personal information in obtaining products or services from Alphonso are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. If you are a California resident and would like a copy of this information, please submit a written request to: Alphonso Inc.

     Alphonso Inc.
     Attn: Privacy Policy
     735 Industrial Rd, Suite 220
     San Carlos, CA 94070 USA
     E-mail: info@alphonso.tv

Children.

Alphonso will not collect personally identifiable or other information from any person who is actually known to us to be under the age of 13. If we become aware that a person under 13 has provided personally identifiable or other information, Alphonso will take steps to remove such information and terminate that individual's account, access and use of the Service.

Security.

Alphonso takes reasonable physical, technical, and administrative steps to help maintain information we collect, store, and use in a secure manner.

Non-US Users.

YOU HEREBY EXPRESSLY CONSENT TO THE TRANSMISSION, COLLECTION, STORAGE, PROCESSING AND USE OF YOUR USER DATA (INCLUDING PERSONAL INFORMATION) AND ANALYTICS IN ACCORDANCE WITH THIS PRIVACY POLICY. YOUR USER DATA (INCLUDING PERSONAL INFORMATION) MAY BE COLLECTED, STORED, PROCESSED, USED AND TRANSMITTED WITHIN, FROM AND TO THE COUNTRY WHERE IT WAS COLLECTED AND THE UNITED STATES. UNITED STATES LAWS REGARDING PROCESSING OF PERSONAL INFORMATION MAY BE LESS STRINGENT THAN THE LAWS IN YOUR COUNTRY.

Updates.

Alphonso reserves the right, at its sole discretion, to update, modify or replace this Privacy Policy, in whole or in part, at any time. Alphonso will use reasonable efforts to notify you of any material change approximately 30 days in advance of the effective date of any change. Change notices may be communicated by postings at or through the Site, Apps, SDK or otherwise. In any case, you should periodically check the Privacy Policy for changes. Continued access or use of the Service following any change to the Privacy Policy constitutes your acceptance of those changes. Information collected by the Service is subject to the Privacy Policy in effect at the time of use.

You may correct or otherwise change your registration data by contacting Alphonso, as provided below.

Contact.

If you have any questions regarding this Privacy Policy or your dealings with the Service, please contact us at:

     Alphonso Inc.
     Attn: Privacy Policy
     735 Industrial Rd, Suite 220
     San Carlos, CA 94070 USA
     E-mail: info@alphonso.tv