Effective Date: May 3, 2019
Alphonso Inc. develops and distributes certain “Video AI” software for set top boxes and smart televisions. Video AI refers to Alphonso’s ability to collect and analyze publicly available content (TV shows, advertisements, movies, video games) being played on or through a TV, including Alphonso’s automatic content recognition (ACR) collection technology. The Video AI data collection, storage, analysis and reporting tools are collectively referred to as the Service.
The following policy explains how Alphonso collects, uses and shares information when consumers interact with the Service. Alphonso complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Economic Area to the United States. For more information see “For Users in the European Economic Area” below.
Whenever you interact with the Service, you provide your consent a variety of technologies employed to collect data, which may include:
• Device type;
• Make and model of device;
• Operating system type;
• The time of your interaction with the Service;
• Device identifiers, such as IDFA, IP address, MAC address, or other such identifiers;
• Information about your location.
The Service only collects data from your device if you have agreed to participate. If you agree, the Service may collect video and/or audio information from what you are watching through your device, regardless of the source of the information (e.g., TVs, video and audio streaming devices, set-top boxes, etc.) in order to determine the programs you have watched and the advertisements you have seen. The information collected (the “Viewing Data”) is used by Alphonso and shared with third parties (the “Data Partners”). The Service may also collect your Device’s IP Address, and associate your Viewing Data to that IP Address and/or a device ID. Viewing Data is never associated with name, postal address, or email. Importantly, Alphonso’s Video AI is not designed to recognize human conversation, ambient sounds, and other non-commercial audio or video content.
Use & Sharing of Information
Alphonso and its Data Partners uses the various types of information it collects for a variety of purposes, including to:
• Maintain, operate, improve and provide the Service;
• Analyze user trends and behaviors, and to generate reports;
• Deliver marketing and advertising materials on our behalf, and for other third parties, that we believe are relevant to you;
• Offer recommendations to you about programing content on your TV and other devices we believe you may enjoy; and
• As otherwise disclosed at the time of collection.
Alphonso also uses the various types of information it collects in its legitimate interest:
• To maintain, operate, improve our business;
• To support our business development efforts;
• To provide customer service, communicate with and market to our customers;
• 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 select third parties that will use the information for their own business purposes including ad targeting and measurement for participants in the Service and other users;
• 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;
• 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, or to withdraw consent that you previously provided, please see the “Your Choices” section of this policy. Please note that if you do not provide consent, or if you choose to withdraw your consent, the advertising you see in mobile apps may be less relevant to you and you will not receive personalized content recommendations on your TV. You have the right to withdraw your consent at any time. Alphonso shares data that does not identify you or your device specifically, such as aggregate or de-identified data, without restriction.
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 where the Service is integrated.
If you would like to exercise choice regarding interest-based advertising in this browser, you can visit www.aboutads.info/choices. 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 via www.youradchoices.com/appchoices.
When you make choices regarding interest-based advertising through the tools described above, we will stop using data from that device for interest-based advertising on that device and on associated devices. We will also stop using data collected from associated devices for interest-based advertising on the device where choice was exercised.
Marketing E-mails: If you receive marketing emails from Alphonso regarding our products and services, you can unsubscribe from these emails through opt-out included in that e-mail.
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:
2440 W El Camino Real
Mountain View, CA 94040
Alphonso will not knowingly collect personally identifiable or other information from children under the age of 13 (or an age set by local law in a jurisdiction where we offer our Services). Where information is collected electronically, Alphonso may not be able to determine whether information was collected from a someone under the age of 13, and such information is treated as if it had been collected from an adult. 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 access and use of the Service.
Alphonso takes reasonable physical, technical, and administrative steps to help maintain information we collect, store, and use in a secure manner.
Alphonso retains data we collect to support our Site and Service only as long as it is needed to provide our services to our customers or for our use for our legitimate interest such as accounting and legal compliance, and after this time, that data is deleted or de-identified.
For Users in the European Economic Area
You hereby expressly consent to the transmission, collection, storage, processing and use of your User Data (including personal information) and Analytics within, from and to the United States, in addition to the country where you are located (if not the United States). Alphonso makes no representation that the Service is accessible, appropriate or legally available for use in locations outside the United States, and accessing and using the Service is prohibited from territories where doing so would be illegal. If you access or use the Service from other locations, then you do so at your own initiative and are responsible for compliance with local laws.
EU-U.S. Privacy Shield: Alphonso complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Economic Area (EEA) to the U.S. for the transfer of personal information to the U.S., as that term is defined in the Privacy Shield Framework. Alphonso has certified to the Department of Commerce that we adhere to the Privacy Shield Principles of notice, choice, accountability for onward transfers, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the terms in this policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov.
By participating in the EU-U.S. Privacy Shield Framework, Alphonso is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. For more information about the EU-U.S. Privacy Shield, please visit https://www.privacyshield.gov/list.
Individual Rights: We recognize that individuals from the EEA have certain individual rights under European law with respect to your personal data, including the right to request access to, correct, amend, delete, or limit the use of your personal data under certain circumstances. If you wish to exercise these rights, and we are required to effectuate those rights, please reach out to us at firstname.lastname@example.org. In addition, please see the “Your Choices” section above for information about how to withdraw your consent to our collection of personal data. You have the right to withdraw your consent at any time. You also have the right to lodge a complaint with the applicable supervisory authority in the member state of your residence.
2440 W El Camino Real
Mountain View, CA 94040 USA