Effective Date: January 1, 2022
The following policy is intended for users of Smart TVs in Canada.
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.
This policy explains how Alphonso collects, uses and shares information when consumers interact with the Service, in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA).
To what information does this policy apply?
This policy is intended to apply to personal information. In general, personal information is any information about an identifiable individual, such as an individual’s home address, telephone number, email address or ID number. However, for the purposes of the Service, only the information listed below is collected; the Service does not collect names, addresses or telephone numbers.
This policy does not apply to anonymous information – which is any information that does not include an individual’s name, contact information or any other information that could reasonably be expected to identify the individual.
You opt-in to the Service through the configuration options on your Smart TV, either during the initial setup, or by going back to the settings menu and selecting the option to opt-in to ACR. Similarly, you may opt-out of the Service at any time through the settings menu on your Smart TV, by turning off ACR within the settings.
The Service’s technology is based on the general desire to understand how your Smart TV is being used, and more specifically on the programming and advertising that is being played through the Smart TV. The information collected through the service is limited to data collected from the Smart TV and connected devices. The information may include:
- Device type, make and model;
- Operating system type and version;
- Technical details relating to the device (which may include things like the kind of computer chip being used by the device, the language being used by the device, configuration details, audio sample rate, and the size of the device’s screen);
- The time of your interaction with the Service;
- The source of the video and/or audio information (which may include the number of the channel being watched);
- Device identifiers (which may include things like your device’s IP address, MAC address and device name);
- Information about your location; and
- Program and advertisement data (referred to as “Viewing Data” and explained below).
Viewing Data is 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.). We collect this Viewing Data to determine the programs you have watched and the advertisements you have seen. While the Service does collect device identifiers which are associated with your Viewing Data, your Viewing Data is never associated, in any of the materials we provided to Clients, with your name, postal address, or email. Importantly, the Service does not recognize human conversation, ambient sounds, and other non-commercial audio or video content.
Purposes: Use & Sharing of Information
Alphonso differentiates between Service Providers, Data Partners and Clients.
Service Providers receive Viewing Data which may include device identifiers. Service Providers do a variety of tasks, including performing matches to append data, performing blind matches so that data sets can be created that have no identifying criteria (e.g., no device identifiers), or services relevant to advertising to you. These Service Providers are contractually limited in how they are allowed to use any Viewing Data, and are required to delete all Viewing Data once they have performed their function.
Data Partners receive Viewing Data which may include device identifiers. They are able to use the data to create products that will be sold or otherwise shared with Clients. Data Partners are allowed to keep Viewing Data for however long they need, but they are contractually required to ensure that none of the products they provide to their clients will include any data that can be used to identify you. Additionally, all Data Partners contractually agree to delete data related to any particular individual in response to a verified request received by either the Data Partner or Alphonso, in accordance with any applicable privacy law or regulation.
Clients will only receive Viewing Data in aggregated or anonymized form. They are able to use the data however they like, and can keep the data for however long they choose. But, again, none of that data is identifiable to an individual.
Alphonso and its Service Providers use Viewing Data for a variety of purposes, including to:
- Deliver marketing and advertising materials on our behalf, and for other third parties, that we believe are relevant to you, both to your Smart TV as well as to other devices that are connected to your Smart TV, either directly or through wireless connections;
- Offer recommendations to you about programing content on your TV and other devices we believe you may enjoy; and
- Perform marketing services.
Alphonso and its Data Partners use Viewing Data for a variety of purposes, including to:
- Maintain, operate, improve and provide the Service; and
- Generate reports analyzing user trends and behaviors.
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; and
Alphonso may share any data it collects with a variety of parties, including:
- 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.
You have the right to withdraw your consent at any time. 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 below. Please note that if you do not provide consent, or if you choose to withdraw your consent, the advertising you see on your devices may be less relevant to you, and you will not receive personalized content recommendations on your TV.
You opt-in to the Service through the configuration options on your Smart TV, either during the initial setup, or by going back to the settings menu and selecting the option to opt-in to ACR. If you choose to opt-in to the Service, you consent to our collection and use of data about the video and audio content on that Smart TV to customize advertising in other connected devices, to provide you with television content recommendations, and for other uses as outlined above. If you would like to withdraw that consent at any time, you can do so in the settings menu of your Smart TV, by turning off ACR within the settings.
If you would like to exercise choice regarding interest-based advertising on a browser, you can visit www.aboutads.info/choices. To make choices about interest-based advertising on a mobile device, you can download the version of AppChoices for your device via www.youradchoices.com/appchoices.
If you choose to opt-out of interest-based advertising through the tools described above, we will stop using data from that device for interest-based advertising on that browser, mobile 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.
Personal information collected through the Service may be stored or processed in or outside Canada. The information will be protected with appropriate safeguards, but may be subject to the laws of the jurisdiction where it is held.
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. These steps include the hashing (or other encryption) of data, along with limitations on who is allowed to access an personal data.
Alphonso retains data we collect through the Service only as long as it is needed to provide our services or for our legitimate interest (such as accounting and legal compliance). After this time has passed, that data is deleted or de-identified.
You may access or review the information we have about you. You can challenge its accuracy and completeness and request amendments, as appropriate, by contacting us in writing at Chief Privacy Officer, Alphonso Inc., 211 Hope Street, Suite 390905, Mountain View, CA 94041.
You can also visit the privacy pages at https://www.alphonso.tv/privacy for more information.
211 Hope Street, Suite 390905
Mountain View, CA 94041 USA
Or to contact the privacy official directly, please feel free to communicate with our General Counsel and Chief Privacy Officer at firstname.lastname@example.org.