PRIVACY POLICY

Effective Date: October 22, 2018.

1. Introduction and Overview.

This Privacy Policy describes how Film Bureau LLC ("Film Bureau," "we," "our," or "us") collects, uses, and shares information about you and applies to your use of any online service location that posts a link to this Privacy Policy and all features, content, and other services that we own, control and make available through such online service locations (collectively, the "Service"). This Privacy Policy does not apply to our information collection activities offline or otherwise outside of the Service (unless otherwise stated below or at the time of collection).

By using the Service, you agree and consent our Terms of Use, Video Privacy Notice and Consent, Children's Privacy Notice, and to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree and consent, discontinue use of the Service.

If you have any questions about our privacy practices, please contact us as set forth in the section entitled "Contact Us" below.

2. Information Collection.

A. Information You Provide.

We collect information you provide directly via the Service, such as when you access or make changes to your account, view digital screeners, or contact customer support. We may use Service Providers (defined below) to collect this information.

The information we collect includes information that identifies you personally (whether alone or in combination). Some examples of information we collect include the following:

• Contact Data, including your first and last name, e-mail address, postal address, and phone number.
• Account Credentials, including your username, password, password hints, and information for authentication and account access.
• Demographic Data, including your age, gender, and country.
• Profile Data, including what company you work for, the title of your position, your Voting Group (defined below) membership, and your interests and favorites.
• Content, including the content of any messages you send to us, such as feedback and product reviews you write, or questions and information you provide to customer support.

You may choose to voluntarily submit other information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.

B. Information Collected Automatically.

We automatically collect information about your device and how your device interacts with our Service. We may use Service Providers to collect this information. Some examples of information we collect include the following:

• Service Use Data, including data about the number of times you view particular digital screeners, the percentage of digital screeners you view, the geographic area where you access the digital screeners, the features you use and content you access, the pages you visit, the day and time you browse and view content, and your referring and exiting pages.
• Device Connectivity and Configuration Data, including data about the type of device or browser you use, your device's operating software, your internet service provider, your device's regional and language settings, data regarding network connected hardware (e.g., Apple TV or Roku) and device identifiers such as IP address.
• Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level) and, with your consent, precise location data (such as latitude/longitude data).

We use various current – and later – developed technologies to collect this information ("Tracking Technologies"), including the following:

• Log Files. A log file is a file that records events that occur in connection with your use of the Service, such as your service use data.
• Cookies. A cookie is a small data file stored on your device that acts as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
• Pixels. A pixel (also known as a web beacon) is code embedded in a website, video, or e-mail that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, or e-mail that contains a pixel, the pixel may permit us or a third party to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from third parties that allow us track our conversions and provide you with additional functionality.
• Device Fingerprinting. Device fingerprinting is the process of analyzing and combining sets of information elements from your device's browser, such as JavaScript objects and installed fonts, in order to create a "fingerprint" of your device and uniquely identify your device.
• Location-Identifying Technologies. GPS, WiFi, Bluetooth, and other location-aware technologies may be used to collect precise location data when you enable location-based services through your device. Location data may be used for purposes such as verifying your device's location and delivering or restricting relevant content based on that location.

For further information on Tracking Technologies and your rights and choices regarding them, see the sections entitled "Third Parties" and "Your Rights and Choices" below.

C. Information from Other Sources.

We also obtain information about you from other third party sources. To the extent we combine such third party sourced information with information we have collected about you through the Service, we will treat the combined information in accordance with the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data. These third party sources vary over time, but have included:

• Membership lists from the guilds, unions, trade associations, or other organizations participating in the voting-based awards program and in which you are a member ("Voting Groups").
• Partners with which we offer co-branded services or engage in joint marketing activities.
• Publicly-available sources and data in the public domain.

For further information on Third Party Services, see the section entitled "Third Parties" below.

3. Use of Information.

We use information we collect in accordance with the practices described in this Privacy Policy, including to:

• Manage our Service, including your registration and account.
• Provide access to view digital screeners including the video, audio, images, music, graphics, software, and text contained therein.
• Use information as directed by your Voting Group and as your Voting Group permits us to.
• Respond to your comments, questions, and requests, and provide customer service.
• Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
• Prevent and address fraud, breach of policies or terms, and threats or harm.
• Enforce the content protection and anti-piracy policies of Film Bureau and the studios, independent film makers, and other individuals or entities that own, license, have intellectual property rights in, or have provided digital screeners to us for use on the Service ("Content Providers").
• Monitor and analyze trends, usage, and activities.
• Conduct research, including focus groups and surveys.
• Improve the Service or other Film Bureau websites, apps, marketing efforts, products and services.
• Develop and send you direct marketing, including communications about our and third party products, offers, promotions, rewards, events, and services.
• Fulfill any other purpose disclosed to you, at your direction, or with your consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled "Your Rights and Choices" below.

4. Sharing of Information.

We share information we collect in accordance with the practices described in this Privacy Policy, including as follows:

• Service Providers. We share your information with our agents, vendors, and other service providers (collectively "Service Providers") in connection with their work on our behalf. Service Providers assist us with services such as data analytics, marketing and promotional services, website and digital screener hosting, and technical support. Service Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for other purposes.
• Affiliates. We may share your information with our related entities. For example, we may share your information with our affiliates for customer support, marketing, and technical operations.
• Business Partners. We may share your information with our business partners in connection with offering you co-branded services or engaging in joint marketing activities.
• Content Providers. We may share your information with Content Providers.
• Voting Groups. We may share your information with your Voting Groups for their own business and marketing purposes.
• Merger or Acquisition. We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
• Security and Compelled Disclosure. We may share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share your information to protect the rights, property, life, health, security and safety of us, the Service or any third party.
• Direction or Consent. We may share your information to fulfill any other purpose disclosed to you, at your direction, or with your consent.

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) with third parties except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled "Your Rights and Choices" below.

5. Viewing Information.

In certain circumstances, we may need to share information about the videos you view on our Service along with other information we have about you, including information you have provided to us (such as your name or address) and information we have automatically collected (such as an IP address, device identifier, or precise location data). By using the Service, you consent to our doing so, including the collection, use, and sharing as described in our Video Privacy Notice and Consent. For more information, please review that policy.

6. Third Parties.

A. Third Party Services.

Our Service contains content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties ("Third Party Services"). These Third Party Services may use Tracking Technologies to independently collect information about you and may solicit information from you. The information collected and stored by third parties, whether through our Service, a Third Party Service, a Third Party Feature (defined below), or a third party device, remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

B. Analytics.

Our Service contains Tracking Technologies owned and operated by Third Parties. For example, we use Tracking Technologies from third party analytics provides, such as Google Analytics, to help us analyze your use of the Service, compile statistic reports on the Service's activity, and provide us with other services relating to Service activity and internet usage.

For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled "Information Collected Automatically" above and "Your Rights and Choices" below.

7. Your Rights and Choices.

A. Account Information.

You may access, update, or remove certain information that you have provided to us through your account by sending an e-mail to the e-mail address set forth in the section entitled "Contact Us" below or visiting your account settings. If you send an e-mail, we may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

B. Tracking Technology Choices.

Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.

Your browser settings may allow you to automatically transmit a "Do Not Track" signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to "Do Not Track" signals or other mechanisms. For more information on "Do Not Track," visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not function correctly.

C. Analytics.

You can opt-out of your data being used by Google Analytics through cookies by visiting https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.

D. Communications.

You can opt-out of receiving promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link, or e-mailing us at the e-mail address set forth in the section entitled "Contact Us" below with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that you cannot opt-out of non-promotional e-mails, such as those about your account, transactions, servicing, or Film Bureau's ongoing business relations.

E. Your California Privacy Rights.

California's "Shine the Light" law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties' and affiliates' own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing.

Film Bureau may share personal information as defined by California's "Shine the Light" law with third parties and/or affiliates for such third parties' and affiliates' own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set forth in the section entitled "Contact Us" below. Requests must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Film Bureau is not required to respond to requests made by means other than through the provided e-mail address or mail address.

F. Your European Privacy Rights.

Data subjects in Europe have additional rights as set forth in the "Additional Disclosures for Data Subjects in Europe" section below.

8. Children.

The Service is not directed toward children and we do not knowingly collect information from children through the Service without verifiable parent consent. Where we obtain verifiable parental consent, we may allow Voting Group members who are children to use the Service. For details on how we treat information from Voting Group members who are children, please visit our Children's Privacy Notice. If you believe Film Bureau has collected information from children in violation of applicable law, please contact us as at the e-mail address set forth in the section entitled "Contact Us" below.

9. Data Security.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect your information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information.

10. International Transfer.

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the U.S. and other jurisdictions as set forth in this Privacy Policy. If your data is collected in Europe, we will transfer your personal data subject to appropriate safeguards, such as Standard Contractual Clauses.

11. Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice, to your e-mail address.

12. Contact Us.

If you have any questions or comments about this Privacy Policy, please contact us:

By e-mail:

[email protected]

By mail:

Film Bureau LLC
556 S. Fair Oaks Ave.
Suite 101-605
Pasadena, CA 91105

13. Additional Disclosures for Data Subjects in Europe.

A. Data Controller.

Data protection laws in Europe make a distinction between organizations that process personal data for their own purposes (known as "controllers") and organizations that process personal data on behalf of other organizations (known as "processors").

Film Bureau acts as a controller with respect to personal data collected as you interact with the Service. In other instances, Film Bureau acts a processor on behalf of its customers, separate legal entities, which are the controllers. For example, Film Bureau processes personal data provided to it by your Voting Group in order to allow your Voting Group to provide you with access to the Service. Please visit the applicable customers' privacy policy for information about their privacy practices. Any questions that you may have relating to the processing of personal data by Film Bureau on behalf of its customers and your rights under data protection law should be directed to the customers as the controllers, not to Film Bureau.

B. Lawful Basis for Processing.

Data protection laws in Europe require a "lawful basis" for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our Service Providers, partners, or customers; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.

C. Your European Privacy Rights.

If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

You may exercise your rights by submitting a written request to us at the address set forth in the "Contact Us" section above. We will respond to your request within 30 days. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

If your personal data has been processed by us on behalf of a customer and you wish to exercise any rights you have with such personal data, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal data. We will refer your request to that customer, and will support them to the extent required by applicable law in responding to your request.

D. Complaints.

If you have a complaint about our use of your personal data or response to your requests regarding your personal data, you may submit a complaint to the data protection regulator in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator, and would welcome you directing an inquiry first to us.