Last Updated: October 26, 2018
This Policy applies to all of our products and services (“Samba Services” or the “Services”). Our Services include Samba Interactive TV and other Smart TV apps (“Smart TV Services”), our websites (e.g. www.samba.tv), and our mobile apps (e.g. Samba TV Mobile). Our Services also include our products and services that may be integrated into third-party websites, mobile apps and Smart TV apps (“Integrated Services”).
Your privacy matters to Samba TV. If you have any questions please contact us at email@example.com or as described below in the Contact Us section.
Collection of Information
Information You Provide to Us
We collect information you provide directly to us. For example, we collect information when you create an account, update your profile, participate in certain interactive features of the Services, fill out a form, request customer support, or communicate with us. The types of information we collect may include your name, email address, phone number, interests and preferences, location, and other information you choose to provide.
Information We Get When You Use Our Services
We collect information about the Services you or your household use and how they are used, such as when you watch a video on Hotlist, visit a third-party website or app that uses our Integrated Services, or interact with our ads and content. This information includes:
We automatically collect standard log files when you use our Services, which include the time and date of access, pages or features viewed, IP address, the type of web browser you use, and the referral URL.
We collect information about the devices you use to interact with our Services. This device-specific information may include the hardware model and brand, operating system, device identifiers, resource usage, and error logs. We may also discover when your Smart TV is available to connect with a mobile device, which can, for example, be used to make pairing your devices easier.
Content Viewing Information:
We receive information about the content you view and interact with through a Smart TV that integrates our Smart TV Services or through Smart TV Apps (“Content Viewing Information”). Content Viewing Information includes things like the title of the content, actions taken while viewing the content, and the length of time you viewed it.
We receive this information in two principal ways:
- Smart TV Apps: We may receive such viewing information when you use our Smart TV Apps or third-party Smart TV apps that use our Integrated Services.
- Smart TV Services: When you opt-in to our Smart TV Services, we may recognize the content played through your TV. Please note, we are only able to recognize public content, such as certain shows and movies. We won’t know when you’re watching, for example, home videos.
Precise Location Information:
With your consent, we may collect information about the precise location of your device, including when you access or use one of our mobile apps or an app that uses our Integrated Services.
Information Collected by Cookies and Other Technologies:
We use various technologies to collect information when you interact with our Services. These technologies include cookies, local storage and web beacons. Cookies and local storage are small data files that are stored on your device when you visit a website. Cookies and local storage enable us and our customers to provide features and functionality (such as keeping you logged in), measure the popularity of our Services, and monitor their performance.
Web beacons (or pixel tags) are electronic images that may be used in our Services or emails to help deliver cookies, count website visits, and determine the effectiveness of email marketing campaigns. Our cookies are set to expire twenty-four (24) months from the last time our systems encounter a particular computer or device.
Information from Integrated Services:
We collect information when you visit or use third-party websites and apps that use our Integrated Services, including through the cookies and other technologies described above. For example, when you elect to pair a broadcaster’s app to your TV, that broadcaster can use our technology to synchronize your experience on their mobile apps as you watch a show on your TV. Also, third-party apps and websites can use our measurement and advertising services to better understand usage of their services and enable the delivery of interest-based advertisements. The information we collect includes information about your use of those websites and apps, as well as information those apps or websites enable us to collect from their services. For example, a streaming video provider may enable us to receive information about the content you watch so that our recommendation service can suggest additional content that you might like.
You may opt out of providing information through our Integrated Services by following the instructions under the “Web and Mobile Apps” heading in the “Your Rights and Choices” section below.
Information We Collect from Other Sources:
Where the law permits, we may also obtain information from other sources and combine that with information we collect through our Services. For example, we might obtain information from data providers and advertising exchange services, including assumed demographics and interests, and data about your engagement with our ads.
Also, if you create or log into your Samba TV account through a social media service, we will have access to certain information from that service based on the settings and authorizations you grant us through that service.
Use of Information
We may use the information we collect to:
- Provide, maintain and improve our Services (for instance, we use information we collect to refine the user experience, fix service malfunctions, test our security systems and increase our technical performance);
- Monitor and analyze usage of our Services;
- Personalize our Services and deliver recommendations, advertisements, content and features that match your interests;
- Improve our advertising and measurement systems so we can show you relevant ads on and off our Services (for example, if you are interested in cooking shows, we may serve you ads for new TV cooking programs);
- Communicate with you about products, services, offers and events offered by Samba TV or others, and provide content we think you will find interesting;
- Respond to your comments and questions and provide customer service; and,
- Detect, investigate and prevent fraudulent and other illegal activities, and protect the rights, safety and property of Samba TV and others.
To clarify, information we receive about you or your household from using one device or Smart TV may be combined with information we receive from use of other devices or Smart TVs. For example, if we know you love watching football on your Smart TV, we may show you real-time football stats on your mobile device. You may always opt out of receiving such tailored content on your household devices by following the instructions set forth in the “Your Rights and Choices” section below.
Sharing of Information
Information You Share
When you submit a post to any interactive areas of our websites or apps, users of those services may be able to see the posts, your username and when you submitted the post.
Information We Share
We may share the information we collect about you with third parties in the following circumstances:
With Your Consent or at Your Direction:
At your direction or if we have your consent to do so, we will share information with companies, organizations or individuals outside of Samba TV. When you authorize us to share information about you with other companies, you should review their privacy policies to understand how they may use and treat your information.
With Vendors, Consultants, and Data Processors:
We may share information with vendors, consultants and data processors, service providers and other trusted businesses who work on our behalf and make our business-to-business activities in digital advertising possible.
For Legal Reasons:
We may share information with companies, organizations, or individuals outside of Samba TV: in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, legal process or national security requirements; if we believe your actions are inconsistent with our user agreements; or, to protect the rights, property or safety of Samba or others.
With Our Corporate Family:
We may share information between and among Samba TV’s current and future parents, affiliates, subsidiaries and other companies under our common control and ownership. We rely on our legitimate interests to do so in order to administer and deliver our Services as described in this Policy.
We may also share information in connection with any merger, sale of assets, financing or acquisition of all or a portion of our business by another company.
When You are not Directly Identified:
We may share certain information, such as Content Viewing Information, that does not, on its own, directly identify you as an individual. We may share this information with our partners and customers (including for advertising and analytics purposes), and the public. We may, for instance, publish aggregated reports regarding how many people viewed a particular TV show. Or, we may share data about your device with advertising platforms to help make the ads you see more relevant to you.
To clarify, the personal information that we share will not directly identify you, but may indirectly identify you through, for example, your device or other means. The types of personal information we may share include device IDs, advertising IDs, IP addresses, hashed/encrypted versions of your email address or other identifier, or pseudonymous IDs.
Analytics and Advertising Services Provided by Others
We engage other companies to serve advertisements on our behalf across the Internet and provide analytics services to us.
Samba TV takes reasonable and appropriate security measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
Samba TV is striving to make our services available globally. We are based in the United States and currently have subsidiaries in the United Kingdom, Poland and Taiwan. In the future Samba TV may also establish additional affiliates and subsidiaries in other countries.
To facilitate our operations and to help deliver our Services globally, we may transfer personal information to the U.S. and any other country where our affiliates, subsidiaries, vendors, consultants and service providers operate. For example, we may transfer your personal information to Samba’s servers in the U.S. to provide you with relevant recommendations on Samba TV Mobile.
When we transfer personal data outside of the EEA or Switzerland, we ensure an adequate level of protection for the rights of data subjects based on: the adequacy of the receiving country’s data protection laws, contracts that place obligations on the recipient of the data pursuant to model clauses approved by the European Commissions, or EU-US and Swiss-US Privacy Shield principles (the “Principles”). Samba TV is a participant in the EU-US Privacy Shield and Swiss-US Privacy Shield programs (https://www.privacyshield.gov/list).
If you have a Privacy Shield-related complaint, please contact us at firstname.lastname@example.org. As part of our participation in Privacy Shield, if you have a dispute with us about our adherence to the Principles, you may address it through our internal complaint resolution process, or through the independent dispute resolution body JAMS at no cost to you.
Privacy Shield participants are subject to the investigatory and enforcement powers of the US Federal Trade Commission and other authorized statutory bodies. Under certain conditions you may invoke binding arbitration before the Privacy Shield Panel. Learn more about the EU-US Privacy Shield and Swiss-US Privacy Shield here.
Please note that for data transfers involving personal data from Argentine data subjects, we will rely on the principles and standards of the model contract clauses approved by the Argentine Data Protection Agency in Disposition 60/E/2016, for the transfer of personal data to countries that, according to the Agency, do not provide an adequate level of data protection.
If you would like more information, please feel free to contact us through the email or at the address provided in the Contact Us section.
Your Rights and Choices
Below are the rights and choices we provide in connection with the practices described in this Policy.
Smart TV Services
We require TV manufacturers to provide you with an opt-in to enable our Smart TV Services that collect Content Viewership Information. This opt-in will usually be presented when you first set up your Smart TV, or after your Smart TV gets a software update that includes our Smart TV Services.
You should be able to opt out of, or in to, our Smart TV Services at any time your TV is connected to the Internet. You typically can find our opt-out and opt-in feature in the “settings” menu of your TV or within the Smart TV Services user interface. If you have trouble finding this feature, you should contact the TV manufacturer to determine the exact location. If you opt out of our Smart TV Services, we will no longer collect TV viewing information through this service. However, we still may receive Content Viewership Information, as described above in the “Collection of Information” section, when you watch content through certain Smart TV Apps.
Also, if you opt out of our Smart TV Services, you will not be able to take advantage of our interactive features on your Smart TV; or, features of other applications that rely on Smart TV Services to operate (after you authorized their use), such as receiving content recommendations based on the shows you love, interacting or playing along with your favorite shows using your TV remote or mobile device, accessing exclusive content and offers, resuming a show from where you left off and receiving notifications when the show you were watching returns from commercial.
You may also choose to enable Limit Ad Tracking from the Privacy menu within Smart TV Settings on your Smart TV. If you do so, our advertising platform will opt your Samba TV Advertising ID out of receiving targeted advertising based on Content Viewing Information from Smart TV Services, regardless of what device you are using. Note that whenever you want to unlink the data associated with your Samba TV Advertising ID, you can simply reset it. Please check with the TV manufacturer for the exact location of these features. If you cannot find them or your TV manufacturer has not enabled them, please contact us at email@example.com.
If you intend to sell or otherwise give away your Smart TV, you should perform a “factory reset.” This will 1) reset the Samba TV advertising ID, and 2) allow the new owner of the TV to choose whether they want to opt-in or opt-out. If you sell or give away your Smart TV without performing a “factory reset,” information about the new owner may be incorrectly attributed to you.
Web and Mobile Apps
Samba TV is an active member of the Network Advertising Initiative (“NAI”), an industry association that develops the policies around online consumer privacy in the context of interest-based advertising. Samba TV complies with the NAI Code of Conduct. Consistent with our commitment to the NAI principles, we provide means for you to opt out of interest-based advertising based on your web browsing and mobile app usage:
You can opt out of having Samba use your web browsing information for interest-based advertisements by visiting http://optout.networkadvertising.org or accessing “Opt out of Samba TV Ads” using the opt-out link available below.
For the most effective and up-to-date methods to limit ad tracking on your mobile device, please refer to your mobile operating system settings to see how you can opt out of interest-based advertisements, or reset your mobile device advertiser ID to unlink information previously associated with your advertiser ID.
You may learn more about interest-based advertising, as well as pertinent self-regulatory frameworks — and companies like Samba TV that strive to embrace such regimes — by visiting the NAI (https://www.networkadvertising.org) or the Digital Advertising Alliance (http://digitaladvertisingalliance.org).
Cookies and Local Storage
If you prefer, you can usually choose to set your browser to remove or reject browser cookies or to clear local storage. Please note that if you choose to remove or reject cookies or clear local storage, this could affect the availability and functionality of our Services.
You can turn location-based services on and off by adjusting the settings of your mobile device.
Account Information and Requests
In accordance with applicable law you may have the right to access, update or delete personal information we hold about you, including deleting Content Viewing Information. This means you may have the right to 1) be informed of the personal information we collect, how we use it, what personal information we have shared with third parties, and to be provided with a copy of that information; and 2) have corrections made, or have the information deleted if it is not accurate or processed in violation of applicable laws. You may be able to exercise these rights by logging into your online account within the Samba TV products and services that you use. Otherwise please submit a written request using the details provided in the Contact Us section below.
Further, if you are from certain territories, you may have the right to exercise additional rights available to you under applicable laws, including broader rights to access and erasure of your personal information, the right to object to or restrict processing of your personal information, or the right to data portability in certain circumstances. If you would like to make such a request, please contact us at firstname.lastname@example.org or at the address provided below in the Contact Us section.
We will consider all requests in accordance with applicable laws. To obtain access to your personal information, we may require that you provide additional information to confirm your identity. This confirming information will only be used to process your request. To correct any information we have about you, please send a correction request following the same instructions as above.
Remember that in certain jurisdictions you also have the right to complain to a dataprotection authority (“DPA”) about our collection and use of your personal information. For moreinformation, please contact your local DPA in the EU or the Swiss Federal Data Protection and InformationCommissioner. In addition, as discussed above, if you are from the EEA or Switzerland and you have a dispute withus about our adherence to the Principles, you may address it through our internal complaint resolution process,or through the independent dispute resolution body JAMS at no cost to you.
Retention of Information
We may store Content Viewership Information so long as you continue to have a relationship with our Smart TV Services. Content Viewing Information may be stored up to ten (10) years from the last time our Services encounter a particular device unless you ask us to delete that information by following the instructions above.
From time to time, we may send you marketing communications about our products and services, in accordance with your preferences. You may opt out of receiving promotional messages from us at any time by following the instructions in those messages (often it will be a notice or link at the bottom of the message). If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
Mobile Push Notifications
With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
Withdrawal of Consent
Where we rely on your consent to process your personal information, you have the right to withdraw your consent at any time.
Legal Basis for Processing (EEA and Switzerland)
If you are an individual from the EEA or Switzerland, our legal basis for collecting and using your personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where: 1) we have your consent to do so, 2) where we need the personal information to perform a contract with you (such as delivering the Services to you), or 3) where the processing is in our or a third party’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.
Where we rely on your consent to process personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent prior to its withdrawal.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and let you know whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide it). Similarly, if we collect and use your personal information in reliance on our (or a third party’s) legitimate interests which are not already described in this policy, we will make it clear to you at the relevant time what those legitimate interests are.
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at email@example.com or at the address provided below in the Contact Us section.
Rights of Argentine Data Subjects and Legal Basis for Processing Their Data
Please be aware that if you are an Argentine data subject, you have the right to access, delete, update or amend your personal data under Argentina’s Data Protection Act.
If you are an individual from Argentina, the legal basis for processing your personal data, as well as collecting and using your personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where: 1) we have your consent to do so, and 2) the existence of a contractual relationship between you and Samba TV by the virtue of the use of our products and services.
The owner of the personal data has the right to exercise and the right of access his or her data free of charge at intervals of not less than six months, unless a legitimate interest is accredited for the purpose as established in article 14, subsection 3 of the Law No. 25,326. In addition, the owner of personal data also has the right to update or request the deletion of his or her personal data pursuant to article 16 of Law 25,326.
The NATIONAL DIRECTORATE OF PROTECTION OF PERSONAL DATA, Body of Control of Law No. 25,326, has the power to address complaints and claims that are filed in relation to the breach of the rules on protection of personal data.
Argentine data subjects who wish to file a formal complaint regarding the collection and use of their personal information by Samba TV must contact the Agency for Access to Public Information at:
Av. Pte. Gral. Julio A. Roca 710, Piso 2°,
Ciudad de Buenos Aires
Tel: +5411 2821-0047
We may change this policy from time to time. If we make changes, we will revise the date at the top of the policy and provide notice. Such notice may take various forms, such as updating the date on the top of the policy, adding a statement to our website, sending you an email, or providing an on-screen notification on your Smart TV.
If you have any questions or complaints regarding this policy or about Samba TV’s privacy practices, please contact us at firstname.lastname@example.org, or at:
Free Stream Media Corp.
123 Townsend St, 5th floor
San Francisco, CA 94107
You may also contact our Data Protection Officer at email@example.com, or at:
Lucid Privacy Group
1556 Shrader St.
San Francisco CA 94117
If you are a resident in the EEA or Switzerland, please note that the data controller responsible for your personal information is Free Stream Media Corp. in the United States.
We will respond to all inquiries in accordance with the applicable data privacy laws.