The purpose of Samba TV’s Privacy Policy is to explain how you can control the personal information we collect. We build our products to improve television and that includes empowering you to make decisions about your privacy. Samba TV continuously strives to follow the Golden Rule: we handle your information in the same way we would expect ours to be handled. If you have any questions about this policy or how we handle your information, please contact us at privacy@samba.tv or as described in Section 11 (Contact Us).
Last Updated: July 12, 2021
We, Samba TV, Inc., and our affiliates and subsidiaries, which include Samba TV UK Limited, Samba TV Poland Sp.zo.o, Samba TV Germany Gmbh, Screen6 B.V., and Samba TV Taiwan Branch (collectively “Samba TV”, “Samba”, “we”, “us” or “our”), know you care about how your information is used and shared. This Privacy Policy (or “Policy”) describes our practices, including your choices, regarding the information we collect.
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”).
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.
If you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us, including having had obtained any necessary consent on his or her part; and, that we may collect, use, and disclose such information for the purposes described in this Privacy Policy. Any collection and processing of information that you have provided about another person will be in accordance with this Policy.
We may collect information about the Services you or your household use and how they are used, such as when you watch a video on a Samba mobile application, visit a third-party website or app that uses our Integrated Services, or interact with our ads and content.
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 certain ads. We may also obtain from our data providers household or unique device identifiers (such as IP Addresses and Advertising IDs) gathered across platforms (including websites, TV applications, or mobile applications) which may be combined with our data and distributed to our clients so they can better tailor their advertising, marketing, measurement, analytics, and research; our data providers who are contractually bound to comply with all applicable data privacy laws before collecting such data and providing it to us.
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.
We may use the information we collect to:
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.
We may share the information we collect about you with third parties in the following circumstances:
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.
We will generally retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy. However, we may retain certain information as required by applicable law (such as tax, accounting or other legal requirements). When we have no basis to continue processing your personal information, we will either delete or anonymize it in accordance with applicable laws (though we may need to retain cached or archived copies for a certain period until deletion is possible).
We may store Content Viewership and Ad Exposure Information for up to three (3) years from the last time our Services encounter a particular device, unless you ask us to delete that information before then. Our cookies are set to expire in less than 13 months. Identifiers associated with your non-Samba TV devices (such as device IDs, mobile ad ids, IP addresses) are kept for no more than 180 days since our last receipt of such identifier.
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.
The countries where we may transfer your personal information might have laws which are different, and potentially not as protective as the laws of your country of residence. When we transfer your personal information abroad, we will take appropriate safeguards to protect the information in accordance with this Privacy Policy and seek to ensure that overseas recipients comply with applicable privacy laws.
When we transfer personal data outside of the EEA or Switzerland, we ensure an adequate level of protection for the rights of data subjects by placing obligations on the recipient of the data pursuant to standard contractual clauses approved by the European Commission.
Samba TV is also a participant in the EU-US Privacy Shield and Swiss-US Privacy Shield programs and is committed to the Principles of Notice, Choice, Accountability for Onward Transfer to Third Parties, Security, Data Integrity and Purpose Limitation, Access and Recourse, Enforcement, and Liability, as indicated by our EU-US Privacy Shield and Swiss-US Privacy Shield certifications. Please note that notwithstanding any language to the contrary in this Privacy Policy, in cases of onward transfer of personal information to third parties pursuant to the EU-US and Swiss-US Privacy Shield, Samba TV is potentially liable.
If you have a Privacy Shield-related complaint, please contact us at privacy@samba.tv. 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 70/E/2017, 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 Section 11 (Contact 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
In general, you have the right to access, update or delete your personal information. This means you have the right to request that we:
You can exercise these rights by:
We will respond to all requests in accordance with applicable laws, which may require that you provide us with additional information to confirm your identity. This confirming information will only be used to process your request.
Below are the choices we provide in connection with the practices described in this Policy.
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 in or out of our Smart TV Services at any time your TV is connected to the Internet. You typically can find a feature to opt-out and opt-in in the “settings” menu of your TV; it may also be in the settings menu of the application that integrates our Services. 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. You should review the opt-out options provided by such applications. If you cannot find the opt-out settings, please contact us at privacy@samba.tv.
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 privacy@samba.tv with your TV manufacturer and model number and we will attempt to provide you with more detailed instructions on where to locate these features.
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.
You may also find helpful information about how to opt-out of Smart TV Services and television streaming devices at Network Advertising Initiative’s web page dedicated to “Internet Connected TV Choices.”
You may learn more about “interest-based” or “tailored” advertising, as well as pertinent self-regulatory frameworks by visiting the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”). The NAI and DAA are industry associations that develop policies around online consumer privacy in the context of “interest-based” or “tailored” advertising.
Samba TV is an active member of the NAI and the DAA. We adhere to the NAI Code and implement the opt out mechanisms provided by the NAI and DAA:
Note, you will need to opt out on each browser on each of your devices.
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 and may result in a new Samba TV cookie being created on your browser or device in the future.
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). Unless restricted by local regulations, we may still send you non-promotional communications about your account following your opt-out.
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.
Samba TV does not intentionally collect information about individuals under the age of 13 and partners with independent companies to validate our compliance with COPPA.
Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification. Samba TV is a member of the PRIVO Kids Privacy Assured COPPA Safe Harbor Certification Program (“the Program”). The Program certification applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO Seal. PRIVO is an independent, third-party organization committed to safeguarding children’s personal information collected online. The PRIVO COPPA certification Seal posted on this page indicates Samba TV has established COPPA compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at privacy@samba.tv. If you have further concerns after you have contacted us, you can contact PRIVO directly at privacy@privo.com.
If you are a California resident, this section applies to you. This section describes how we collect, use, and share personal information in operating our business. For purposes of this section, “personal information” has the meaning given in the California Consumer Privacy Act of 2018 (CCPA), but does not include certain de-identified or aggregated information, information publicly available in government records, or certain information excluded from the CCPA’s scope.
We do not knowingly collect information from individuals under the age of 16 without parental consent.
The list below summarizes, during the 12 months preceding the last update of this Privacy Policy, the categories of personal information we collect, as well as where we collect it from, how we use it, and who we share it with. More information regarding the: sources from which we collect personal information can be found in Section 1; business and commercial purposes for which we collect your personal information can be found in Section 2; categories of recipients with whom personal information is shared or sold can be found in Section 3.
1. Email address, IP address, device ids, cookies, and advertising IDS
2. Demographic information such as household income, age bracket, and homeownership
3. Ad Exposure and Content Viewing information associated with your TV ID or IP Address
In the past 12 months, we have disclosed or sold IP addresses, device IDs, advertising IDs, and content and ad exposure data, as described in this Privacy Policy, to our advertising, media, and content recommendation partners, for the purposes of delivering digital advertisements and measuring content and advertising effectiveness,
Under the CCPA you have the right to request that we (a) disclose to you what personal information we collect, use, disclose, and sell, (b) delete personal information we collected or maintain about you, and (c) do not sell your personal information (CCPA “opt-out”).
You can exercise these rights by submitted a request via our webform or emailing privacy@samba.tv. Additional information on how to exercise these rights may be found in Section 7.
You also have a right not to be discriminated against for exercising any of these rights, and Samba will not do so. However, please note that if you request the deletion or non-sale of your data, Services that rely on such data, such as Recommendations, may no longer function correctly.
The list below provides Samba TV’s metrics for responding to privacy rights requests in 2020.
1. Access Requests
2. Delete Requests
3. Opt-out of Sale
Median days for substantive response: 6
Note: The numbers above reflect all requests received by Samba TV, not just those from California residents. Samba TV extends CCPA and GDPR rights globally, and does not deny requests based on the requester’s residency.
If you live in Europe, this section applies to you.
Our legal bases for collecting personal data are:
You have the right to (a) access your personal data, (b) rectify, restrict, or delete your personal data, (c) object to the processing of your personal data (this is your “opt-out”), (d) revoke your consent to our processing of your personal data, and (e) raise concerns about our use of your personal data to our data protection officer or to the relevant data protection authorities.
You can exercise these rights by submitted a request via our webform or emailing privacy@samba.tv. Additional information on how to exercise these rights may be found in Section 7.
The data controller responsible for your personal information is Samba TV, Inc. in the United States. We may also share your data with trusted business partners for purposes consistent with this privacy policy. The specific businesses with whom we share personal data pursuant to controller-to-controller agreements are:
If you live in Australia, this section applies to you. This Privacy Policy constitutes our notice of privacy practices under the Australian Privacy Act of 1998. In addition, the specific businesses with whom we share personal data may are:
None of the personal information we collect is ‘sensitive information’ under the Australian Privacy Act of 1998, and we will not collect any sensitive information from you in connection with our Services.
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 privacy@samba.tv, or at:
Samba TV, Inc.
(ATTN: Privacy)
118 King Street
Suite 110
San Francisco, CA 94107
USA
You may also contact our Data Protection Officer at:
Vincent Rezzouk-Hammachi
Bird & Bird Privacy Solutions
Avenue Louise 235 Box 1
1050 Brussels, Belgium
dpo.sambatv@twobirds.com
We will respond to all inquiries in accordance with the applicable data privacy laws.
In the European Union, you also have the right to complain to a data protection authority (“DPA”) about our collection and use of your personal data. Please contact your local DPA in the EU or the Swiss Federal Data Protection and Information Commission, as appropriate.
