PIVOTSHARE PRIVACY POLICY

This Privacy Policy applies to all of the products, services and websites offered by Pivotshare or its subsidiaries or affiliated companies. Sometimes, we may post product specific privacy notices or Help Center materials to explain our products in more detail.

Categories of Personal Information Collected

Browsing Pivotshare: You can watch videos on Pivotshare without having a Pivotshare Account. You also can contact us through our website or by emailing us directly without having to register for an account.

Your Pivotshare Account: When you create a Pivotshare Account, some information about your Account and your account activity will be collected by Pivotshare including your email address and a password, which is used to protect your account from unauthorized access. Other account information includes the date you opened your Pivoshare Account, the date you last logged into your Pivotshare Account, the country you are in, and activity information such as uploading videos, posting comments, flagging videos, or watching premium videos.

Your Publisher Account: For activities involving earnings and payment, we may ask for social security information in order to successfully process payments to you and comply with United States tax laws. This information will not be used in any other way.

Any videos that you submit as free to Pivotshare may be redistributed through the internet and other media channels, and may be viewed by other Pivotshare users or the general public.

You may also choose to add personal information which may include your name, gender, profile picture or other details, that will be visible to other users on Pivotshare. If you choose to add certain features to your Pivotshare page, then these features and your activity associated with these features will be displayed to other users and may be aggregated and shared with your friends or other users. Such shared activity may include your favorite videos, videos you rated and videos that you have uploaded.

Usage Information: When you use Pivotshare, we may record information about your usage of the site, such as the communities you subscribe to, which other users you communicate with, the videos you watch, the frequency and size of data transfers, and information you display about yourself as well as information you click on in Pivotshare (including UI elements, settings). If you are logged in, we may associate that information with your Pivotshare Account including which videos are watched, your IP address, as well as your browser and device information. In order to ensure the quality of our service to you, we may place a tag (also called a "web beacon") in HTML-based customer support emails or other communications with you in order to confirm delivery.

Analytics: We use third-party analytics provided by Google Analytics. For information on how Google Analytics collects and processes information about you and information on how to opt out from Google’s collection of information from you, please click here.

Categories of Uses

To communicate with you and to inform you of products, programs and services.

If you submit personal information to Pivotshare, we may use that information to operate, maintain, and improve the features and functionality of Pivotshare, and to process any flagging activity or other communication you send to us.

We may use your email address without further consent for non-marketing or administrative purposes (such as notifying you of major Pivotshare changes or for customer service purposes).

For paid affiliates, we may collect and store your social security (and related) information for payment purposes to comply with United States tax laws.

We use cookies, web beacons, and log file information to: (a) store information so that you will not have to re-enter it during your visit or the next time you visit Pivotshare; (b) provide custom, personalized content and information; (c) monitor the effectiveness of our marketing campaigns; (d) monitor aggregate metrics such as total number of visitors and pages viewed; and (e) track your entries, submissions, and status in promotions, sweepstakes, and contests.

Cookies & Tracking Technology

Cookies: A cookie is a small text file that is stored on a user’s computer for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our website. A persistent cookie remains on your hard drive for an extended period of time.

For example, when you sign in to our website, we will record your user or member ID and the name on your user or member account in the cookie file on your computer. We also may record your password in this cookie file for automatic sign-in. For security purposes, we will encrypt any usernames, passwords, and other user or member account-related data that we store in such cookies. In the case of sites and services that do not use a user or member ID, the cookie will contain a unique identifier. We may allow our authorized service providers to serve cookies from our website to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our site, content and advertising.

You may delete or decline cookies by changing your browser settings. (Click "Help" in the toolbar of most browsers for instructions.) If you do so, some of the features and services of our website may not function properly.

We may allow third-parties, including IAC companies, advertising companies, and ad networks, to display advertisements on our site. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. Our website does not provide any personal information to these third parties, but they may collect information about where you, or others who are using your computer, saw and/or clicked on the advertisements they deliver, and possibly associate this information with your subsequent visits to the advertised websites. They also may combine this information with personal information they collect from you. The collection and use of that information is subject to the third-party’s privacy policy. This information allows them to deliver targeted advertisements and gauge their effectiveness. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies (www.networkadvertising.org).

Web Beacons: Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies which are stored on the user’s computer hard drive, web beacons are embedded invisibly on the web pages (or in email) and are about the size of the period at the end of this sentence.

Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages and to understand usage patterns. We also may receive an anonymous identification number if you come to our site from an online advertisement displayed on a third-party website.

"Do Not Track" Signals: Some browsers and services allow users to initiate "Do Not Track" signals that commonly prevent participating websites or services from collecting and sharing personally identifiable information. Pivotshare does not share personally identifiable information with any third party services or companies beyond its own content suppliers, nor does Pivotshare collect personally identifiable information across third party websites.

Your Rights

If you have a Pivotshare Account, you may update or correct your personal profile information, email preferences and privacy settings at any time by visiting your account profile page. To submit other individual right’s requests that apply in your region, please click here.

You may control the information that is available to other users and your confirmed friends at any time by editing your Pivotshare Account and the features that are included in your community.

You may, of course, decline to submit personal information through Pivotshare, in which case you can still view videos and explore Pivotshare, but Pivotshare may not be able to provide certain services to you.

Parents who believe we’ve unintentionally collected personal data about their underage child should contact us for help deleting that information.

Please note: To protect your privacy, we may ask for additional information to verify your identity in order for us to respond to your request. See here for further details.

Users in the European Union only:

Under EU Regulation 2016/679 of the European Parliament and the Council; the General Data Protection Regulation (“GDPR”), you have a number of rights when it comes to your personal information. Further information and advice about your rights can be obtained from the data protection regulator in your country of residence within the EU. You can exercise any of these rights by contacting us through our email or mailing address in the “Contact Us” section below:

The right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.

The right of access: You have the right to obtain access to your information, and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law.

The right to rectification: You are entitled to have your information corrected if it is inaccurate or incomplete.

The right to erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

The right to restrict processing: You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

The right to data portability: You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. This is not a general right however and there are exceptions.

The right to object to processing: You have the right to object to certain types of processing, including processing for direct marketing (i.e. receiving emails from us notifying you about other services we provide which we think may be of interest to you or being contacted with varying potential opportunities). You may change your preferences regarding email or newsletters as described above.

The right to lodge a complaint: You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.

The right to withdraw consent: If you have given your consent to anything we do with your personal data (i.e we rely on consent as a legal basis for processing your personal information), you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your personal information at any time.

Your California Privacy Rights:

The California Consumer Privacy Act (“CCPA”) affords the Californian consumer specific rights regarding personal information. These rights have been described in the Supplemental Privacy Policy. If you have a specific question or concern about your rights, or questions about our policy in support of your rights as a Californian consumer, please contact us through our email or mailing address in the "Contact Us" section.

We may disclose your information to Crackle Inc. and its affiliates, subject to the terms of the agreements that created our joint venture, Crackle Plus, for as long as Crackle Inc. owns any interest in the joint venture. Crackle Inc. and its affiliates may use your information for any lawful commercial purposes, including marketing and advertising.

Other than sharing your information with Crackle Inc., as described above, we will only knowingly share your information with non-affiliated third parties for their own direct marketing purposes if you specifically opt-in, or are offered the opportunity to opt-out and elect not to opt-out, to such sharing at the time you provide personal information. If you do not opt-in or if you opt-out at that time, we will not knowingly share the information that was collected, but we may continue to seek your consent to sharing with the same or other non-affiliated third parties for their own direct marketing purposes from time to time. Each consent notice and opportunity will be treated separately so it is possible that you may consent to some sharing but not to others.

In addition, California residents may request information about our compliance with the Shine the Light law and the companies with which we may have shared personal information for their direct marketing purposes by emailing us at support@pivotshare.com with the subject line “California Privacy Rights Request”. You must include your name, street address, city, state, and ZIP code and, if applicable, the URLs and usernames of your accounts on our Sites. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided e-mail address.

For more information on the California Consumer Privacy Act please visit https://www.oag.ca.gov/privacy/ccpa

Advertising on Pivotshare

Pivotshare strives to provide you with relevant and useful advertising. We may use a range of information including cookies, web beacons, IP addresses, usage data and other non-personal information about your computer or device (such as browser type and operating system) to provide you with relevant advertising. While you are logged in or logged out of your Pivotshare Account, we may also show you advertising based on non-personally identifiable information you have provided to us in your Pivotshare Account.

We use cookies on Pivotshare to help advertisers and publishers serve and manage ads on this site. Advertisers may serve ads based on interests and demographic categories associated with non-personally identifiable online activity, such as videos viewed or frequency of uploading. Advertisers may also serve ads to you based on previous activity on that advertiser's website or based on non-personally identifiable information from other companies. This non-personally identifiable information is held separately from your Pivotshare Account data, or other personally identifying information in our possession.

Categories of Sharing

Pivotshare only shares personal information with other companies or individuals outside of Pivotshare in the following limited circumstances:

• Upon purchasing a video on Pivotshare, we retain the rights to distribute your email address, first and last name, and your mailing address to any content supplier that you have purchased from.
• Upon creating or logging-in to your Pivotshare account through any of our content suppliers' media websites, or visiting any of these websites, we retain the right to employ software to track your behavior within the confines of the website for use in statistics and reports that may be used to inform and improve our services and/or our content suppliers' services.
• We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
• We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of Pivotshare, its users or the public as required or permitted by law.

Affiliates and Non-Affiliated Third Parties: We may disclose your information to Crackle Inc. and its affiliates, subject to the terms of the agreements that created our joint venture, Crackle Plus, for as long as Crackle Inc. owns any interest in the joint venture. Crackle Inc. and its affiliates may use your information for any lawful commercial purposes, including marketing and advertising. We may also disclose your information to affiliates and non-affiliated companies when we believe their products or services may be of interest to you, so that they can contact you with offers. If you respond to an offer and provide information directly to another company (including Crackle Inc. or its affiliates) that information will be subject to their privacy policy, not this Privacy Policy. If you later decide that you do not want that third party to use your information, you will need to contact the third party directly. Pivotshare is not responsible for the manner in which other businesses collect or use your personal information.

If Pivotshare becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will ensure the confidentiality of any personal information involved in such transactions and provide notice before personal information is transferred and becomes subject to a different privacy policy.

Information security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to personal information to Pivotshare employees, contractors and agents who need to know that information in order to process it on our behalf. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Accessing and updating personal information

When you use Pivotshare services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

Enforcement

Pivotshare regularly reviews its compliance with this Privacy Policy. When we receive formal written complaints, it is Pivotshare’s policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between Pivotshare and an individual.

Changes to this Privacy Policy

Please note that this Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any Privacy Policy changes on this page. We will also keep prior versions of this Privacy Policy in an archive for your review.

Contact Us

If you have any questions about this Privacy Policy, please feel free to contact us through our website or write to us at

support@pivotshare.com

Privacy Matters
c/o Chicken Soup for the Soul Entertainment.
P.O. Box 700
Cos Cob, CT 06807-0700
USA

Pivotshare Supplemental Privacy Policy For California Consumers under CCPA

INTRODUCTION.

This Supplemental Privacy Policy for California Consumers under CCPA (“California Statement”) explains rights that California consumers may have under the California Consumer Privacy Act of 2018 (“CCPA”).

When we use the term “personal information” in this supplemental California Statement, we are using that term as CCPA defines it, which CCPA generally defines “personal information” to mean information that we maintain in a way that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. However, personal information does not include publicly available, deidentified, or aggregate consumer information (which are all defined in CCPA). Notably, the definition of “personal information” also does not apply to the collection of personal information from job applicants, employees – whether you are our employee or any employee of the entity arranging access to our Services for you, business owners, directors, officers, staff, or contractors.

Where we act as a “business” under CCPA (meaning we determine the manner and reasons for why we process your personal information), we may be required to disclose the categories of personal information we collect, the sources where we obtain that information, the purposes for why we collect that information, and who we share that information – all of which depends on the specific Service.

We obtain the categories of personal information from sources as described in the PivotShare Privacy Policy. We use and share personal information as described in the Pivotshare Privacy Policy. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

YOUR PRIVACY RIGHTS

The CCPA provides California residents (consumers) with specific rights regarding their personal information. If you are a resident of California and are not a job applicant, employee, or employee of another company interacting with us in your job role, you have the right to request what information we collect, use, and disclose. This includes the categories of personal information and the specific pieces of personal information. You may also request the sources of personal information collected about you, the purpose for collecting the personal information. You also have the right to request that we delete your information.

The CCPA also gives California residents the right to stop the “sale” of their personal information. Based on the current draft CCPA regulation and amendments, Pivotshare does not "sell" your Personal Information.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. An authorized agent may only act on your behalf if you provide a written and signed permission to do so. You will still need to verify your own identity directly with us. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

You may make a request by emailing us at: privacyqueries@chickensoupforthesoul.com

In order to process your requests, we must first verify your identity. We use the information you provide with your request but may need to request additional information from you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.