Philo Privacy Policy

1. Information We Collect

In connection with the Services, we may collect, store, and use information, some of which may be “Personal Information” as defined by law. We may merge the information we collect from or about you with information from different sources. When we receive information from different sources, we will continue to apply this Privacy Policy to any Personal Information we receive, unless we have disclosed to you otherwise.

These are the types of information we may collect about you:

1. Information Provided by You

For example, you may provide information to us directly, some of which may be Personal Information, in these circumstances:

• Customer Service and Support Inquiries and Other Contacts with Philo
• Product Feedback, Surveys, Reviews, Comments, and/or Input
• Email Message or Inquiry Forms
• Inquiries via Social Media
• In connection with the Philo Subscription Service
• In connection with the Philo Edu Service

The details:

• Customer Service and Support Inquiries and Other Contacts with Philo. We need your name, and email address to communicate with and respond to you. We may also ask for your phone number and that you confirm information about your Philo account (“Account") in our system. We will collect any other information you provide in your email or phone call to us, such as, device information, operating system, other information relevant to your issue, so we can assist you or contact you about resolving the issue. We may also make audio recordings of your phone calls to us, consistent with the law. In connection with inquiries regarding the Philo Edu Service, we will collect platform, physical location, school, and credentials, that may include your student identification number.
• Product Feedback, Surveys, Reviews, Comments, and/or Input.As part of your feedback, you may be asked to provide your first and last name, street address, email address, phone number or other Personal Information, and we may gather location and other information from your order history. We also collect the information you provide to us in your product feedback, surveys, reviews, comments, and/or input.
• Email Message or Inquiry Forms. If you email an inquiry to us or fill out a form to receive additional information, we will use the contact information you provide to respond to your inquiry, and we will collect the information you provide, including the contents of the messages or attachments you send us.
• Inquiries via Social Media. If you contact us via social media, including without limitation, Facebook and Twitter, we will have access to your social media handle and other information you post, and we may use that information to respond to your inquiry.
• In Connection with the Philo Subscription Service. If you are a user of the Philo Subscription Service, we collect certain information specific to that Service:
• Registration. If you sign up for a trial period, we collect the information you provide us, such as your mobile phone number or email address to begin the trial period and create your Account.
• Purchases. If you continue your trial period or purchase a subscription to the Philo Subscription Service (“Subscription”), your first and last name, mobile phone number, email address, and billing Zip code are necessary to continue your trial period and to purchase a Subscription, and our payment card processor will also need to collect payment card information from you. We do not have access to your full payment card information. We only have access to a truncated version of your payment card number, card expiration date, card security code, and billing zip code.
• Accessing the Philo Subscription Service.  If you are a Philo Subscription Service subscriber and you want to use the Service, your mobile phone number or email address is necessary for us to authenticate your Subscription.
• Communications, Newsletters and Promotions. You will need to register on the Philo Subscription Service if you want to access newsletters or information on special promotions.
• Registering for a Contest, Sweepstakes or Other Promotion. For example, you may provide your first and last name, phone number, and home address, and we may be legally obligated to disclose this information if you win. We also collect any other information you provide with your submission.
• In Connection with the Philo Edu Service. If you are a user of the Philo Edu Service, we collect certain information specific to that Service:
  • Verification: If you become a registered user of the Philo Edu Service, we may require you to provide certain information to us, such as a unique token, all or part of your legal name, your email address, your physical location, your residential address, device information and/or identification of your school.
  • Accessing the Philo Edu Service. If you are a registered user of the Philo Edu Service and you want to use the Service, you must input additional verification information which may include a username, password and certain additional information required by applicable law or regulation.
2. Information We Collect Indirectly from You, Including When You Use the Services

We may also collect certain information indirectly from you, including when you use the Services, and some of this information, whether alone or combined with other data, may be your Personal Information. Examples of information collected indirectly from you include: 

• Viewed Content
• Location Information
• Usage and Interaction Information
• Device Information
• Information Collected via Cookies and Similar Technologies

The details:

• Viewed Content. If you stop watching a program on a particular device, the Services give you the option to pick up the program where you left off when you launch the Services on a different device.  To do this, we must keep track of the content you have watched, including series titles and episode names, when you watched the content, and the point at which you stopped watching the content. We make recordings of that content, and connect that information to your Account, along with identifying all devices you use with your Account. The Services also let you pause, rewind or fast-forward content. To do this, we must make recordings of the content you are watching and connect that information with your Account. The general categories of content you view may also be used to provide you with more relevant advertising. We may also collect information about ads you have viewed on the Philo Subscription Service.
• Location Information. We use various technologies to detect your general location, such as city or zip code. To learn more about your choices regarding our collection and use of location data, please see Section 4 of this Privacy Policy.
• Usage and Interaction Information. We collect information about your use of and interaction with the Services, including your activities on the Services, the pages and content you view, click, or scroll over, the dates and times of your use, landing pages, the average time spent using the Services, click stream information, information about your interaction with customer support services including any phone number you use to call us, and information about your interaction with our emails and texts. For the Philo Subscription Service, we also collect information about your interaction with ads, including the ads you view, click or scroll over, click stream information, and time and date of interaction.
• Device Information. We collect information about the devices you use with the Services, including device model, IP address, MAC address, type and version of browser, browser identifier, type and version of operating system, type of platform, identity of carrier, radio type (such as 4G), preferences and settings (such as preferred language), application installations, referring and exit pages and URLs, domain names, device identifiers, push notification tokens, and, for the Philo Subscription Service, advertising identifiers.
• Information Collected via Cookies and Similar Technologies. We use cookies and other technologies to collect usage data and store preferences. Information we collect via the data collection technologies described in this Section may be linked to other information about you and may be Personal Information. The Services may use cookies and similar technologies to collect information automatically as you interact with and otherwise use the Services, and to collect such information over time and across different websites. We use cookies and similar technologies to, for example, collect “clickstream” data and other information, such as your browser type and version, operating system, and platform, referring and exit pages, domain names, landing pages, the average time spent using the Services, shows viewed, content searched for, access and viewing times, and other relevant statistics and information, and assign unique identifiers to the device you use to access the Services for the same purposes. We may associate the information obtained through cookies and similar technologies with your Personal Information so we can better customize your experience using the Services and/or the ads and promotions you see. By accessing and/or using the Services, whether as a guest or a registered user, you acknowledge, understand, and agree that you are giving us your consent to store your activities and your use of the Services as described in this Privacy Policy. These data collection technologies include:
1. Cookies. “Cookies” are small pieces of information downloaded to your device when you visit a website or other service and are stored by your browser. Cookies are then sent back to the originating service on each subsequent visit to that Service or to another website or service that recognizes those cookies. Cookies are useful because they allow a website to recognize a user’s device. Our cookies enable us to facilitate access to different aspects of our Services. For example, by showing when and how you and others visit our Services, cookies help us to see which pages of the Services are popular and which are not. Cookies can also help us improve your enjoyment of the Services, for example, by remembering your session ID and other Personal Information used to identify you as an authorized subscriber to the Services. We may create a unique device or user ID for you and store it in a cookie so we can customize your experience based on your preferences. We may use cookies to personalize ads for the Philo Subscription Service and on other web properties. We may use session cookies during the time of your visit on the Services that may be deleted when you exit, depending on your browser, and we may also use more permanent cookies so we can recognize you if you return to the Services. You can find more information about cookies at www.allaboutcookies.org.
2. Web Beacons and Pixel Tags. We may also use web beacons and pixel tags (also known as web bugs and clear GIFs). Web beacons (also called single pixel gifs, clear GIFs, or web bugs) are Internet tools, such as transparent images on the Services or in emails we may send you, that help us to determine, for instance, whether a page on the Services or ad on the Philo Subscription Service has been viewed or an email opened. For example, when you ask us to send you information, we may use web beacons to determine how many emails we sent were actually opened. A pixel tag is a type of web beacon embedded in an image on the Services. In general, any electronic image viewed as part of a web page, including a banner ad on the Philo Subscription Service, may contain a pixel tag. We may use web beacons and pixel tags to help us optimize and tailor the Services. In connection with the Philo Subscription Service, we may also use web beacons and pixel tags to help us track conversions and optimize and tailor advertising for you and other future visitors to the website. Web beacons allow third parties to obtain information, such as the IP address of the computer that downloaded the page on which the web beacon appears, the URL of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the browser used to view the page, and the information in cookies sent by the third party.
3. Local Storage and Local Shared Objects. We may use local shared objects (LSOs) such as Flash Cookies and local storage, such as HTML5 Local Storage, to enhance user experience. Local storage is similar to browser cookies but can store data more complex than simple text. By itself, local storage does nothing to or with the data stored on your device. Third parties with whom we partner to provide certain features on the Services or, in connection with the Philo Subscription Service, to display advertising based upon your web browsing activity may also use Flash cookies or HTML5 to collect and store information.

To learn more about your choices regarding cookies and other similar technologies, please see the "Cookies, HTML5 and Flash Cookies” and "Opt-Out Options for Third-Party Online Behavioral or Interest-Based Advertising” subsections of subsections of Section 4 of this Privacy Policy.

3. Information We Receive from Third Parties

We may receive information about you (including Personal Information) from third parties. This information may include:

• Information Specific to the Philo Subscription Service
• Information Specific to the Philo Edu Service

The details:

• Information Specific to the Philo Subscription Service. If you are a user of the Philo Subscription Service, we receive certain information specific to that Service:
  • When you access or interact with the Philo Subscription Service through another company, (for example, distribution partners, including device partners) or you pay for the Philo Subscription Service or otherwise receive access to the Philo Subscription Service as part of your relationship with another company (for example, through other companies that offer access to media content), we may collect your email address, mobile phone number, and other identifiers that support authentication, activation, personalization of the Philo Subscription Service, and payment processing and other billing-related matters.
  • If you are on another website and you opt-in to receive information from us, that website will forward to us your email address and other information about you so we may contact you as requested.
  • You may participate in a third party application or feature (such as one of our pages on Facebook or Twitter or another social platform or website) through which you allow us to collect (or the third party to share) information about you, including Personal Information.
  • When you access, log into or connect with the Philo Subscription Service through social media networks and other third-party platforms, we may collect information including, identifiers, your user ID and user name connected with that service, gender, physical location and that of your devices, your date of birth, certain profile information, your profile page URL, your email address, mobile phone number, any other information you have made available to that service, and any information you have authorized the service to share with us (which may include your user ID, billing information, public profile information, email address, mobile phone number, birthday, pages you have “liked” and other Account and profile data), and you are authorizing us to collect, store, and use such information and content under this Privacy Policy. Your use of any such third party service is at your own discretion and is not required to use the core features of the Philo Subscription Service (for example, to watch television content you are entitled to watch).
  • We may also collect information about you or your use of the Philo Subscription Service from vendors and other third parties, including service companies (for example, data licensors, research and analytics companies, and payment processors), public databases, our marketing partners, and advertisers. This may include contact information and information (whether identifiable, de-identified or anonymous, and whether collected online or offline) about your interests, demographic data, purchasing behavior, and your activities online (such as websites visited and ads viewed), and this information may be matched to the data you provide and the data we collect from you.
• Information Specific to the Philo Edu Service. If you are a user of the Philo Edu Service, we receive certain information specific to that Service:
  • To enable the Philo Edu Service, we may receive information from your school, such as a unique token, all or part of your name, your email address, your IP address, or other information about you.
2. How We Use Information

We describe how we use information:

1. General Uses of Information
2. Use of Information for the Philo Subscription Service
3. Use of Precise Location Information
4. Use of Information That is Aggregated or De-Identified

The details:

1. General Uses of Information. We collect and use Personal Information, which includes location information, for purposes that include:
   • providing you the Services, including support services and other services you request;
   • communicating with you, including for marketing, promotions, updates and notices;
   • authenticating your Account, including, for the Philo Edu Service, establishing your identity with your school, and verifying your eligibility to use the Services and receive various content available on the Services;
   • tailoring your experience on the Services and/or otherwise customizing what you see when you use the Services, including customizing recommendations;
   • sending you the information and materials you request or otherwise contacting you as you request;
   • understanding, analyzing, and measuring how you use the Services;
   • diagnosing and debugging problems;
   • tracking your return visits to, and use of, the Services;
   • formatting content for your device type and browser;
   • compiling aggregate data for internal and external purposes;
   • preventing, detecting, and prosecuting security incidents and potentially fraudulent, illegal, or harmful activities;
   • enforcing our Terms of Service and other policies;
   • protecting your rights, our rights or third party rights and complying with legal obligations or legal processes;
   • saving certain information for use on your return visits to the Services;
   • auditing;
   • maintaining or servicing your Account;
   • verifying customer information;
   • undertaking internal research for technological development and demonstration;
   • undertaking activities to verify or maintain the quality or security of the Services;
   • drawing inferences from the information;
   • other uses under our Terms of Service; and
   • any other purpose disclosed to you when we collect the information or that is related to a request made by you.
2. Use of Information for the Philo Subscription Service. For the Philo Subscription Service, we also use Personal Information for purposes that include:
   • identifying content you share;
   • processing and collecting payments;
   • administering surveys, loyalty programs, giveaways, contests, sweepstakes, and other promotions and events;
   • managing, improving, upgrading, enhancing, and optimizing the Philo Subscription Service’s operations and displaying advertising, marketing, and promotional information and content;
   • providing customized content and measuring the performance of the content;
   • facilitating and delivering contextual and targeted advertising and researching and measuring the effectiveness of ads;
   • marketing and advertising the Philo Subscription Service on other services and platforms and tracking the effectiveness of the campaigns; and
   • conducting market research and inviting you to join focus groups and participate in surveys and studies.
3. Use of Precise Location Information. Besides the other uses described in this Section 2, we may use your location to provide offers, notices, and for the Philo Subscription Service, ads relevant to your geographic location and conduct analytics to improve the Services. We may also use location information to confirm that you are in the geographic area where we are permitted to provide the Services. Location information may be combined with other data. To learn more about your choices regarding our collection and use of precise location data, please see Section 4 of this Privacy Policy.
4. Use of Information That is Aggregated or De-Identified. We may aggregate information about you with information about others or we may otherwise “de-identify” information about you so the information does not reasonably identify you. We may use aggregated or de-identified information for any business purpose.
3. How We Share Personal Information

Your Personal Information, including location information collected in connection with the Services, may be shared with these third parties:

1. Service Companies
2. Analytics Partners
3. Other Business Partners
4. Third Parties When Required or Permitted by Law or To Protect Legal Rights
5. Third Parties in Connection with Certain Business Transactions
6. Affiliated Media Content Providers
7. Third Parties with Your Consent
8. Information That is Aggregated or De-Identified
9. Social Media and Other Third Party Platforms in Connection with Philo Subscription Service
10. Ad Partners in Connection with Philo Subscription Service
11. Audience Measurement Providers in Connection with Philo Subscription Service
12. Third Parties for Joint Promotions, Sweepstakes or Contests in Connection with Philo Subscription Service
13. Schools in Connection with Authorization for Philo Edu Service

The details:

1. Service Companies. Certain companies (collectively, “Service Companies”) provide services to us, our business partners or, in the case of the Philo Subscription Service, our advertisers. Service Companies may use data for the same purposes we do under this Privacy Policy. For example, they may assist us with our business operations; the provision of the Services, including all associated features, functions, transactions and operations; marketing; analytics; data processing or data management; security; fraud prevention; legal services; auditing; Account management; hosting; customer or technical support; delivering you the features and functionality you have requested; other services; and in connection with the Philo Subscription Service, advertising; billing and processing payments; Account management; hosting; and measurement. These Service Companies include, without limitation, companies that send text messages or emails to you, support customer service, and for the Philo Subscription Service, companies that process payment card information, support our advertising programs, provide data storage, assist with audience research, and assist with product development. Service Companies may receive the information described in Section 1 of this Privacy Policy. Depending on the services they provide, Service Companies will receive different information from us. For example, Service Companies that assist us with emails and texts may receive your email address or mobile phone number and the content of the message we are sending, which may include a reminder you have requested for a particular television program; companies that assist us with customer service or support may receive information necessary to access your Account, information needed to resolve the issue, and any other information you provide; and for the Philo Subscription Service, payment processors may receive order information, payment information, IP addresses and other device identifiers to process payments; marketing and advertising Service Companies may receive location information, email addresses, phone numbers, other contact information, IP addresses, advertising identifiers, and your reactions, such as clicking on an ad or making a purchase; and measurement Service Companies may receive IP addresses, advertising identifiers, and other device identifiers. Service Companies may use the Personal Information we provide to them consistent with our agreements with them, and those terms may, for example, authorize them to use Personal Information to carry out the service they are providing for us, to analyze, manage, maintain, or improve their services, to combat fraud, financial loss, and abuse, as required by law, to share Personal Information with their service companies, and , where permitted by law, to improve ad targeting.
2. Analytics Partners. We contract with third parties, including without limitation, Google Analytics, that use data collection technologies to track, analyze and report data about the use of the Services and to analyze and optimize marketing of the Services (“Analytics Partners”). The data collection technologies our Analytics Partners use may include various technologies to detect more precise geographic location information and sensor data via cellular network information, and other location-based features. To learn more about your choices regarding Google Analytics’ use of data, please see Section 4 of this Privacy Policy, and to learn more about your choices regarding the collection and use of precise location data, please see Section 4 of this Privacy Policy.
3. Other Business Partners. In providing the Services, we work with partners who help us offer the Services. For example, these partners include companies that provide content to us, distribute our Services, and provide you devices on which our Services are displayed, and their corporate owners. In connection with the Philo Subscription Service, we may share information collected from or about you with these partners, including email address, mobile phone number, viewing information, information about the ads you view on the Services and Account or device information (e.g., device type, IP address, ZIP code, advertising identifiers). This information may be shared for different purposes depending on the partner, including, without limitation, for reporting and analytics, activating, administering, and improving and personalizing your experience with the Philo Subscription Service or the partner, including by providing you with more tailored content, features, and ads on the Philo Subscription Service and on other platforms and services.
4. Third Parties When Required or Permitted by Law or To Protect Legal Rights. We or our Service Companies may disclose your Personal Information without your permission (i) where we believe rights, property or an individual’s safety or security is at risk; (ii) if we believe that you are violating our Terms of Service for Philo Subscription Service, Terms of Service for Philo Edu Service, or this Privacy Policy or any of our other legal rights; (iii) to protect against fraud or for risk management purposes; or (iv) where required or permitted by applicable law (which may include a lawful access request by US or foreign courts, governments or law enforcement agencies).
5. Third Parties in Connection with Certain Business Transactions. If Philo sells all or part of its business or is otherwise involved in a reorganization, dissolution, merger, transfer of all or a material part of its business or other similar event, Personal Information and non-personal information will likely be disclosed or transferred as part of the transaction and as part of pre-transaction due diligence. If, in connection with a business transaction your Personal Information will be processed in a materially different way, material changes will be posted on the Philo website or the Services. If you have an Account and provided your email address, we may also provide you with email notification of such material changes.
6. Affiliated Media Content Providers. If you use the Services to sign on to applications offered by affiliated media content providers (for example, “TV Everywhere” applications), we may share your information with them to certify to them that you may use those applications. We may also provide relevant information to them under this Privacy Policy. Your use of such applications is optional and may be subject to separate terms of use and privacy policy(ies) provided by the media content provider.
7. Third Parties with Your Consent. When you consent or share information, we may share information from or about you with any party. For example, in connection with the Philo Subscription Service, there may be functions within that Service that give you the option to share information about your activities on that Service and you may have the option to share information with our advertisers or other partners through an interactive ad. Information you share through third party platforms and with social networks, advertisers, and other third parties is subject to their terms of use and privacy policies which we recommend you review.
8. Information That is Aggregated or De-Identified. Third parties may use aggregated information or de-identified information about you for any business purpose.
9. Social Media and Other Third Party Platforms in Connection with Philo Subscription Service. By accessing, logging into, or connecting with the Philo Subscription Service using Account information from a social media network or other third-party platform, you agree that we may transmit your user information to the provider of the social media network or other third-party platform.
10. Ad Partners in Connection with Philo Subscription Service.We work with a variety of third party advertisers, ad networks, advertising servers, data exchanges, traffic measurement providers, marketing analytics providers and other providers who provide services related to advertising (“Ad Partners”) to deliver ads to you on the Philo Subscription Service, to provide services related to advertising, and to provide services to help us market and advertise the Philo Subscription Service on other services. You may submit data requested by interactive ads placed on the Philo Subscription Service or on third-party platforms. We may share this information with our Ad Partners. The Ad Partners may use various technologies to identify your general location, such as city or zip code. To learn more about your choices regarding the collection and use of precise location data, please see Section 4 of this Privacy Policy. We and our Ad Partners and their service companies may collect information about your movement within and usage of applications using one or more advertising identifiers, which is a randomly generated alphanumeric code associated with your device, to support or deliver personalized advertising. These user-resettable identifiers have different names depending on the operating system – Google Advertising ID (GAID) on Android devices and Identifiers for Advertisers (IDFA) on iOS on Apple devices. Ad Partners and their service companies may also use cookies and similar technologies to collect information from or about you through the Philo Subscription Service. These collection technologies on the Philo Subscription Service, in your browser and within our applications may be used to (among other purposes) collect data about you when you visit the Philo Subscription Service (such as content viewed or ads viewed or clicked on), where you go, what you do (such as making a purchase), how you use the Philo Subscription Service, and where you go after you leave that Service, and your other activities online and may include the information described in Section 1 of this Privacy Policy (“Information We Collect”), including without limitation, your email address and phone number. The Ad Partners may use the information on the Philo Subscription Services and on other websites and applications you visit for purposes that include, without limitation, to measure and improve advertising effectiveness, track conversions, improve advertising strategy and planning, link your devices, enable other enhancements, provide reporting, prevent fraud, conduct benchmarking, facilitate safety and security, conduct research and development, enable the Ad Partners to deliver more relevant targeted ads on and within the Philo Subscription Service and other websites or applications you visit, comply with law, and provide the information to other Ad Partners. We may provide log files to Ad Partners for the purposes described in this Section 3(J). The log files cover activity on the Philo Subscription Service over a period of time by all viewers of the ad and may include, without limitation, information related to the ad, times of interaction, information about your device, identifiers for you and your device, and cookie information that can be linked to your activity on other services and on other devices. We may also compile and provide reports, including in encrypted, aggregated, or de-identified forms, to Ad Partners about the effectiveness of their campaigns. Besides the other uses described in this Section 3, our Ad Partners may use your location to provide ads, offers and notices relevant to your geographic location. To learn more about your choices regarding Ad Partners’ use of data, please see Section 4 of this Privacy Policy.
11. Audience Measurement Providers in Connection with Philo Subscription Service. The Philo Subscription Service on some platforms contains Nielsen’s proprietary measurement software which will allow you to contribute to market research, like Nielsen’s TV ratings. Nielsen uses information about you to calculate measurement statistics, and this information may include information about your use of the Philo Subscription Service and specific content you have viewed. To learn more about your choices regarding Nielsen’s use of data, please see Section 4 of this Privacy Policy.
12. Third Parties for Joint Promotions, Sweepstakes or Contests in Connection with Philo Subscription Service. If we offer a joint promotion, sweepstakes, contest, or other opportunity with one or more partners, we may provide your Personal Information to the partners.  Any use or sharing of your Personal Information by a partner will be subject to the partner’s privacy policy.
13. Schools in Connection with Support for Philo Edu Service.If you are a Philo Edu Service user and you contact us regarding authorization issues, we may need to provide your school with your on-campus address and student identification number email so your school can verify your housing status and get your Account access restored.

Digital Fingerprinting and Cross-Device Linking. Besides the data collection and sharing described in this Privacy Policy, the third parties in this Section 3 may use certain technological measures and third party databases and services to engage in digital fingerprinting and cross-device linking. These technologies may passively collect information about your device to develop a digital identifier for your device, which is then stored on your device to identify the device in various online transactions. This information is combined with other information regarding your use of the Services and third party databases and may be combined with information from your Account, including Personal Information such as email addresses and phone numbers. The data collected by third parties may be maintained to create a history and reputation of a particular device, and may be used to connect to information on other devices you have used, to help reduce online fraud and recognize your devices in connection with the Services, analytics and, for the Philo Subscription Service, personalized advertising on and within the Philo Subscription Service and other websites or applications you visit. To learn more about your choices, please see Section 4 of this Privacy Policy.

4. Your Consumer Choices, Including Opt-Out Options and Interest Based Advertising Options

You have choices about how we and third parties collect and use certain information about you in these areas:

1. Promotional Communications
2. Text Messages
3. Cookies, HTML5 and Flash Cookies
4. Google Analytics
5. Nielsen Measurement
6. Opt-Out Options for Third-Party Online Behavioral or Interest-Based Advertising
7. Precise Location Collection
8. Additional Rights and Choices for California Residents

The details:

1. Promotional Communications. If you opt-out of marketing email communications, such as newsletters, special offers, promotions, and special event invitations, you may do so at any time and without penalty by clicking on the link provided in the email to unsubscribe, contacting us at philo.com/contact, emailing us at help@philo.com or calling us at 855-CSPHILO (855-277-4456). “Opt-out” and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply. During that time your Information will remain subject to your prior privacy settings. Additionally, information provided to third parties with your consent before you elect to opt out or unsubscribe typically cannot be retrieved or revoked by us, unless required by applicable law, and you cannot retroactively opt out or unsubscribe regarding those third parties. Unsubscribing to marketing communications from Philo will remove you from the Philo marketing email list. You cannot unsubscribe from emails about your Account, your Subscription, the Services, or other requests, because we will still need to communicate with you about those items.
2. Text Messages. If you want to stop receiving text messages from Philo, text “STOP” to “PHILO” (74456 on your keypad). If you stop text messages, you will not be able to log into the Philo Subscription Service using your phone number. To restart text messages from Philo, text “START” to “PHILO.” Message and data rates may apply. (Please contact your carrier if you have any questions about your text plan or data plan.) Message frequency varies. Neither Philo nor any mobile carrier is responsible for any undue delays, failure of delivery, or other error in the transmission of any message. For complete SMS program terms, please see https://about.philo.com/terms/#sms-terms.
3. Cookies, HTML5 and Flash Cookies. Each of your browsers, such as Internet Explorer, Chrome, Firefox, and Safari, may allow you to manage your cookies and local storage for that browser. Because each browser is a little different, we encourage you to check your browsers’ “Help” feature to learn how to block cookies, how to receive notification of new cookies, and how to disable existing cookies. If you block or disable cookies, you may not be able to take full advantage of all the Services and some parts of the Services may not function properly. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please click here. “Do Not Track” signals or other mechanisms that provide a method to opt out of the collection of information over time and across third-party websites are currently under development. Because they are not yet finalized, we follow the standards in this Privacy Policy, and we do not monitor or follow any Do Not Track or similar browser requests. However, some of our features may monitor or follow Do Not Track or similar browser requests. For more information about do not track, visit www.allaboutdnt.org.
4. Google Analytics. To learn more information about Google Analytics and your options, please visit support.google.com/analytics/answer/6004245 and www.google.com/policies/privacy/partners/.
5. Nielsen Measurement. You can access more information about the Nielsen measurement software and learn about your choices regarding Nielsen’s measurement:
   • On iOS and Android devices, in your Settings for the Philo application, click on “About Nielsen Measurement”.
   • On the Philo website, visit About Nielsen TV Rating Measurement, or in your Account settings, go to “Nielsen TV Rating Measurement” and click on the link.
6. Opt-Out Options for Third-Party Online Behavioral or Interest-Based Advertising.
   • We follow the self-regulatory principles of the Digital Advertising Alliance (“DAA"). For more information about the Ad Partners’ technologies and how they use the information collected by the technologies on the Philo Subscription Service and your options not to accept cookies placed by some Ad Partners on the Philo Subscription Service, visit the Network Advertising Initiative (“NAI”) at www.networkadvertising.org or the Digital Advertising Alliance (“DAA”) at www.youradchoices.com to change your consumer preferences regarding certain online ads and to obtain further information about third party ad networks.
   • You can opt out of personalized advertising on Android and iOS through your device settings. These opt outs will disable personalized ads from all providers on all of your mobile applications on these platforms, and not just on our mobile applications.
   • Android Users (version 2.3 and above): “Opt out of Ads Personalization” by following the instructions provided by Google here: Google Play Help.
   • iOS Users (version 6 and above): “Limit Ad Tracking” by following the instructions provided by Apple here: Apple Support Center.
   • The DAA offers AppChoices, a separate choice tool for users to exercise control over the collection and use of data through mobile applications for personalized advertising and other related uses. To exercise choice for participating companies, you can install the DAA’s AppChoices application on your mobile device. Visit here for more information on DAA’s AppChoices tool.
   • These opt-outs are device- or browser-specific and may not work on all devices. If you choose to opt-out through the mechanisms in this Section, you still may see ads but the ads from NAI participants will not be based on your interests.
7. Precise Location Collection. You can turn off precise location collection (or, on some operating systems, continuous precise location collection) through your device settings or by deleting our application from your device. For example, by disabling “Location Services” for the Philo application in your iOS device’s settings, iOS will no longer share your precise physical location with Philo.
8. Additional Rights and Choices for California Residents.If you are a California resident, you may have additional rights and options. Please see Section 12 of this Privacy Policy for more information.
5. Third Party Tracking

Third parties, other than our Service Companies and Partners, do not have authorization from us to track which websites you visited before and after visiting our Services. However, we cannot control third party tracking and there may be some third party tracking that occurs without our knowledge or consent.

6. Changes in Personal Information

If you wish to update, correct, or otherwise have access to your Personal Information in our records, please:

1. Contact us at philo.com/contact;
2. Email us at help@philo.com;
3. Call us at 855-CSPHILO (855-277-4456);
4. If you have an Account, please log into your Account.

The details:

We will not modify or remove Personal Information from the database of any third party to whom we disclosed your Personal Information prior to processing your request. Any Personal Information we have copied may remain in back-up storage for some period of time after your request.

We may request certain Personal Information from you to verify your identity when you are seeking access to your Personal Information records.  

7. For the Philo Subscription Service - Cancelling Your Subscription, Deleting Your Account, and Removing Your Credit/Debit Card Information

You may cancel your Philo Subscription Service by going to philo.com/account and following the instructions. After you cancel your service, we retain certain parts of your information, including your name, email address, and phone number. Our payment processor retains your payment card number to facilitate restarting your Philo Subscription Service unless you click the “remove payment info” button on your Account page. If you want to delete your Account, you may contact us at philo.com/contact, email us at help@philo.com or call us at 855-CSPHILO (855-277-4456), but without an Account, you cannot use the Philo Subscription Service. After you delete your Account, we may retain information from or about you under applicable law, including for various legal, operational, accounting, and auditing purposes, your information may remain in back-up storage for some period of time, and we cannot delete any Personal Information you consented to be provided to certain third parties.

8. Links from the Services

The Services may contain links to third party websites or services not controlled by us. Sometimes, you may navigate to pages of other websites framed with elements of the Services such as in the header or footer. There, the URL will identify the site you are visiting. These links are provided to you as a convenience, and you agree to use these links at your own risk. These other sites and services are not bound by our Privacy Policy, and we are not responsible for the privacy practices or content of those third-party websites or services. If you disclose your information to others in connection with your use of our Services, you are subject to their privacy policies, which may differ from ours, for example, regarding the level of security, use of cookies, and collection, use and disclosure of Personal Information. If you would like information on any other party’s privacy policy, contact that party directly, and we encourage you to do so.

9. Security

We have implemented physical, electronic, and managerial procedures intended to protect your data. Despite these efforts, we cannot guarantee the security of your information. We cannot guarantee protection of all electronic information from interception, misappropriation, misuse, or alteration. We cannot guarantee that your information will not be disclosed or accessed by accidental circumstances or the unauthorized acts of third parties. Any transmission of information is at your own risk. Note that if you allow others to use your Account (including others you permit to set up profiles under your Account), they may view information about your Account or the profiles under your Account, including information about the videos you view and your email address and phone number, and may be able to change your login credentials.

10. Children

Our Services are not intended for children without the involvement and approval of the child’s parent or guardian, and we will not knowingly collect Personal Information from children under the age of 13.

We encourage parents and guardians to talk to their children about their use of the Internet and the information they disclose online. If we learn that we have collected the Personal Information of a child under 13 without verifiable consent, then we will take steps to remove such Personal Information.   If you learn we have collected Personal Information from a child without parental consent, please contact us atphilo.com/contact, email us at help@philo.com or call us at 855-CSPHILO (855-277-4456) promptly.

11. Notice to Non-United States Users

Philo is a Delaware corporation, and we provide the Services only to residents located in the United States. Philo’s Services are not available outside the United States. If you are located outside of the United States and visit our website, the Personal Information you provide will be transferred to and maintained inside and outside the United States, and these jurisdictions’ data protection and privacy laws may not be of the same level of protection as those of the country where you reside or are a citizen. If you do not consent to this transfer, do not visit or use the Services. By visiting or using our Services and providing us with your information, you are consenting to the collection, transfer, storage, and processing of such information in the United States and other countries.

12. Your California Privacy Rights

If you are a resident of California, the following rights may be available to you, and to the extent the terms in this Section 12 conflict with other terms in this Privacy Policy, this Section 12 shall control.

1. 12.1 "Shine the Light” Law. If you are a resident of the State of California, under California’s "Shine the Light" law, Civil Code Section 1798.83, we provide you with information on how to exercise your disclosure choice options such as your right to opt-out (which we may sometimes call “unsubscribe”) or opt-in for use of your Personal Information by third parties (such as advertisers and promotional partners) for marketing in this Privacy Policy. So, under the California Civil Code, we do not have to maintain or disclose a list of the third parties that received your Personal Information for marketing during the preceding year. If you are a California resident and wish to request information about how to exercise your third party disclosure choices or other rights afforded under the law of the State of California, please contact us at philo.com/contact, email us at help@philo.com, call us at 855-CSPHILO (855-277-4456), or send a request by postal mail to the address in Section 15 of this Privacy Policy. All requests must be labeled “Your California Privacy Rights” on the email subject line or envelope or post card. For all requests, please clearly state that the request is related to “Your California Privacy Rights”, include your name, street address, city, state, zip code and e-mail address (your street address is optional if you want to receive a response to your request via email) and indicate your preference on how our response to your request should be sent (email or postal mail). We are not responsible for notices not labeled or sent properly, or do not have complete information.
2. 12.2 California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with certain additional rights described below. This CCPA notice supplements the information in this Privacy Policy. All capitalized terms in this Section 12.2 that are not otherwise defined in this Privacy Policy shall be defined as set forth in the CCPA. For information about Philo’s collection and use of Personal Information about a California resident who is a job applicant to, employee of, owner of, director of, officer of, or contractor of Philo, please see:Philo’s CCPA Notice at Collection – Employees, Applicants, Owners, Directors, Officers and Contractors.

   12.2.1 Disclosures About Your Personal Information

   1. 12.2.1.1 In the past twelve months, depending on the circumstances, we have Collected these categories of Personal Information:
      • Identifiers, such as your name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, Account name and other similar identifiers. For the Philo Edu Service, we may need your school identification number to handle support issues with your school.
      • Categories of Personal Information listed in the California Customer Records law, such as the identifiers above, your telephone number, and, by our payment processor, your credit card number or debit card number.
      • Characteristics about you, such as age and gender.
      • Commercial information, such as the Services you have obtained and your history of using those Services.
      • Internet or other electronic network activity information, such as your browsing history, search history, viewing activity, and other information regarding your interaction with the Services and, in connection with the Philo Subscription Service, ads.
      • Geolocation data.
      • Audio information, such as recordings of your support and service calls to us, and electronic information, such as device information as described in Section 1(B).
      • Inferences drawn from the information we collect about you so we can better understand your preferences, characteristics, and behavior, including to customize content, our Services, and in connection with the Philo Subscription Service, ads for you.
      • Inferences drawn from the information we collect about you so we can better understand your preferences, characteristics, and behavior, including to customize content, our Services, and in connection with the Philo Subscription Service, ads for you.
   2. 12.2.1.2 In the past twelve months, depending on the circumstances, we have Collected Personal Information from these categories of sources, as further described in Section 1 of this Privacy Policy:
      • Information provided by you
      • Information we collect when you use the Services
      • Information we receive from third parties
   3. 12.2.1.3 In the past twelve months, we have Collected or “Sold” as that term is defined in the CCPA, Personal Information for the Business Purposes and Commercial Purposes identified in Section 2 and Section 3 of this Privacy Policy.
   4. 12.2.1.4 In the past twelve months, depending on the circumstances, we have shared Personal Information with these categories of third parties, as further described in Section 3 of this Privacy Policy:
      • Service Companies
      • Analytics Partners
      • Other Business Partners
      • Third Parties When Required or Permitted by Law or To Protect Legal Rights
      • Third Parties in Connection with Certain Business Transactions
      • Affiliated Media Content Providers.
      • Third Parties with Your Consent
      • Social Media and Other Third Party Platforms in Connection with Philo Subscription Service
      • Ad Partners in Connection with Philo Subscription Service
      • Audience Measurement Providers in Connection with Philo Subscription Service
      • Third Parties for Joint Promotions, Sweepstakes or Contests in Connection with Philo Subscription Service
      • Schools in Connection with Authorization for Philo Edu Service
   5. 12.2.1.5 In the last twelve months, depending on the circumstances, we have “Sold” the categories of Personal Information in Section 12.2.1.1 of this Privacy Policy.
   6. 12.2.1.6 In the last twelve months, depending on the circumstances, we have disclosed the categories of Personal Information in Section 12.2.1.1 of this Privacy Policy for a Business Purpose.

12.2.2 Data Rights

12.2.2.1 Right to Know. Up to twice a year, you may request that we disclose to you the following information as it applies to the 12 months before your request:

• The categories of Personal Information we have Collected about you.
• The categories of sources from which the Personal Information is Collected.
• The Business or Commercial Purpose for collecting or “Selling” your Personal Information.
• The specific pieces of Personal Information we have Collected about you.
• The categories of Personal Information we have “Sold” or disclosed about you for a Business Purpose, and the categories of Third Parties to whom your Personal Information was “Sold” disclosed for a Business Purpose.

12.2.2.2 Right to Delete. You may request that we delete the Personal Information we have Collected from you (and direct our Service Providers to do the same). We will delete your Personal Information unless it is necessary for purposes permitted by the CCPA.

12.2.2.3 Right to Opt Out of “Sales”. “Sale” is broadly defined under the CCPA and includes some transfers of Personal Information to Third Parties when no money is paid for the information. We may disclose certain Personal Information that may be considered a “Sale” under the CCPA, and the CCPA gives you the right to opt out of such “Sales” of your personal information. The opt out in this Section will apply to “Sales” that occur after the opt-out has been processed by us within the time limit required under California law. Information on how to opt out of “Sales” is in Section 12.2.2.4.

12.2.2.4 Exercising Your Rights Under the CCPA.

• Any request from you must be a request we can reasonably verify.
• You may designate an authorized agent to make a request on your behalf.
• To exercise any of your rights under the CCPA with Philo, including opting out of “Sales”, please contact us using one of these methods:
  • Contact us at philo.com/contact
  • Email us at help@philo.com
  • Call us at 855-CSPHILO (855-277-4456) during operating hours
• We intend to respond to a Verifiable Consumer Request for knowledge or deletion within 45 days of receiving the request. If we require more time, we will inform you of the reason and extension period in writing.
• We intend to respond to a Consumer Request to opt-out of the “sale” of your Personal Information within the time limit required by applicable law.
• When you make a request under the CCPA, we will use the Personal Information you provide to us only to review and comply with your request.

12.2.2.5 We will not discriminate against you for exercising any of your rights under the CCPA.

12.2.2.6 We do not have a financial incentive program for the Collection, Sale, or deletion of Personal Information.

12.2.2.7 To our knowledge, we do not “Sell” the Personal Information of minors under 16.

13. Third-Party Operating Systems, Platforms, Communication Services, Devices, and Software Elements

Some of the Services use third party operating systems, platforms, communication services, devices, and software elements (such as mobile device operating systems, wireless services, mobile phone, tablet devices, and connected televisions), and some of the Services are provided by third party distributors, device makers, device operators, platform operators, and communication services. We do not control these third party entities, products, and services, and they may collect, use, process, transmit and disclose your information. For example, these third-party entities, products, and services may gather information, including Personal Information, from the Services in a way that overrides your settings and preferences in the Services. As we do not control these third-parties’ data handling practices, we recommend that you review their privacy policies, terms of service and license agreements (if any).

14. Changes to This Policy

We reserve the right to modify this Privacy Policy at our discretion at any time. Material changes will be posted on the Philo website or the Services. If you have an Account and provided your email address, we may also provide you with email notification of such material changes. Your continued use of our Services following any changes constitutes your acceptance of the changes. You should review this Privacy Policy regularly and note the effective date of the policy to ensure you are updated as to any changes.

15. Contact Information

If you have a question related to this Privacy Policy, please contact us at:

philo.com/contact

or at:

help@philo.com

or at:

Philo, Inc.
225 Green Street
San Francisco, CA 94111

or at:

855-CSPHILO (855-277-4456)

This Privacy Policy was last modified on the date stated above and is effective on such date.