UPDATED AND EFFECTIVE DATE: July 8, 2024
This Privacy Policy applies to all Philo, Inc. (“Philo,” “we,” “our,” “us”) platforms and services, including our websites, apps, APIs, widgets, our subscription-based video streaming service (the “Philo Subscription Service”) and our on-campus, private network video streaming service (the “Philo Edu Service”) (collectively, the “Services"). We want you to understand how we collect, store and use your data, so we encourage you to carefully review this Privacy Policy. The Philo Subscription Service provides live and time-shifted television programming delivered over the Internet through applications on consumer devices, including desktop computers, mobile devices, tablets and connected televisions and the Philo Edu Service provides video streaming service for colleges and universities. For the Philo Edu Service, our agreement with your school may also restrict how we can collect, use, and share your data.
By accessing, visiting, using, interacting, or submitting information to the Services, you agree to (a) the practices described in this Privacy Policy and (b) receive communications from us and, unless you otherwise indicate, third parties as described in this Privacy Policy. This Privacy Policy will remain in full force and effect, even if your use of the Services terminates, expires, or is deactivated. If you do not agree with any provision of this Privacy Policy, do not access or use any part of the Services. This Privacy Policy applies regardless of the device you use to access the Services and whether you are accessing the Services as a guest or a registered user.
Along with this Privacy Policy, please read our Terms of Service for Philo Subscription Service and Terms of Service for Philo Edu Service, which govern your use of the respective Services.
This Privacy Policy contains links to other web pages and websites. These website addresses (i.e., URLs) may not function as hyperlinks on all devices you use to access the Services. To view this Privacy Policy with clickable hyperlinks, please visit the webpage at philo.com/privacy on your device.
Enhancement Data
Viewed Content and VPPA Compliance
Live Chat
Sweepstakes, Contests, & Promotions
Third Parties Providing Services on Our Behalf
Affiliated Media Content Providers
Nielsen Measurement
Employment Applications
Schools in Connection with Support for Philo Edu Service
Social Media and Other Third-Party Platforms in Connection with Services
Business Transactions and Transfers
Digital Fingerprinting and Cross-Device Linking
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 data from children under the age of 18.
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 data of a child under 18 without verifiable consent, then we will take steps to remove such personal data. If you learn we have collected personal data from a child without parental consent, please email us at help@philo.com, contact us at philo.com/contact, or call us at 855-CSPHILO (855-277-4456) promptly.
In connection with the Services, we collect data about you directly through the Services, automatically when you visit the Services, and sometimes from third parties. Some of this data may be considered “personal information” or “personal data,” and some may further be considered “sensitive”, under various applicable laws. We consider data that identifies you as a specific, identified individual (such as your name and email address) to be personal data. We will also treat additional information, including IP addresses and cookie identifiers, as “personal information” “or personal data” where required by applicable law.
Note that we may de-identify or pseudonymize personal data so that it is non-personal, such as aggregating or converting it to a code, sometimes using a function commonly known as “hash”. We maintain and use de-identified data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification processes satisfy legal requirements. We will treat de-identified and pseudonymized data as non-personal to the fullest extent allowed by applicable law. If we combine non-personal data with personal data, then we will treat the combined information as personal data under this Privacy Policy. We may share non-personal data with third parties for any purpose in our discretion and as permitted by law, including for advertising, research and marketing purposes.
Please click here to review a Chart that sets out in detail Philo’s data collection and use practices, which include the (1) categories of personal data we collect, (2) purposes for which we collect that information, (3) categories of third parties to whom that information may be disclosed for a business purpose and (4) categories of third parties to whom the information may be sold for monetary value or other valuable consideration or shared for cross context behavioral advertising/targeted marketing.
We encourage you to read the Chart carefully, but we provide a summary of our key data practices below.
We collect information, including personal data, from you, automatically through your use of the Services, and from third parties. The categories of information we collect that may be considered “personal data” or “personal information” under applicable law include: (1) Contact Information, (2) Payment and Financial Information, (3) Transaction Information, (4) Video Viewing History, (5) Device ID/Information, (6) Location Data, (7) User Account Information, (8) Educational Information in connection with the Philo Edu Service, (9) Employment Information, (10) Demographic Information, (11) Audio Data, (12) Information about Your Interests and Preferences. Each of these categories is further described in the Chart. We primarily use this information to facilitate your use of the Services, to personalize your experience, and to send you information from us or on behalf of certain third parties, and as otherwise disclosed in the Chart. Please also review the "Additional Details About our Data Practices" section for more information.
We may share your information for business purposes with our third party service providers and unaffiliated third-party business partners for their business and marketing purposes, and as otherwise disclosed in the Chart. For more details, please review the Chart and the “Disclosure of Data to Third Parties” section.
Philo works with third party business partners, including online advertising companies, ad agencies, and analytics providers who may set and access their own tracking technologies on your device, and they may otherwise collect or have access to information about you including Device ID/Interaction Information (further defined in Section 4 below). They may use this information to serve Philo ads online, to serve third party ads on the Services, and to provide us with information regarding the use of the Services and the effectiveness of our ads. For more information, including your opt-out choices, please review the “Third Party Advertising and Analytics/Privacy Controls" section and the information set forth in the Chart. This practice may be considered a sale or sharing under certain state laws and residents of those may have additional rights. For more information, please review the “U.S. State Specific Rights” section and our California Privacy Notice.
We provide in this section additional detail about the information practices listed in the Chart of key data practices linked in Section 3 above, where it would be helpful for your understanding of such practices.
Device ID/Information. We, our service providers, business partners, and/or other third parties may automatically collect and/or store certain information when you visit or interact with the Services (“Device ID/Information”). This Device ID/Information may be stored and/or accessed from your computer, tablet, mobile phone, digital media player, or other device whenever you visit or interact with the Services. Device ID/Information may include, but is not limited to:
Approximate Location Data. We may collect or infer your approximate location through data we collect, such as IP address. In addition, some mobile service providers may also provide us or our third-party service providers with data regarding the physical location of the device used to access the Services.
Device ID/Information may be collected through the use of the following technologies:
Cookies, Local Storage, and Local Shared Objects. “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 data 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 Services 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. Most browsers provide you with the ability to disable, decline, or clear cookies and local storage; please check your browser’s settings for further information. You can find more information about cookies at www.allaboutcookies.org.
We may use local shared objects (LSOs) such as 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 Services, to display advertising based upon your web browsing activity may also use HTML5 to collect and store information.
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 or ad on the Services 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 Services, may contain a pixel tag. We may use web beacons and pixel tags to help us optimize and tailor the Services. In connection with certain Services, 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.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily used by our server or a third-party service provider or business partner while you browse or interact with the Services and is deactivated or deleted when you disconnect from the Services.
Software Development Kits (SDKs). These are software packages that contain a set of tools that can be used to help build applications and implement new features in existing apps. These tools can be used to create and operate features that collect information from your device.
Data Collection from Mobile Devices. We use embedded scripts and the tools provided in SDKs to collect information from mobile devices such as the hardware model, operating system and version, identification numbers assigned to your mobile device, such as the ID for Advertising (IDFA) on Apple devices, and the Advertising ID on Android devices, mobile network information, and website usage behavior. In addition, we may use a variety of other technologies that collect similar information for security, fraud detection, and maintenance purposes.
Session Recording Language. Philo may record through session replay technology your interactions with the Services, such as what pages you visit on the Services, how long you visit those pages, and any links you click or information you provide. We use this information for our internal business purposes, such as for website analytics, to improve the Services and our products and services, and to address functionality issues.
In addition, we may use a variety of other technologies that collect similar device and device interaction information for security, fraud detection, and maintenance purposes.
Enhancement Data. We may receive data about you from third parties, such as data aggregators and other business partners. We may also supplement the data we collect with outside records from third parties, such as public databases, publicly available social media pages, and third parties who enhance the information we have about you, in order to provide you with information, services or products you have requested, to tailor content, to provide relevant advertising, to offer you opportunities to purchase products or services that we believe may be of interest to you, and for other purposes. The data collected and stored by third parties is subject solely to the third party’s privacy practices.
We may ask you to provide data to use when you use the Services, for example, in the following ways:
Viewed Content and VPPA Compliance. 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 certain Services.
You acknowledge that, if you choose to post any information about your viewing history on a third-party platform, or by liking or sharing any content, the Video Privacy Protection Act of 1998 (18 U.S.C. § 2710) (or any similar state law) does not apply. However, to the extent it does apply in any manner, you are providing your informed, written consent to the disclosure of that information pursuant to the Video Privacy Protection Act.
Live Chat. The Services can record, use, and retain your information provided, as well as the communications within the chat, for purposes of assisting you during the conversation, provide related support for your account, to improve our products and services, and for marketing purposes. If you do not consent, please do not continue with chat assistance. If you choose to permit screen or video sharing to assist with troubleshooting, we may be able to view any data, applications, or content displayed through your device camera or present on your device screen at that time.
Sweepstakes, Contests, & Promotions. We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern the Promotion, which may contain specific requirements of you (including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, personal data may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, as required by law, or as permitted by the Promotion’s terms or official rules (such as on a winners list).
Philo may share non-personal data, which may include Device ID/Interaction Information, data that has been hashed or otherwise de-identified or pseudonymized, with third parties in our discretion and as allowed by law, including for targeted advertising purposes. We may share the data we have collected about you as allowed by law, as disclosed at the time you provide your information, as described in this Privacy Policy, with your consent, and in the following circumstances:
Third Parties Providing Services on Our Behalf. Certain companies (collectively, “Service Companies”) provide services to us, our business partners or, in the case of certain Services, 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; 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 companies that process payment card information, support our advertising programs, provide data storage, assist with audience research, and assist with product development. Depending on the services they provide, we may share information to Service Companies or allow those Service Companies to collect information about you. 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 payment processors may receive order information, payment information, IP addresses and other device identifiers to process payments; marketing and advertising Service Companies may receive non-precise 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 data we provide to them consistent with our agreements with them, and those terms may, for example, authorize them to use personal data 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 data with their service companies, and , where permitted by law, to improve ad targeting. Additionally, we may share various information relating to our users and fraudulent or potentially fraudulent activities with our fraud prevention and similar service providers, and they will use this information to help us and their other clients prevent fraudulent and illegal transactions
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 is subject to separate terms of use and privacy policy(ies) provided by the media content provider.
Nielsen Measurement. You can access more information about the Nielsen measurement software and learn about your choices regarding Nielsen’s measurement:
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.
Social Media and Other Third-Party Platforms in Connection with Services. By accessing, logging into, or connecting with certain Services 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.
Business Transactions and Transfers. 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 data and non-personal data 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 data 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. By providing your information, you understand and agree that we may transfer such information to the acquiring entity without your further consent.
Digital Fingerprinting and Cross-Device Linking. Besides the data collection and sharing described elsewhere in this Privacy Policy, some third parties 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 data 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 personalized advertising on and within certain Services and other websites or applications you visit. To learn more about your choices to opt-out of third party advertising and analytics, please see Section 5 of this Privacy Policy.
We work with a variety of third party business partners (such as advertisers, ad networks, advertising servers, data exchanges, traffic measurement providers, marketing analytics providers, anti-fraud vendors, ad verification vendors, ad agencies and other providers who provide services related to advertising (“Ad Partners”) to deliver ads to you on certain Services and elsewhere online, to provide services related to advertising, and to provide services to help us market and advertise certain Services on other services. These Ad Partners may set and access their own tracking technologies on your device (including cookies and web beacons), and they may otherwise collect or have access to Device ID/Interaction Information and other data about you, some of which may be personal data under various state laws. You may submit data requested by interactive ads placed on certain Services or on third-party platforms. We may share this information with our Ad Partners. The Ad Partners may use various technologies to identify your non-precise location, such as city or zip code. 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 Services. These collection technologies on the Services, in your browser and within our applications may be used to (among other purposes) collect data about you when you visit the Services (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 Services, and where you go after you leave that Service, and your other activities online and may include the information described in Section 2 of this Privacy Policy (“Personal, Sensitive, and Non-Personal Data We Collect and How We Use and Disclose It ”), including without limitation, your email address and phone number. The Ad Partners may use the information on the Services and on other websites and applications you visit for purposes that include, without limitation, the following activities: to advertise to you on the Philo Services and elsewhere online based on your activities on our Services; measure ad performance and report the efficacy and performance of ad campaigns; improve advertising effectiveness, including to determine when an ad is viewable to a consumer; track conversions; generate and match audience segments for the purposes of targeting ads; limit the frequency with which you see certain ads; generate campaign insights to better understand the impact of an ad campaign or its effect on the types of audience to which it was served; link your devices, enable other enhancements, provide reporting, detect actual or potential ad 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 Services and elsewhere online, including negative targeting” (i.e., designate you as among a group of consumers not to be targeted with certain ads); comply with law, and provide the information to other Ad Partners. Besides the other uses described in this section, our Ad Partners may use your non-precise location to provide ads, offers and notices relevant to your geographic location.
We may provide log files to Ad Partners for the purposes described in this section). The log files cover activity on the Services 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.
If you would like to opt-out of third party advertising and analytics, there are a variety of tools available to you:
Cookie Opt-Out Tools. 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. Various browsers may offer their own management tools for removing HTML5. To disable sharing through cookies set on our site by third parties for advertising and analytics purposes, please visit our Help Center page on Opting-Out of Sales, Sharing, and Targeted Advertising. Please see also our U.S. State-Specific Rights section below for more information.
Global Privacy Controls. Global Privacy Control (“GPC”) is a technical specification in your browser settings that you can use to automatically inform websites of your privacy preferences with regard to third party online tracking. To find out more about and set up GPC, please visit https://globalprivacycontrol.org/#about.
NAI/DAA Opt-Out. 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 Services and your options not to accept cookies placed by some Ad Partners on the Services, 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.
Google Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of Services and report on activities and trends. This service may also collect information about the use of other websites, apps, and online services. 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/.
Interest-Based Advertising. We work with Ad Partners who provide interest-based advertising, targeting, analytics, and optimization services to Philo. For more information on these Ad Partners or to opt-out of the collection and use of your data for the purposes of interest-based advertising, please see below.
Connected Devices. Connected devices, such as TV streaming devices and smart TV’s, often offer mechanisms that allow you to manage your privacy preferences for digital advertising data collection and use. Please review your device settings to learn more and/or opt-out of interest based advertising on connected devices. You can also learn more about your choices related to connected devices here.
The Trade Desk. To learn more about The Trade Desk and their cookie-less identifier, Unified ID 2.0 (UID2), please visit The Trade Desk's Privacy Policy. To opt-out of The Trade Desk’s UID2, please visit The Trade Desk’s Opt-Out page here.
Liveramp. To learn more about Liveramp’s privacy practices, please visit liveramp.com/privacy. To opt-out of Liveramp, please visit liveramp.com/opt_out.
Do Not Track. 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 will monitor and follow any Do Not Track or similar browser requests when they meet the requirements of applicable laws. For more information about do not track, visit www.allaboutdnt.org.
Please note that opting out through these mechanisms does not opt you out of being served advertising, and that you will continue to receive generic ads while online. Your opt-out choices are typically browser and device specific; if you disable your cookies, upgrade your browser after opting out, or use multiple different devices, please opt-out on each device and each browser separately.
Certain states provide additional rights. Please see Section 13 – U.S. State-Specific Rights below for more information.
The details:
The Services may contain content that is served by someone else or links to third party websites or services that Philo does not control. 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 data. The third-party operators and content providers use their own cookies or other tracking technologies on your device and they may independently collect data from or about you. If you would like information on any other party’s privacy policy, contact that party directly, and we encourage you to do so.
We have implemented physical, electronic, and managerial procedures intended to protect your data. While Philo takes commercially reasonable steps designed to secure your personal data, no data transmission over the Internet, wireless transmission, or electronic storage of data can be guaranteed to be 100% secure. 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 use of our Services or 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.
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 data 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.
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 data, 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).
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.
If you have a question related to this Privacy Policy, please contact us at:
or at:
or at:
Philo, Inc.
225 Green Street
San Francisco, CA 94111
or at:
855-CSPHILO (855-277-4456)
Residents of certain U.S. states may have the ability to exercise additional rights and choices regarding their personal data. We will take reasonable steps to accommodate your request but may need to verify your identity before doing so. If you are a resident of Colorado, Montana, Oregon, Texas, or Nevada, please see additional information below. If you are a California resident, please see Section 14 – California Privacy Notice.
Colorado, Montana, Oregon, and Texas. We set forth above the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared. Residents of Colorado, Montana, Oregon, and Texas have certain privacy rights with respect to this data, as described below. If you are a Consumer of one of these states (as defined by by the respective state law) and would like to exercise your applicable rights, please email us at help@philo.com or contact us at philo.com/contact.
In your request, please provide enough information to allow us to verify you are the person about whom we collected personal data. You must also describe your request with enough detail so that we can understand, evaluate and respond to it. We can’t respond to your request if we can’t verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity.
Opt-Out of Sales of Your Personal Data and Targeted Advertising – You have the right to opt out of the sale of your data. Colorado, Montana, Oregon, and Texas laws define “sale” broadly to include sharing for monetary or other valuable consideration that may be triggered by certain targeted advertising, analytics practices, or similar activities that Philo engages in. If you would like to opt out of the sale of your personal data, please make a request by emailing help@philo.com or contact us at philo.com/contact.
Right to Appeal – If, for any reason, you would like to appeal our decision relating to your request and you are a resident of Colorado, Montana, Oregon, or Texas, you have the right to submit an appeal and can do so by emailing help@philo.com or contact us at philo.com/contact. Please include your full name, the basis for your appeal, and any additional information to consider.
Sensitive Data – If you are a Colorado, Montana, Oregon, or Texas resident, we will obtain your consent to the processing of any Sensitive Data (as defined by the respective state law) we collect.
Nevada. Philo does not currently sell your covered information as those terms are defined under applicable Nevada law. You may still submit an opt-out request, and we will honor that request as required by Nevada law if Philo were to engage in such a sale in the future. If you are a Nevada resident and would like to opt-out of the sale of your covered information, please submit your request by emailing us at help@philo.com, contacting us at philo.com/contact, or calling us at 855-CSPHILO (855-277-4456). Your request must include your full name, street address, city, state, zip code, and an email address so that we can contact if needed regarding this request. If you previously provided a phone number, it will assist us in making sure we identify you as someone who wants to opt-out. You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request. Philo will respond to your request within sixty (60) days either confirming that your request has been processed or indicating that we need an additional thirty (30) days to complete the request.
If you are a resident of California, the following rights may be available to you, and to the extent the terms in this Section 14 conflict with other terms in this Privacy Policy, this Section 14 shall control.
This California Privacy Notice is updated and effective as of July 1, 2024.
This California Privacy Notice supplements the information contained in Philo’s Privacy Policy and applies only to California residents. This notice sets forth the disclosures and certain additional rights for California Consumers regarding their personal information, as required by the California Consumer Privacy Act (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”), described below. This notice supplements the information in this Privacy Policy and applies only to California residents. All capitalized terms in this Section 14.1 that are not otherwise defined in this Privacy Policy shall be defined as set forth in the CCPA, CPRA, and the associated regulations of the Attorney General, unless otherwise defined. 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 California Privacy Notice – Employees, Applicants, Owners, Directors, Officers and Contractors.
California Consumers have the right to request: (1) that we disclose to you what personal information we collect, use, disclose, and sell/share, including the right to request that we provide to you the specific pieces of personal information we have collected about you (“Right to Know”) (2) that we delete the personal information we have collected from you (“Right to Delete”); and, (3) that we correct inaccurate personal information we hold about you (“Right to Correct”), (4) to opt out from the sharing of your personal information to a third party for cross-context behavioral advertising (i.e. targeted advertising) (“Right to Opt-Out of Sharing”), and (5) to opt-out from the sale of personal information (“Right to Opt-Out of Sale”), all subject to the meanings and exceptions set forth in the CCPA and CPRA. More information on each of these rights is below.
California Consumers may request that we disclose the following information:
In order to have us provide you with specific pieces of information, we may require a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
California Consumers may request that we delete the personal information we have collected from you (and direct our Service Providers to do the same).
Please note that as part of the verification process, we may follow up after you submit your request and require you to confirm that you want your information deleted.
California Consumers have the right to request that we correct inaccurate information we hold about you.
Under the CPRA Regulations, a business must only provide the Right to Limit the Use and Disclosure of Sensitive Personal Information when such sensitive personal information is collected or processed for the purpose of inferring characteristics about a consumer, or does not fall under certain statutory exceptions, pursuant to CPRA §1798.121. Philo’s use and disclosure of sensitive personal information is not used for such purpose and/or falls within the statutory exceptions, and we therefore do not offer this right at this time.
“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. Philo engages in certain online advertising practices (and third-party analytics and similar activities), which may be considered a “sale” or “share” for cross-context behavioral advertising (i.e., targeted advertising). The opt out in this Section will apply to “sales” or “sharing” that occurs 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 14.1.3.
To disable sharing through cookies set on our site by third parties for advertising and analytics purposes, please visit https://www.philo.com/do_not_sell and learn more at our Help Center page on Opting-Out of Sales, Sharing, and Targeted Advertising. If you have a Philo account, you may stop the sale or sharing of your personal data that we may collect in connection with your account by visiting your Account Settings and clicking the toggle next to “Do Not Sell/Share My Personal Information for Cross-Context Behavioral Advertising/Opt-Out of Targeted Advertising”.
Please read the “Third-Party Advertising & Analytics/Privacy Controls” section of the policy for more information on how you can manage your privacy via third parties. The Digital Advertising Alliance (“DAA”) also offers tools for California consumers to send requests under the CCPA to opt out of the sale of personal information by some or all of the participating companies (https://privacyrights.info).
Any request from you must be a request we can reasonably verify and you must also describe your request with enough detail so that we can understand, evaluate and respond to it. Making such a request does not require you to create an account with us.
When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we may ask that you provide us with information, beyond your full name, in order to verify your identity and fulfill your request, such as your mailing address, phone number (if you have provided it), and email address that you have used to interact with Philo. We will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making. We may ask for additional information as needed to fully verify your request.
If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.
California Consumers may designate an authorized agent to make a request on your behalf. If you are an agent submitting a CCPA request on a consumer’s behalf, please complete your request through one of the methods outlined below. We will also ask you to submit a declaration signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request and needs to be clear about the permission granted. Alternatively, you may submit a copy of a power of attorney under Probate Code sections 4000-4465. The consumer’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the consumer to directly confirm with us that they provided you with permission to submit a request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer’s behalf, we may deny the request.
To exercise any of your rights under the CCPA with Philo, including opting out of “sales” or “sharing” for cross context behavioral advertising, please submit your request using one of these methods:
Email us at help@philo.com.
Contact us at philo.com/contact.
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” or “sharing” 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.
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 will monitor and follow any Do Not Track or similar browser requests when they meet the requirements of applicable laws. For more information about do not track, visit www.allaboutdnt.org.
Global Privacy Control (“GPC”) is a technical specification in your browser settings that you can use to automatically inform websites of your privacy preferences with regard to third party online tracking. To find out more about and set up GPC, please visit https://globalprivacycontrol.org/#about
We will retain all categories of personal information described in this California Privacy Notice for as long as it is reasonably necessary for the purposes set out in this California Privacy Notice, considering the time period reasonably necessary to: use the Sites; exercise the choices and rights you have requested; comply with our contractual obligations; enforce our terms for use of the Sites; comply with legal and regulatory requirements, and allow you to restart your Account. If you are a user of the Philo Subscription Service, please review our retention practices related to your Account deletion as further outlined in Section 6(F) of the Philo Privacy Policy. Except as noted differently on specific pages or apps, we retain your personal information while you have an account with us, while you are using our Sites or continuing to visit us, or to restart your Account. We will retain information from closed accounts as necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is otherwise required or permitted by law.
14.1.6 California consumers have the right to not receive discriminatory treatment for exercising CCPA rights. We will not discriminate against you for exercising any of your rights under the CCPA.
14.1.7 Under California regulation, certain programs we offer that provide benefits to consumers may be considered financial incentive programs. We may collect personal information from you in connection with these programs, for example contact information (name, email address, phone number, residential address, year of birth) and certain commercial information for a number of reasons, including to administer the program, contact you with regard to your account (if any), to provide the benefits to you, to better serve you, process payments, and to fulfill your requests associated with the program.
To opt into the programs, you may need to provide certain information, register for an account and agree to the applicable program terms, or otherwise follow the instructions associated with that applicable program. Please also see the terms of the program you are joining for additional description of the program and any additional requirements. Participation in our programs is voluntarily, and you can withdraw at any time.
To the extent that we provide a program that may be considered a financial incentive because the program is directly or reasonably related the collection, deletion or sale or retention of consumer personal information, the value is reasonably related to the overall value we receive from the personal information participants provide specific to the program minus the costs and expenses we incur in providing the program.
In addition to the below, we may collect and/or use additional types of information and will do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA and CPRA.
14.1.8 To our knowledge, we do not “Sell” or “Share” the personal information of minors under 16.
The personal information we collect about you will depend upon how you use our Services or otherwise interact with us. Accordingly, we may not collect all of the below information about you.
In addition to the below, we may collect and/or use additional types of information, and will do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA and CPRA.
Category of Personal Information Collected |
Categories of Sources from which the Information was Collected |
Business or Commercial Purpose(s) for which Information is Collected |
Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose |
Categories of Third Parties to Whom this Type of Personal Information is Sold or Shared for Cross Contextual Behavioral Advertising |
|---|---|---|---|---|
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) |
We may collect this type of information from: - Consumer (i.e., you), - Cookies and tracking technologies - Social media companies - Third-party business partners - Schools in connection with the Philo Edu Service |
We may use this type of information to: - Provide you the Services, allowing you to participate in features we offer; - Manage our relationship with business contacts for the purposes of receiving their services and support; - Communicate with you, including for marketing, promotions, updates and notices; - Verify and authenticate your identity, and verify your eligibility to use the Services; - Tailor your experience on the Services and/or otherwise customize what you see when you use the Services, including customizing recommendations; - Understand, analyze, and measure how you use the Services; - Process and collect payments related to a purchase or as otherwise related to your Philo Subscription Service; - Prevent, detect, and prosecute security incidents and potentially fraudulent, illegal, or harmful activities; - Enforce this Privacy Policy, our Terms of Service and other policies; - Comply with legal obligations or legal processes; - Undertake activities to verify or maintain the quality or security of the Services; - For any other purpose disclosed to you when we collect the information or with your consent |
We may disclose this type of information to: - 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 - Ad Partners - Audience Measurement Providers - Third Parties for joint promotions Sweepstakes or Contests - Schools in connection with the Philo Edu Service |
Third party advertising, analytics, and similar marketing business partners may have access to this data, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances. |
Any categories of Personal Information described in subdivision (v) of Section 1798.140 (such as name, address, and phone number, and other categories of information classified as “personal” under this California law.) Note: information in this category may overlap with other categories. |
We may collect this type of information from: - Consumer (i.e., you), - Cookies and tracking technologies - Social media companies - Third-party business partners - Schools in connection with the Philo Edu Service |
We may use this type of information to: - Provide you the Services, allowing you to participate in features we offer; - Manage our relationship with business contacts for the purposes of receiving their services and support; - Communicate with you, including for marketing, promotions, updates and notices; - Verify and authenticate your identity, and verify your eligibility to use the Services; - Tailor your experience on the Services and/or otherwise customize what you see when you use the Services, including customizing recommendations; - Understand, analyze, and measure how you use the Services; - Process and collect payments related to a purchase or as otherwise related to your Philo Subscription Service; - Prevent, detect, and prosecute security incidents and potentially fraudulent, illegal, or harmful activities; - Enforce this Privacy Policy, our Terms of Service and other policies; - Comply with legal obligations or legal processes; - Undertake activities to verify or maintain the quality or security of the Services; - For any other purpose disclosed to you when we collect the information or with your consent |
We may disclose this type of information to: - 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 - Ad Partners - Audience Measurement Providers - Third Parties for joint promotions Sweepstakes or Contests - Schools in Connection with the Philo Edu Service |
Third party advertising, analytics, and similar marketing business partners may have access to this data, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances. |
Protected classification characteristics (such as age, marital status, and gender) |
We may collect this type of information from: - Consumer (i.e., you) - Social media companies - Third-party business partners |
We may use this type of information to: - Provide you the Services, allowing you to participate in features we offer; - Manage our relationship with business contacts for the purposes of receiving their services and support; - Communicate with you, including for marketing, promotions, updates and notices; - Verify and authenticate your identity, and verify your eligibility to use the Services; - Tailor your experience on the Services and/or otherwise customize what you see when you use the Services, including customizing recommendations; - Understand, analyze, and measure how you use the Services; - Prevent, detect, and prosecute security incidents and potentially fraudulent, illegal, or harmful activities; - Enforce this Privacy Policy, our Terms of Service and other policies; - Comply with legal obligations or legal processes; - Undertake activities to verify or maintain the quality or security of the Services; - For any other purpose disclosed to you when we collect the information or with your consent |
We may disclose this type of information to: - 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 - Ad Partners - Audience Measurement Providers - Third Parties for joint promotions Sweepstakes or Contests |
Third party advertising, analytics, and similar marketing business partners may have access to this data, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances. |
Commercial information (such as the Services you have obtained and your history of using those Services) |
We may collect this type of information from: - Consumer (i.e., you), - Cookies and tracking technologies - Social media companies - Third-party business partners |
We may use this type of information to: - Provide you the Services, allowing you to participate in features we offer; - Manage our relationship with business contacts for the purposes of receiving their services and support; - Communicate with you, including for marketing, promotions, updates and notices; - Verify and authenticate your identity, and verify your eligibility to use the Services; - Tailor your experience on the Services and/or otherwise customize what you see when you use the Services, including customizing recommendations; - Understand, analyze, and measure how you use the Services; - Process and collect payments related to a purchase or as otherwise related to your Philo Subscription Service; - Prevent, detect, and prosecute security incidents and potentially fraudulent, illegal, or harmful activities; - Enforce this Privacy Policy, our Terms of Service and other policies; - Comply with legal obligations or legal processes; - Undertake activities to verify or maintain the quality or security of the Services; - For any other purpose disclosed to you when we collect the information or with your consent |
We may disclose this type of information to: - 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 - Ad Partners - Audience Measurement Providers - Third Parties for Joint Promotions - Sweepstakes or Contests - Schools in Connection with the Philo Edu Service |
Third party advertising, analytics, and similar marketing business partners may have access to this data, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances. |
Internet or other electronic network activity information (such as information about the hardware and software you use to visit the Services, areas of the Services you visit, login information (such as when you last logged into your Philo account, and other information regarding your interaction with the Services)) |
We may collect this type of information from: - Cookies and tracking technologies |
We may use this type of information to: - Provide you the Services, allowing you to participate in features we offer; - Manage our relationship with business contacts for the purposes of receiving their services and support; - Communicate with you, including for marketing, promotions, updates and notices; - Verify and authenticate your identity, and verify your eligibility to use the Services; - Tailor your experience on the Services and/or otherwise customize what you see when you use the Services, including customizing recommendations; - Understand, analyze, and measure how you use the Services; - Prevent, detect, and prosecute security incidents and potentially fraudulent, illegal, or harmful activities; - Enforce this Privacy Policy, our Terms of Service and other policies; - Comply with legal obligations or legal processes; - Undertake activities to verify or maintain the quality or security of the Services; - For any other purpose disclosed to you when we collect the information or with your consent |
We may disclose this type of information to: - 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 - Ad Partners - Audience Measurement Providers - Third Parties for Joint Promotions - Sweepstakes or Contests in Connection with Philo Subscription Service - Schools in Connection with the Philo Edu Service |
Third party advertising, analytics, and similar marketing business partners may have access to this data, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances. |
Audio, electronic, or similar information such as recordings of your support and service calls to us, and electronic information, such as device information as described in Section 4(A). |
We may collect this type of information from: - Consumer (i.e., you), - Social media companies - Third-party business partners |
We may use this type of information to: - Provide you the Services, allowing you to participate in features we offer; - Communicate with you, including for marketing, promotions, updates and notices; - Understand, analyze, and measure how you use the Services; - Prevent, detect, and prosecute security incidents and potentially fraudulent, illegal, or harmful activities; - Enforce this Privacy Policy, our Terms of Service and other policies; - Comply with legal obligations or legal processes; - Undertake activities to verify or maintain the quality or security of the Services; - For any other purpose disclosed to you when we collect the information or with your consent |
We may disclose this type of information to: - 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 |
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Inferences drawn from the information we collect about you These inferences help us to provide support for our Services, to manage, improve, upgrade, enhance, and optimize the Services’ operations, and better understand your preferences, characteristics, and behavior, including to customize content, our Services, and ads for you. |
We may draw these inferences ourselves or acquire them from third-party data resellers or other business partners. | We may use this type of information to: - Provide you the Services, allowing you to participate in features we offer; - Tailor your experience on the Services and/or otherwise customize what you see when you use the Services, including customizing recommendations; - Understand, analyze, and measure how you use the Services; - Prevent, detect, and prosecute security incidents and potentially fraudulent, illegal, or harmful activities; - Enforce this Privacy Policy, our Terms of Service and other policies; - Comply with legal obligations or legal processes; - Undertake activities to verify or maintain the quality or security of the Services; - For any other purpose disclosed to you when we collect the information or with your consent |
We may disclose this type of information to: - 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 - Ad Partners - Audience Measurement Providers - Third Parties for joint promotions Sweepstakes or Contests |
Third party advertising, analytics, and similar marketing business partners may have access to this data, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances. |
14.2 "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 email us at help@philo.com, philo.com/contact, call us at 855-CSPHILO (855-277-4456), or send a request by postal mail to the address in Section 12 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.