Effective date: May 21, 2018
Because our services record and track viewing of content for users of all ages, we may collect photos of children under thirteen (13) through the System. Accordingly, pursuant to the Children’s Online Privacy Protection Act (“COPPA”), if you have children who are under 13 residing in your household we will obtain prior verifiable consent from the parent or legal guardian of each child before such collection, unless the collection of information falls within an exception that is permitted by applicable law. The photos will be collected to as necessary for the child to participate in the Program, and it will only be retained as is reasonably necessary to allow your child to participate in the Program, or as required by law. In addition, these photos will only be used for internal business purposes.
Parents or legal guardians may contact us as set forth below to ask if we have collected their child's Personal Information, to review the information or request that it be deleted, or to withdraw their consent for us to collect such information. We reserve the right to verify that the requester is in fact the child's parent or legal guardian. In any correspondence such as e-mail or mail, please include the child’s name and the parent’s email address and telephone number.
TVision Insights, Inc.
955 Massachusetts Avenue
Cambridge, MA 02139
Information We Collect
Information You Provide to Us:
We receive and store the following Personal Information that you provide to us when you decide to participate in the Program:
- First and last name;
- Email address;
- Physical address;
- Date of birth;
- Demographic information (gender, age, race, ethnicity, city and state);
- Information about your TV and video viewing habits; and
- Phone number.
Information Collected Automatically
Whenever you or others interact with the System (including passively, by simply being in the vicinity of the System when it is on), we automatically receive and capture certain information from the System. This information may include
- certain audience viewing data;
- photos, images, and face geometry (a biometric identifier used for facial recognition); and
- color and depth sensory data.
We use this data to generate information about your engagement with TV and video content and share it as described below.
Use of Your Information
We use your Personal Information and other information internally in connection with our System and the Program, including to: (1) gather information about audience engagement and provide that information to our partners and affiliates; (2) improve our services; (3) allow you to set up a user account and profile; (4) contact you; (5) respond to your service requests; and (6) analyze how you use the System. In certain cases, we may share Personal Information with third parties as described below.
Disclosure of Your Information
We may share your Personal Information and other information that we collect through the System with third parties as follows:
- De-identified Information. We may de-identify your Personal Information and provide it and other information to our partners. We may also provide aggregate usage data to our partners, who may use this data to understand how often and in what ways people use our System, so that they, too, can provide you with an optimal viewing experience.
- Vendors and Service Providers: We may employ third party vendors and service providers to perform tasks on our behalf, or to enable the System technology. We may share your information with these parties to enable them to perform these functions. For example, we may use a data hosting service to store and process information that we collect through the System. Unless you are otherwise informed, these third parties do not have any right to use Personal Information we share with them beyond what is necessary to assist us.
- Business Transfers: Your information may be transferred in the event of a merger, acquisition, reorganization, bankruptcy, receivership, sale of company assets, transition of service to another provider. Your information may be transferred to a successor or affiliate alone or as part of that transaction along with other assets.
- Legal Requirements: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of TVision, (iii) act in urgent circumstances to protect the personal safety of users of the System or the public, or (iv) protect against legal liability.
- With Your Consent: We may also share any information from or about you, including Personal Information and television and video viewing information, with any party when we have your consent.
We store, transmit, and protect Personal Information using a reasonable standard of care within the industry and in a manner that is the same or more protective than the manner in which we store, transmit, and protect other confidential information. However, the Internet cannot be guaranteed to be fully secure and we cannot ensure or warrant the security of any information you provide to us in connection with your participation in the Program.
Retention and Destruction of Face Geometries
TVision will destroy your biometric identifier (specifically, face geometries used for facial recognition in conjunction with the Program) when the purpose for collecting the identifier has expired or been satisfied, or within three years of your last interaction with TVision, whichever occurs first.
Retention of other Personal Information
We retain information about your TV and video viewing habits for one year after your participation in the program concludes and you return the System to TVision. We may retain non-video viewing and non-biometric Personal Information only for as long as is reasonably necessary to accomplish the purposes for which it was collected.
You may contact us at email@example.com to update the following information:
- email address
- household demographic information
You may always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to use the System.
We may communicate with you by email to send you information about other products and services that may be of interest to you. These emails will contain an easy-to-use opt-out mechanism if you no longer want to receive them. You may also contact firstname.lastname@example.org in order to opt-out. Please note that you may continue to receive emails from us concerning your participation in the Program after your opt out of receiving promotional messages from us.
You may withdraw your consent for TVision to share your TV and video viewing information with third parties at any time by emailing us at email@example.com. Please note that withdrawing your consent may result in termination of your participation in the Program.
Third Party Applications and Services