SENTAI®

Updated February 5, 2020

Updates to Our Privacy Policy. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on this Site or elsewhere across our Services. Your use of the Services following these changes means that you accept the revised Privacy Policy. If you would like to review the version of the Privacy Policy that was effective immediately prior to this revision, please contact us at privacy@sentaifilmworks.com.

TYPES OF INFORMATION WE COLLECT

We collect personal information and anonymous information. These categories of information may be combined as aggregate information. When anonymous information is directly or indirectly associated with personal information, this anonymous information also is treated as personal information.

We collect the following kinds of information:

· Registration information you provide when you create an account, including your first name, family name, address, country of residence, gender, date of birth, email address, username and password

· Location information when you visit our sites and/or use our applications, including location information provided by mobile devices communicating with our sites or applications (including beacon technologies) and information such as your IP address where such collection is required and/or permissible by law

· Information you provide when you use our sites, services, applications, and our applications on third party sites and platforms

· Information you provide on our sites and/or applications

· Usage, technical data, including device identifiers and IP addresses, when you visit our sites, use our applications on third party sites or platforms or you interact with emails we transmit

· Transaction information you provide when you request information or purchase a product or service from us, whether on our sites or via our applications, including your order information, preferences, mailing and/or billing address, telephone number and payment information

· Credit card data is captured at the moment required to conclude a transaction and is not stored by us; our payment gateway may retain that information for the purposes of billing, chargebacks and fraud detection.

HOW WE COLLECT YOUR INFORMATION

· We collect information you provide to us when you request products, Services or information from us, when you register with us, when you report bugs or issues affecting your use of our products and Services, when you submit requests for new products and Services or other activities on our sites and applications, when you respond to surveys, or you and/or your devices otherwise interact with us.

· We collect information through technological means such as cookies, web beacons, or other means, including when you visit our sites and use our applications or use our applications on third party platforms.

· We acquire information about you from other sources, such as public databases, our affiliates and strategic partners when you have enabled sharing, data aggregators, and other commercially available sources. In some cases, local law may require that you authorize the third party to share your information with us before we can acquire it.

HOW WE USE YOUR INFORMATION

We may have access to and use your information for the following purposes:

· Provide you with the products and services you request

· To the extent consistent with applicable law and preference controls that we make available to you, to:

(i) Personalize, customize and enhance the relevance of content and experience

(ii) Send you offers, promotions and other marketing and/or advertising material relating to our sites, products, Services and applications or those of third parties

(iii) Improve the relevance of our marketing and advertising interactions with you regarding our sites, products, Services and applications and those of others

· Communicate with you about your account, account usage or transactions with us

· Send you information about features and changes to our sites, applications, products and Services, or changes to our policies

· Detect, investigate and prevent activities that may violate our policies or which may be illegal or infringing of third party rights including responding to valid private party requests, government and law enforcement requests made consistent with applicable law

SHARING YOUR INFORMATION WITH OTHERS

We do not knowingly allow other parties to collect personal information about your online activities over time and across third-party websites when you use our site and Services. However, when you leave our site or click links to affiliated Service Providers including, by way of example, our e-commerce affiliates, they may collect information about you to conduct business with you, to transact with you and/or to otherwise interact with you. Their policies may differ from ours.

Your information may be shared with:

· Service Providers. Service Providers are third parties with whom we may work to offer products and Services such as our e-commerce affiliates. You can tell when you are accessing a Service offered by a Service Provider because the Service Provider's name will be featured prominently. You may be asked to provide information about yourself to register for a Service offered by a Service Provider. In doing so, you may be providing your information to both us and the Service Provider, or we may share your information with the Service Provider. Please note that the Service Provider's privacy policy may apply to its use of your information.

· Social Media Advertising Networks. We may share information about you with social media networks to allow for the delivery of customized advertising about products and Services that you may be interested in. We provide this information to the social media network so they can deliver the ad to the right social media user. The delivery of customized social media ads, and your ability to opt-out of receiving those ads, is governed by the privacy policies of the social media companies who deliver customized ads to you.

· Corporate Affiliates. We may share information including your personal information with commonly owned, wholly or majority owned affiliates or other affiliated organizations, such as HIDIVE.COM, so they can provide you with information about services and products that might interest you.

· Approved Vendors. We may share your information including your personal information with companies we hire to provide certain services such as providing customer service features, moderator services, improving advertising services, providing subscriber benefits and managing databases or other technology.

· Aggregate Data. We may share aggregate statistics and other non-personal information with the media, government agencies, advertisers and other third parties. These aggregate statistics will not allow anyone to identify your name or other personal information.

We May Share Your Information with Other Third Parties:

· Pursuant to Legal Requirements. We will disclose your personal information in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement agency or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law.

· To Protect Our Website and Users. We will disclose your personal information when we believe disclosure is necessary to investigate, prevent or take action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our employees, our website users or others; or to enforce our website terms and conditions or other agreements or policies.

· In Connection with Business Transfers. We may share your personal information as required by law, such as in response to a subpoena or court order or in the unlikely event of a substantial corporate transaction, such as the sale of SENTAI or our affiliates, a merger, consolidation, asset sale or bankruptcy.

CHILDREN’S PRIVACY

Our Services are not addressed toward individuals under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from Children. While individuals under the age of 18 may utilize the service, they may do so only with the involvement, supervision, and approval of a parent or legal guardian.

If you are a parent or guardian and you are aware that your Children have provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to remove that information from our servers. Please contact us at: privacy@sentaifilmworks.com.

DATA SECURITY INTEGRITY AND RETENTION

The security and confidentiality of user information are extremely important to us. We utilize technical, physical and administrative measures that are intended to protect user information from unauthorized access, use and disclosure. We review periodically our security protocols which review can include updating those protocols to address changes in technology, methods and risks. However, be advised, that despite our best efforts, no protocol is perfect and no security measure can guarantee protection. We retain your personal information for the length of time needed to fulfill the purposes outlined in this Privacy Policy or otherwise to the extent permitted or required by applicable law.

DATA PROTECTION

Wherever your personal information is processed, stored or transferred by us, we will take reasonable steps to safeguard the privacy of your personal information. We seek to use reasonable organizational, technical and administrative measures to protect personal information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us at privacy@sentaifilmworks.com.

SENSITIVE DATA

Unless specifically requested or required by law, we ask that you not send us, and you not disclose, on or through the Services or otherwise to us, any sensitive personal information (e.g., social security numbers, national identification number, data related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, or administrative or criminal proceedings and sanctions).

CROSS BORDER TRANSFER

 

SENTAI provides a global service. Sharing data cross-border is essential to the Services so that you receive the same high-quality service wherever you are in the world. As a result, we will, subject to law, transfer personal information and other data collected in connection with the Services, to entities in countries where data protection standards may differ from those in the country where you reside. By using any of the SENTAI branded services, you understand that we transfer your personal information globally. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries will be entitled to access your personal information.

 

COOPERATION WITH LAW ENFORCEMENT AND LEGAL PROCESS

We intend to cooperate with valid private party requests, government and law enforcement requests for information made consistent with applicable law. The primary set of laws governing disclosure of user information is found in the Electronic Communications Privacy Act, 18 U.S.C. § 2701, et seq. (“ECPA”). Because the SENTAI platform functions as an electronic communications service, ECPA mandates that we disclose certain user information only in response to specific types of government process, including subpoenas, court orders, and search warrants. Generally speaking, ECPA permits disclosure of basic user identity and log-in information in response to a subpoena, but requires a court order to disclose additional user records, or search warrant to authorize disclosure of any online communications (e.g. “chat”). The rules may differ also depending on whether law enforcement seeks information that has already been stored, or to capture information prospectively. We may disclose any information about you to private parties (responsive to valid process), government or law enforcement officials as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our rights (or those of a third party), to enforce our terms of use, to protect the safety of the public or any person, or to prevent or stop any activity we consider to be, or to pose a risk of being, unlawful, illegal, unethical, inappropriate or legally actionable.

 

· We may change this Privacy Policy from time to time to address or accommodate technology changes, commercial practices, regulatory requirements and for other purposes.

· We will provide notice to you to the extent the changes are material. We may also obtain your consent to changes to the extent required by applicable law.

LINKS TO OTHER SITES

Our sites and applications may provide links or offer re-directs to other sites and applications that are not operated by us and which are not governed by this Privacy Policy. We urge you to review and become familiar with the privacy policies and practices associated with those other sites and applications.

YOUR CONTROLS AND PREFERENCES

We have enabled features for users to configure how certain information is made available through our social media services. These features are available within the My Account and My Profile sections of the site.

ACCOUNT PROFILES

We may enable account holders to create unique profiles to enable a more customized shopping and user experience and to provide our Services in a manner that is relevant to each account holder and profile. If you share or otherwise allow others to have access to your account, they will be able to view your information (including in some cases personal information) such as your purchase history, ratings, settings, and account information (including your email address or other account information). Anyone you share or allow to access your account can navigate to and use, edit or delete profiles. You should explain this to others with access to your account, and if you do not wish them to use or change your profile, it is your responsibility to address such matters with them.

DEACTIVATING YOUR ACCOUNT

If the Site functionality permits, you can deactivate your account at any time by visiting the preferences page for your profile or delete any content you provide from the Site, though we may retain a copy of any deactivated accounts or deleted content for compliance purposes. When you deactivate your account, your user profiles will be disabled, but your public comments will remain on the site. The Site has no responsibility to take down, remove, or edit any of your public activities or any submissions that are a result of your public activities. For more information, please review our TERMS OF USE at https://www.sentaifilmworks.com/pages/terms-of-use.

COMMENTS, QUESTIONS AND EXERCISE OF YOUR RIGHTS

If you have questions or concerns about our privacy practices and policies or if you wish to exercise any specific rights applicable to you, you may contact us at privacy@sentaifilmworks.com or write to us at SENTAI Privacy Administration, 10114 W. Sam Houston Parkway South, Suite 100, Houston, Texas 77099-5109

NOTICE TO CALIFORNIA RESIDENTS

If you are a California resident, you may have certain additional rights. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes. The law requires operators of websites and online services that collect Personal Information about consumers to explain their do not track policies and procedures. It does not require sites to honor do not track signals and requests, but it does require websites to inform consumers if they disclose consumer data to third parties.

"Do Not Track" Notice

Because providers of "do not track" and similar signals do not yet operate according to common, industry-accepted standards, we currently do not respond to those signals.

Web Site Data Collection

We do not knowingly allow other parties to collect personal information about your online activities over time and across third-party web sites when you use our site and services.

California Business and Professions Code Section 22581 permits registered users who are minors to request and obtain deletion of certain posted content. Requests of this nature should be directed to privacy@sentaifilmworks.com

Users who wish to request further information about our compliance with these requirements, or have questions or concerns about our privacy practices and policies as they relate to California residents may contact us at privacy@sentaifilmworks.com or write to us at 10114 W. Sam Houston Parkway South, Suite 100, Houston, Texas 77099-5109

NOTICE TO EUROPEAN ECONOMIC AREA (EEA) RESIDENTS REGARDING GENERAL DATA PROTECTION REGULATION (GDPR):

If you are from the European Economic Area (EEA), our legal basis for collecting and using the personal information described in this Privacy Policy depends on the personal information we collect and the specific context in which we collect it. We may process your personal information because:

· We need to perform a contract with you

· You have given us permission to do so

· The processing is in our legitimate interests and it’s not overridden by your rights

· To comply with the law

The GDPR affords you certain rights with respect to your personal information as outlined below.

WITHDRAWAL OF CONSENT

You can withdraw your consent for the collection, usage and storage of your personal information and personal information without charge and at any time by giving us reasonable notice. Your withdrawal request can be sent via mail to privacy@sentaifilmworks.com or by regular mail Attn: SENTAI Privacy Administration, 10114 W. Sam Houston Parkway South, Suite 100, Houston, Texas 77099-5109

(i) Following receipt of your request, we will inform you of the likely consequences of the withdrawal of your consent and will cease to process your personal information and personal information therefrom, unless otherwise permitted or required by applicable laws and regulations.

(ii) However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal information, it may mean that we will not be able to continue with your existing relationship with us.

RIGHT OF INFORMATION, CORRECTION AND THE RIGHT TO BE FORGOTTEN

You have the right to request anytime information about the data stored by us concerning you, their source and their recipients as well as the purpose of the data processing. Furthermore, you have the right of correction, and the right of deletion/erasure of the data stored with us.

RIGHT TO OBJECT

You have the right to object at any time to processing of personal information concerning yourself which are necessary for the purposes of the legitimate interests pursued by us. We will no longer process the personal information unless there are lawful or other legitimate grounds for the processing which override the interests, rights and freedoms of you or for the establishment, exercise or defense of legal claims.

RIGHT TO RESTRICTION OF PROCESSING

You have the right to obtain restriction of procession when:

· the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information;

· the processing is unlawful and you oppose the erasure of the personal information and request the restriction of their use instead;

· we no longer need the personal information for the purposes of the processing, but they are required by you for the establishment, assertion or defense of legal claims;

· you have objected to processing your data pending the verification whether our lawful or legitimate grounds override your grounds.

RIGHT TO DATA PORTABILITY

You have the right to receive the personal information concerning yourself, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us, where:

· the processing is based on consent;

· the processing is carried out by automated means

· In exercising your right to data portability, you have the right to have the personal information transmitted directly from us to another controller, where technically feasible

· However, the exercise of the right to data portability:

(i) is without prejudice to the right to erasure;

(ii) shall not adversely affect the rights and freedoms of others.

RIGHT TO LODGE A COMPLAINT WITH THE DPA

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you are not satisfied with our response or think we are processing your personal information not in accordance with the law.

FURTHER INFORMATION AS IT RELATES TO GENERAL DATA PROTECTION REGULATION (GDPR)

Users who wish to request further information about our compliance with these requirements, or have questions or concerns about our privacy practices and policies as they relate to EUROPEAN ECONOMIC AREA (EEA) residents may contact us at privacy@sentaifilmworks.com or write to us at 10114 W. Sam Houston Parkway South, Suite 100, Houston, Texas 77099-5109