Cinedigm Kids Privacy Policy

September 16th, 2011 — 7:57pm

Cinedigm respects your right to privacy and we are committed to protecting it and your Personally Identifiable Information during our day-to-day operations. This Kids Privacy Policy details certain policies implemented on portions of the Site where Kids may submit Personally Identifiable Information to us. This Kids Privacy Policy is incorporated by reference into the general Cinedigm Privacy Policy available at http://cinedigm.com/corporate-info/privacy-policy/. Please refer to that policy as a supplement to this policy, which only contains details specific to information submitted by Kids.

Also, we encourage you to be informed about privacy laws applicable to Kids. Information regarding the Children’s Online Privacy Protection Act (“COPPA”) is available here: http://business.ftc.gov/privacy-and-security/children%E2%80%99s-online-privacy.

Privacy Officer and Site Operator
Collection of children’s information through the Site is operated by the Cinedigm Privacy Officer. Our Privacy Officer may be reached at privacy@cinedigm.com, 818-587-5424, Cinedigm Entertainment Group, 21051 Warner Center Lane, Suite 250, Woodland Hills, CA 91367.

Information We Collect From Kids and How We Collect It
Throughout most of the Site, we do not collect Personally Identifiable Information from Kids. However, some specific portions of the Site deliver Services attractive to Kids and on those portions of the Site we will sometimes collect Personally Identifiable Information from Kids. We may collect a date of birth, email address, zip code, full name, and/or username and password from a Kid. We may also collect information regarding a Kid’s interests, such as what types of movies a Kid likes. We collect this information by enabling Kids to submit information directly to us through links maintained on the Site. We may also collect information from Kids who email us directly expressing an interest in Services.

Initially, we only collect Personally Identifiable Information from Kids for the sole purpose of contacting their Parents to obtain consent to collect and use the information. Thus, we may collect Parental contact information, including a full name and email address, from a Kid. Our policy regarding obtaining Parental consent is described below.

Like most web sites, our web servers do collect some information about Kids’ visits that does not necessarily identify the Kids personally. This information may include the URL, IP address, browser type and language, and the date and time of a Kid’s visit. Like most web sites, we may use cookies, web log files, IP addresses, or web beacons in order to recognize a Kid as a registered user, improve overall Site experience, tailor and customize Services, or track Site usage. This data may be exchanged between a Kid’s computer, our Site, and the systems of third parties who assist us in the operation and delivery of the Site. We do not share the linkage between this data and a Kid’s Personally Identifiable Information with third parties except as described herein and/or authorized by you.

How We Use Kids’ Information
We use Kids’ Personally Identifiable Information internally to register Kids to use our Site and Services, to verify Kids’ authority to use certain features of our Site and Services, to improve and tailor the content and general administration of our Site and Services, and, based upon selected preference settings, to deliver certain content, information, services and notices from Cinedigm, which sometimes includes information regarding events, content, products and services provided by third parties in the children’s or family entertainment business.

We do not share Kids’ Personally Identifiable Information with third parties unless: (a) the third parties assist us in the operation and delivery of the Site; (b) the third parties assist us in completing transactions; (c) we are required to do so by law; (d) it is necessary to protect the rights, property, or safety of customers, our employees, or third parties; or (e) we need to enforce this Privacy Policy or our Terms of Use.

Parental Consent Policy
Other than as discussed below, upon obtaining actual knowledge that a Kid submitted Personally Identifiable Information to Cinedigm, we will delete such information expeditiously, unless retention is necessary: (i) for protecting the security or integrity of the Site; (ii) to take precautions against liability; (iii) to respond to judicial process; or (iv) to provide information to law enforcement agencies or for an investigation on a matter related to public safety.

If a Kid submits Personally Identifiable Information to us through a portion of the Site where we intend to collect Personally Identifiable Information from Kids, we will email a Parent to notify the Parent of the Parent’s rights and request consent for the collection of the information. Unless we receive within two business days a response to the email confirming that the Parent consents to our collection of the Kid’s information for our specified purposes, we will delete the information. If we receive a response to the initial email, we will send a follow-up email the next day to confirm consent.

Although we do not currently share Personally Identifiable Information regarding Kids with third parties other than as described above and consistent with law, if we do so in the future, we will email a Parent to notify the Parent of the Parent’s rights and request consent for the sharing of the information. We will ask the Parent to download a consent form from the Site and return the completed form to us by fax or call us and respond to questions designed to verify provision of Parental consent. If we do not verify Parental consent through one of these methods, we will delete the information, unless we have already received consent from the Parent to the collection of the information for Cinedigm’s internal use.

Consistent with law, we will not condition participation in the Site or Services on the provision of Parental consent for information sharing or on the provision of certain pieces of Personally Identifiable Information unless such consent or provision is reasonably necessary to the performance of specific Services.

Correcting/Updating Kids’ Information
Consistent with law, Cinedigm provides you with the ability to review, correct and/or delete any of the Personally Identifiable Information that your Kid has provided to us. If you have questions about this Kids’ Privacy Policy or wish to review or correct any information you have provided to us, you may do so by contacting our Privacy Officer. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making changes or modifications. Unfortunately, we cannot always ensure that such changes or modifications will be reflected in all iterations of your information as previously stored.

Kids’ Privacy Policy Updates
As our business grows and changes, we expect to revise or enhance this Kids’ Privacy Policy through amendments from time-to-time. We will post a current version of our Kids’ Privacy Policy on our Site and will communicate material changes to our Privacy Policy to you by, among other things, posting a notice on our Site for ten days before the changes take effect. However, we will not deem applicable to you any future changes made that would enable sharing of Kids’ Personally Identifiable Information or communicating with Kids without acquiring verified parental consent.

Definitions
“Cinedigm” refers to Cinedigm Digital Cinema Corp., a Delaware corporation. “Cinedigm” and the Cinedigm logo are registered trademarks of Cinedigm Digital Cinema Corp.

“Including” or “including” mean including without limitation.

“Kid” means a child under the age of 13.

“Parent” includes a Parent or legal guardian.

“Personally Identifiable Information” includes your name, home address, telephone number, email address, birth date, or other information which by its nature can be used to identify or contact you or your Kid, as well as information about your visit that does not necessarily identify you or your Kid personally (such as a URL, IP address, browser type and language, or the date and time of your visit) if such information is stored in a manner that links the information to information which by its nature can be used to identify or contact you or your Kid.

“Privacy Officer” refers to the Cinedigm employee responsible for dealing with privacy issue and who may be contacted at privacy@cinedigm.com, 818-587-5424, Cinedigm Entertainment Group, 21051 Warner Center Lane, Suite 250, Woodland Hills, CA 91367.

“Site and Services” refer to the content, features, and functionality (“Services”) made available to users at the Internet website located at the URL Cinedigm.com and its accompanying pages, as well a via email communications, mobile applications and other media now existing or hereafter devised (“Site”).

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