Privacy Policy

Cohen Media Group/Cohen Film Collection LLC
Privacy Policy and Notice of Information Practices for www.cohenmedia.net and www.cohenfilmcollection.net 

Effective Date: April 22, 2021

Welcome. You have arrived at a site operated by the Cohen Media Group, LLC and/or Cohen Film Collection LLC (“we,” “us” or “our”). We respect the privacy of visitors to our websites and online services and value the confidence of our partners and employees. This Privacy Policy and Notice of Information Practices (“Privacy Policy”) sets forth our practices regarding the collection, use and disclosure of information that you may provide through www.cohenmedia.net, www.cohenfilmcollection.net and any other website(s) that we operate, their subdomains, and all portals, applications, products, services, events and any interactive features, applications or other services that link to this Privacy Policy (“Website” or “Site”), as well as Personal Information provided to us by any means. Additional privacy disclosures may be made at the time of collection of the information. Please read the entire Privacy Policy before using our Website or our services. By using the Website, you agree to abide by the terms of this Privacy Policy. This Privacy Policy is also part of our Terms and Conditions, which govern your use of the Website.

Your Safety and the Security of Your Personal Information

As with all information on the internet, we urge our users to proceed with caution to maintain their digital privacy. Our priority is your safety and security online. We only use the information you provide to us to provide you with the services we offer as stated in this Privacy Policy, and we will not ask you for information that is not required for our services. Please do not send us personal information that we have not requested from you. While we maintain a variety of security procedures to help protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information you provide through the Website, no data transmission over the Internet or stored on a server can be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction or inadvertent disclosure of your information. Please see our Terms and Conditions for additional information. 

Information We Collect

We may ask you for some or all of the following types of information when you access various content or features of the Website or submit inquiries, or directly contact us:

• Your first and last name, email address, mailing or billing address, telephone numbers, credit or debit card number or other electronic payment information, and your payment or service history; 
• Certain online identifiers, such as your username and password if you create an account with us;
• Information from your social media and payment processor accounts, if you use them to interact with our Sites or our services, including but not limited to your username and social media handles, gender, location or other identifying information such as “likes” or “follows”;
• Your language preference; 
• Your location information; 
• Your search queries and the purchases you have made or items you have placed into your shopping cart; 
• Search queries;
• The contents of your message to us in any “Contact Us” form, email communication, or telephone call or other information that you send to us; and
• Other information that could reasonably be used to identify you personally or identify your household or device.

Your decision to provide us with the information above is voluntary, but if you choose not to provide requested information you may not be able to take advantage of all of the features of the Website. 

Like many businesses, we and/or our service providers also may collect and/or store certain information automatically when you visit the Website (“Usage Information”).  This information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site.  Usage information may include:

• Your IP address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;
• Other unique identifiers, including mobile device identification numbers (e.g., MAC address, IDFA, Android/Google Advertising ID, IMEI or other unique identifier);
• Your Device characteristics and functionality (including browser, browser language, operating system, hardware, mobile network information); 
• Sites you visited before and after visiting the Sites;
• Pages you view and links you click on within the Sites, including remembering you and your preferences;
• Your device location and/or other geolocation information, including the zip code, state, or country from which you accessed the Sites; 
• Information collected through cookies, web beacons and other technologies;
• Information about your interactions with email messages, such as the links clicked on and whether the messages were received, opened, or forwarded; and
• Standard Server Log Information.

Our Use of Cookies

We may use cookies, pixel tags and similar technologies to automatically collect the information above.  Cookies are small bits of information that are stored by your computer’s web browser. Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. By using the Website, you consent to our use of cookies and similar technologies. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies, you may not be able to use certain online products, services or features on the Website. As an example, we use cookies to keep track of your shopping cart when you visit our online store, and help identify you when you return to the Store. These cookies are restricted for use only on our Sites, and do not transfer any personal information to any other party. Most browsers are initially set up to accept cookies; however, you can reset your browser to refuse all cookies or indicate when a cookie is being sent. (Note: you will need to consult the help area of your browser application for instructions.) If you choose to disable your cookies setting or refuse to accept a cookie, some parts of our web sites will not function properly or may be considerably slower. For example, without cookies, you will not be able to set personalized preferences or you may have difficulty completing shopping transactions, entering contests, or playing games.

Social Networking Services and Information From Third Parties 

We also may collect and use information provided by third parties, such as social media networks or service providers. For example, you can use third-party social networking services, including but not limited to Facebook, Twitter, and others to share information about your experience on our Website with your friends and followers on those social networking services. These social networking services may be able to collect information about you, including your activity on our Website. These third-party social networking services also may notify your friends, both on our Website and on the social networking services themselves, that you are a user of our Website or about your use of our Website, in accordance with applicable law and their own privacy policies. If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services. Please note that this Privacy Policy applies to our Sites only and third-party or social networking services may have their own privacy policies and terms and conditions that govern their use of your information.

How We Use Your Information

We may use information that we collect for a variety of purposes, including to:

• Operate and improve our Website, products, information, and services;
• Perform our contractual obligations with you and with others;
• Understand you and your preferences to enhance your experience and enjoyment using our Website, products, and services;
• Customize your experience on the Sites; 
• Respond to your comments and questions;
• Provide and deliver products, information, or services you request;
• Send you information, including emails, newsletters, confirmations, invoices, technical notices, updates, security alerts and support and administrative messages;
• Communicate with you about upcoming events or promotions, and news about products, information and services offered by us or our affiliates;
• Link or combine with other personal information we get from third parties, to help understand your needs and interests and provide you with better service;
• Help us address problems with and improve our Sites and our products and services; 
• Engage in analysis, research and reports regarding the use of our Sites, products or services;
• Comply with a law, court order, or other judicial or administrative process; 
• Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity; and
• As otherwise described to you at the point of collection or pursuant to your consent.

How We Share Your Information

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.

• Corporate Parents, Subsidiaries, Partners and Affiliates. As applicable, we may share your information with our affiliated entities for a variety of purposes, including research, business, operational, and marketing purposes.
• Service Providers. We may share your information with service providers that perform certain functions or services on our behalf (such as hosting our website, managing our databases, processing our data, sending out communications on our behalf, processing our payments, or performing analyses of our Site and services).
• Other Parties When Required by Law or as Necessary to Protect the Website. We may disclose your information to third parties in order to: protect the legal rights, safety and security of us, our affiliates and the users of our Website; enforce our Terms and Conditions; prevent fraud (or for risk management purposes); and comply with or respond to law enforcement or legal process or a request for cooperation by a government entity, whether or not legally required.
• In Connection with a Transfer of Assets. If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the event of bankruptcy, we may transfer your information to one or more third parties as part of that transaction.
• Other Parties with Your Express or Implied Consent. We may share information about you with third parties when you consent to such sharing (e.g., if you use a link to share information from the Site to social media, or if you ask us to provide your information to a third party).
• Aggregated Information. We may disclose to third parties information that does not describe or identify individual users, such as aggregated website usage data or demographic reports or research results. This information is not considered personal information and may be used for any purpose.
• In addition, we may allow third parties to place and read their own cookies, web beacons and similar technologies to collect information through the Website (such as Google Analytics). For example, our third-party service providers may use these technologies to collect information that helps us with traffic measurement, research, and analytics. Please note that you may need to take additional steps beyond changing your browser settings to refuse or disable some of these technologies. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and opt out by downloading the Google Analytics opt out browser add-on. If you choose to refuse, disable, or delete these technologies, some of the functionality of the Website may no longer be available to you. You understand that when you use the Website, these analytics providers may collect information related to your use of the Website.

Links to Other Sites

We are not responsible for the content or practices of third party websites that may be linked to our Sites. Our Sites may also be linked to websites operated by other companies. Visitors to these web sites should refer to each website's respective privacy policies and practices.

Response to “Do Not Track” Signals

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. However, because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals. You can learn more about Do Not Track here. 

Children’s Privacy

We respect the privacy of children, and no part of our Site is targeted to attract anyone under the age of 16. We do not knowingly collect, use, or disclose personal information from children under the age of 16 without prior parental consent. If you believe we have information regarding a child under the age of 16 that you have not authorized, you may contact us at info@cohenmedia.net to request deletion of that information. 

International Transfers of Information 

If you are visiting the Site from a location outside of the United States, your connection will be through and to servers located in the United States. All information you receive from the Site will be created on servers located in the United States, and all information you provide will be maintained on web servers and systems located within the United States. Your information, including your Personal Information, may be transferred to – and maintained on – computers located in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. Your consent to this Privacy Policy, followed by your submission of your information represents your agreement to the collection, storage, processing and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States.

We will take all the steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.

Your Choices Regarding Your Personal Data

Our Site may provide you the opportunity to opt-in to receive communications from us when we collect your personal information.  If you receive emails or other communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive, or by contacting us directly at our contact information below. If you opt out, we may still send you non-promotional emails, such as emails about our ongoing business transactions. We ask that you keep your information updated, and you may request changes or updates to your personal information by sending a request to us at info@cohenmedia.net. Users in certain jurisdictions may have additional rights, as outlined below.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

This section of the Privacy Policy applies solely to visitors, users, and others who reside or are located in the European Economic Area (“EEA”). We adopted this Policy to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this Section.

If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information by contacting us at the contact information below. 
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Information.
• The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information.

Legal Basis for Processing Personal Information Under GDPR

In most instances, we are a controller of Personal Information; however, in some instances we may be a processor of Personal Information received from others. Our legal basis for collecting and using the Personal Information described in this section depends on the Personal Information we collect and the specific context in which we collect it.

We may collect or process your Personal Information because:

• We need to provide a product or a service to you;
• You have given us your consent to do so;
• The processing is in our legitimate interests and it is not overridden by your rights; or
• To comply with the law.

Retention of Information

We will retain your Personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your personal information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

We will also retain Personal information, including Usage Data, for internal analysis purposes. Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit). Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site or we are legally obligated to retain this data for longer periods.

Disclosure of Personal Information

Under certain circumstances, we may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

Legal Requirements

We may disclose your Personal Information in the good faith belief that such action is necessary to:

• To comply with a legal obligation; 
• To protect and defend our rights or property; 
• To prevent or investigate possible wrongdoing in connection with the Site or our services; 
• To protect the personal safety of users of the Site, our services or the public; and/or
• To protect against legal liability.

Exercising Your Rights Under GDPR

If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the details in the Contact Us section below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request.  Please indicate “GDPR Request” in the subject line of your inquiry. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA in order to obtain the information. We will respond to your request within 30 days or let you know if we need additional time. 

Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us at info@cohenmedia.net. 

For more information about the GDPR, please contact your local data protection authority in the EEA. 

Your California Privacy Rights

This Section of the Privacy Policy applies solely to California residents. We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Section.

California residents have the following rights:

• The right to know what personal information is being collected about you;
• The right to know whether your personal information is sold or disclosed and to whom;
• The right to access your personal information;
• The right, in certain circumstances, to delete the information you have provided to us; 
• The right to opt out of the sale of personal information; and
• The right not to be discriminated against, even if you exercise your privacy rights.

Requests for Information or Deletion

California consumers have the right to request, under certain circumstances, that a business that collects personal information about the consumer disclose to the consumer the information listed below for the preceding 12 months:

• The categories of personal information collected about you;
• The categories of sources from which we collected your personal information;
• The categories of personal information that we have sold or disclosed about you for a business purpose;
• The categories of third parties to whom your personal information was disclosed for a business purpose;
• Our business or commercial purpose for collecting or selling your personal information; and
• The specific pieces of personal information we have collected about you.

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

You can also request that we delete your personal information. There may be certain exceptions to our obligation to delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.  

We have disclosed the types of personal information about you during your relationship with us as stated in the Privacy Policy.  In particular, our Site has collected the following categories of Personal Information from California residents within the last twelve (12) months:

Do Not Sell My Personal Information

As a California resident, you also have the right, at any time, to tell us not to sell personal information – this is called the “right to opt-out” of the sale of personal information.  We never sell your personal information to third parties for money; however, certain actions we take to share information with our affiliates and related companies, as well as third parties who perform services for us, may be considered a “sale” under the strict language of the CCPA.  As such, you can request that we do not “sell” your personal information by completing a request under the CCPA as indicated below in the “Exercising Your Rights” section.  We will also honor your request to opt out of any marketing emails or correspondence.  

Right Not to Be Discriminated Against

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, as permitted by the CCPA, we may offer you certain financial incentives for the use of your Personal Information that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Third Party Marketing (Shine the Light Act)

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties.  At this time, we do not currently disclose our customers’ personal information to third parties for their own direct marketing purposes. 

Exercising Your Rights Under the CCPA

You or your authorized agent may make a request to access, correct, delete or opt-out of the sale of your information by contacting us using our Contact Us form or as follows:

• Email Address: info@cohenmedia.net 

Please include “CCPA Request” in the subject line of your request. If you use an authorized agent to submit your CCPA request, we may require proof of the written authorization you have given to the agent. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. We also may require you to confirm your identity and your California residency in order to obtain the information, and you are only entitled to make this request twice in a 12-month period. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

Changes in Privacy Policy

This Privacy Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display an effective date on this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any material change to this Privacy Policy regarding use or disclosure of personal information, we will provide advance notice through the Website. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice. If you are concerned about how your personal information is used, please visit our Site often for this and other important announcements and updates. 

Contact Us

If you have any questions about this Privacy Policy, please contact us at:

Privacy Officer

Cohen Media Group
750 Lexington Ave, 5th Floor
New York, NY 10022
646-380-7929 

Email: info@cohenmedia.net 

Information provided by you via general email inquiries to Cohen Media Group or Cohen Film Collection, such as your email address, will be used only to respond to your inquiries in the ordinary course of business, and is never shared with third parties.