Cohen Media Group/Cohen Film Collection LLC
Effective Date: April 22, 2021
Your Safety and the Security of Your Personal 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.
Social Networking Services and Information From Third Parties
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.
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 email@example.com to request deletion of that information.
International Transfers of 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 firstname.lastname@example.org. Users in certain jurisdictions may have additional rights, as outlined below.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
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 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).
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 email@example.com.
For more information about the GDPR, please contact your local data protection authority in the EEA.
Your California Privacy Rights
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.
Category of Personal Information Collected
Sources of Collected Personal Information
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, credit card information, or other similar identifiers
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e))
Characteristics of protected classifications under California or federal law
Commercial information including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Internet or other electronic network activity information including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement
Audio, electronic, visual, thermal, olfactory, or similar information
Professional or employment-related information
Education information (as defined in 20 U.S.C. section 1232g, 43 C.F.R. Part 99)
Inferences drawn from any of the of the information above to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
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:
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.
Cohen Media Group
750 Lexington Ave, 5th Floor
New York, NY 10022
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.