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Privacy Policy.  Updated August 24, 2021.  Posted online at:  https://rodado.media/privacy

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This Privacy Policy describes the information we collect when you use the Rodado website and apps. It is an agreement between you and Rodado, Inc.. By using our apps and website, and viewing the content accessible through our services, such as the Luka app, you expressly consent to our information handling practices as described in this privacy policy. If you do not agree to any of the terms described below, please cease using our apps and website.

 

Our apps and website are controlled and offered from the United States of America and, regardless of your place of residence or access location, your use of them is governed by the law of the State of California, USA. Rodado, Inc. makes no representations that the apps or website are appropriate for use in other locations or are legal in all jurisdictions. Those who access or use our apps or website from other locations do so at their own risk and consent to the transfer and processing of their data in the United States of America.

 

1.         Information We Collect

 

When you visit our website, we collect certain data by automated means, including:

  • Account Data: You do not have to create an account to view content through our apps.  However, if you create an account, you will log in or register using Google login. This ‘single sign-on’ feature allows us to conveniently create an account for you and allows you to log in using familiar credentials. Through this process, we may collect your name, email, and any other information provided to us by Google as the single sign-on partner. We will not collect your Google account password, so if you forget your password, you would have to retrieve it via your Google account.

  • Children under 13: our apps and service are generally intended for an audience over the age of 13 years old. However, a limited number of channels feature children programming. We do not allow children under 13 years old to create an account or provide personally identifiable information (as defined in the Children’s Online Privacy Protection Act (“COPPA”). If you are a child under the age of 13, please ask your parent to create the account to enable you to view and subscribe to children programming channels.

  • System Data: Technical data about your computer or device (including your connected TV), like your IP address, device make, model and type (such as TV brand and model), operating system type and version, data connection type, screen resolution, unique device identifiers (including, in the case of our connected TV apps, your device’s unique advertising ID, device ID, or similar, identifier), browser, browser language and time zone settings, internet provider, network information, or ISP carrier name.

  • Usage Data: Usage statistics about your interactions with our website or TV app, including the last webpage or app you visited/used before visiting our website or launching our app (referrer information), the website pages visited, the features of the app used, the content viewed, the ratings you leave regarding the content you viewed, the time spent on each page or feature, the date and time of your visit or app use, and the features and resources you accessed or used (for example, if you signed up to receive additional information about our products and services). For example, we track what channels and specific content individual users view, watch lists they create, how long a user watches specific channels and content, and other information and metrics relating to users’ viewing history. This usage data is linked to your account registration data.

  • Geographic Data: Geographic location, including information like country, city, and geographic coordinates, determined based on your IP address or GPS location of your device. If you are using a mobile device, your mobile device’s geographic location (specific geographic location if you have enabled collection of that information, or general geographic location automatically).

  • Customer Support Data: If you contact us through our apps or website for help or any other question, we may collect your email address, and any other information you provide in the contact form. We will use your contact and other information you choose to provide only in the context of your inquiry or request.

  • Newsletter Subscription: If you choose to subscribe to our email newsletter, or provide us your email address to receive additional information about our products and services, you will receive periodic promotional messages from us.  We will be tracking whether you open, read, or delete our email messages, or take any action suggested or promoted in our email messages.

  • Customer Rewards. We may offer rewards or other incentive programs for our registered users. These programs may allow you to earn rewards in exchange for certain actions or achievements. We may track and link to your user profile the information provided in the course of these programs, and may use this information to tailor content to your preferences.

 

2.         Our Use of Your Information

 

We collect this data for the following purposes:

Administrative and Technical Purposes

  • To administer your account, your subscriptions, and deliver our services to you.

  • To recognize your browser/device when you visit our site and use our apps, so we understand you are the same visitor or household, so we can provide a consistent experience across your multiple devices.

  • To provide content and services on our website and in our app, and improve them. We analyze information about how many visitors we have, how our visitors use our website and apps and what content, resources, and features they access and use, to improve your experience with our products and services.

  • To advertise and promote our products and services on third-party websites and apps and analyze which of our ads and promotional messages are the most effective.

  • To test and analyze the performance of our website and apps, so we can understand any technical problems or issues and fix them.

  • To comply with our legal obligations. We may use visitor information to carry out fraud prevention checks or comply with other legal or regulatory requirements, where this is explicitly required by law.

 

Customized Content and Advertising Purpose

 

  • To provide you with customized content recommendation and content through our apps, including customized advertising based on the content you viewed or subscribe to. We track this information via identifiers (similar to mobile advertising IDs and alike) so that we can determine what content is most interesting and relevant to you and improve our channel recommendations. We may personalize our services to specific groups of users or devices, suggesting content or titles that may be of interest, organize the viewer guide to show the most relevant channels/titles and customize notifications. We may also use your usage and activity information to deliver to you more relevant advertisements and commercial content. In analyzing data we collect about you, we or our advertising partners may draw inferences about you including about your lifestyle, personal preferences, financial situation or any other indicator used in programmatic ad targeting.

  • We use the following tracking technologies to provide customized content and advertising to you:

    • Cookies. Cookies are small-size data files containing a string of alphanumeric characters that usually include a unique identifier, and are placed on your device. Cookies are usually stored on your device for a specific period of time (persistent cookies). Our advertising partners may use cookies in order to collect information and statistically analyze advertisement preferences.

    • HTML5 and Locally Stored Objects. “Locally stored objects” are pieces of code that typically contain a greater amount and different types of data than browser cookies. These are also used to collect and track information and statistically analyze advertisement preferences.

    • Tags and Pixels. Tags and Pixels are blocks of code that we and our advertising partners may use to track your browsing on the Internet. They are usually placed on a page or otherwise, Internet resource or sent within an e-mail to monitor the behavior of the user visiting the resource or sending the e-mail. It is often used in combination with cookies.

    • Device Identifiers. Device Identifiers or Mobile Device IDs are unique identifiers which can be used to identify a mobile device. We may use standard device identifiers, to track your use of mobile applications and to determine if a piece of advertisement inventory has been delivered to a specific user or retargeted, or to determine the frequency of certain inventory for a certain user. Ultimately, passing device’s ID back to advertisers helps our ad partners to improve the quality of advertising and its efficiency.

    • Software Development Kits. These are blocks of code or algorithm similar to Tags and Pixels that are embedded into a digital resource that allows us to track certain information related to your use of our apps and your activities on our apps.

 

 

Data Retention

 

We retain the information we collect about and from you for as long as necessary to fulfill the purpose we collected it for and for the purpose of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information we process, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, accounting, or reporting requirements.

 

3.         With Whom We Share Your Information

 

We require all third parties to respect your privacy and to treat your information in accordance with the law.

 

Third Party Advertising Partners.  We, and certain third parties operating on or through our apps and website, may engage in online behavioral advertising. This form of advertising includes various parties and service providers that will engage in the processing of personal information about you that we collect, or that is provided by third parties, including information about the content you view or preferences inferred through your use of our apps. This information is analyzed by advertising companies to provide you with more relevant or personalized advertising. The parties that control the processing of personal information for behavioral advertising purposes may build a profile of you containing this information, and may be able to identify you across sites, devices, and over time. These services may also track whether you view, interact with, or how often you have seen an ad, or whether you complete a purchase for goods or services you were shown in an advertisement. In some cases, these parties may also develop and assess aspects of a profile about you to determine whether you are a type of person a company wants to advertise to, and determine whether and how ads you see are effective, and may add such information to your profile. For information on how to opt out of such behaviorally targeted advertising, see Your privacy Rights and Choices below.

Platform Partners. If you have installed and/or use one of our apps, our platform partners (such as Android/Google Play) may collect / receive information about you including your status as a subscriber, the content you view, the version of your app, your device settings, IP address, and other information about your device and app usage.

Social Media Services. If you use any social media plugin, “like” or “share” features of Facebook or Twitter, or other similar features, such activity may be made available to the social media platform. Information collected by these platforms are governed by their respective privacy policies. We may share, rebroadcast, or redisplay that information or other information derived from your social media interactions to the extent permitted by the terms of use governing the relevant social media services.

 

Device Manufacturer. You device manufacturer may also collect data about your interactions with our apps. Please see your device manufacturer’s privacy policy for more information.

Service Providers

  • We use cloud-based data hosting providers to host our website and to also host the user data we collect and store.

  • We may use a third party email service providers to facilitate sending email messages to our subscribers. When you interact with an email message that you receive from us, such third party service providers may collect information about your device and whether you opened, read, deleted the email, or took any action promoted by the email. They use cookies and other tracking technologies to collect some of this information.

  • We use Google Analytics to help analyze how visitors use our website and our apps. Google Analytics collects the IP address assigned to you when you visit the site. They also place a persistent cookie on your web browser to identify you as a unique user the next time you visit the site, and recognize you when you visit other sites that use Google Analytics. Google's ability to use and share information collected by Google Analytics about your visits to our site and other sites is governed by the Google Analytics Terms of Use. To see an overview of privacy at Google and how to opt out of certain Google practices, visit Google’s Privacy Policy.

  • We may use a customer relationship management software to keep track of potential consumers interested in purchasing our products and services.

  • We may use customer support software to help us receive and answer your messages asking for help with our products or services.

 

Business Transaction. In the event that we go through a business transition, such as a merger, acquisition, liquidation or sale of all or a portion of our assets, customer data, including Personal Information, will, in most instances, be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.

 

Compliance with Laws.  If requested or required by government authorities, such as law enforcement authorities, courts, or regulators, or otherwise to comply with the law, we may disclose any information we have about our users. We may disclose information collected about you in order to exercise or protect legal rights or defend against legal claims. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

 

Aggregate Data Sharing.  We may also share user activity aggregated data that does directly or indirectly not identify you with our distribution partners, such as TV manufacturers.  

 

4.         Your Privacy Rights and Choices

 

You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain analytics providers.

 

Account Information and Privacy Settings.  You can access and update you account data that we collect and maintain about you via your Google account settings. Through your account settings, you may access, and, in some cases, edit or delete certain information you’ve provided to us, including your name, password, and email address.

 

You may delete your account with Rodado by removing access of your Google account to our app. Please note, following deletion of your account, we may retain information for a reasonable amount of time should you wish to reactivate your account, and we may retain certain information indefinitely if we believe that it is necessary to comply with our legal obligations, resolve disputes, or as otherwise permitted under the law.

Email Preferences. To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by emailing us at support{at}rodado.media.

Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding any service that you subscribe to, including administrative confirmations, order confirmations, important updates about our services, and notices about our policies.

 

In App Ad Preferences. On your device, you may also go to your OS privacy settings and select “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” (for Android devices), “Limit Ad Tracking” (for iOS/tvOS devices), “Limit Ad Tracking” (for Roku devices) or similar setting offered by your OS, which will allow you to limit our use of information collected from or about your mobile device for the purposes of serving online behavioral advertising to you. You should however contact the manufacturer to obtain all relevant information on how to withdraw your consent.

Web Ad Preferences. You can opt-out of third-party advertising-related cookies, pixel tags and web beacons, in which case you will continue to see advertisements on our website, but they will not be tailored to you based on behavioral targeting. You can choose to opt-out through these (and other) sites:

 

Google Analytics.  You can prevent your data from being collected by Google Analytics when you visit our website by downloading the Google Analytics opt-out browser add-on https://tools.google.com/dlpage/gaoptout. Opting-out is generally done by the third party dropping a cookie on your browser indicating your intent to opt-out. If you get a new device, install a new browser, erase, or otherwise alter the third party’s browser cookie file, you may clear the opt-out cookie and no longer be subject to its opt-out.

 

Your Data Access and Deletion Rights. You may request access to the information we have about your account and app usage, or request that we delete from our systems any personal data that we collected about you by contacting us at support{at}rodado.media.  Please allow up to 30 days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before implementing your request.

Please note: even after we delete your information, some or all of your data may still be visible to others, including data you may have shared using any social sharing feature or data remaining with your email service provider. Even after we delete your email from our systems, we may retain certain data where we have a lawful basis to do so, including for mandatory record-keeping and to complete transactions.

 

California Residents.  Under the California Civil Code, California residents have the right to request a list of all third parties to which a company conducting business in California has disclosed Personal Information during the preceding year for direct marketing purposes. Alternatively, the law provides that, if a company has a Privacy Policy that gives either an opt-out (which we may sometimes refer to as "unsubscribe") or opt-in choice for use of your personal information by third parties (such as advertisers or affiliated companies) for marketing purposes, the company may instead provide you with information on how to exercise your disclosure choice options. If you are a California resident and request information about how to exercise your third party disclosure choices you must send a request to the following address with a preference on how our response to your request should be sent (email or postal mail). Contact us at support{at}rodado.media - or you may contact us via regular mail at 451 Kansas St. Unit 528, San Francisco, CA 94107, Attn: California Privacy Rights. All requests sent via regular mail must be labeled "Your California Privacy Rights" on the envelope or postcard and clearly stated on the actual request. For all requests, please include your name, street address, city, state, and zip code (your street address is optional if you wish to receive a response to your request via email. Please include your zip code for our own record keeping).

 

To the extent required by California Law, we permit minors under the age of 18 to request the deletion of any content or information that the minor has posted or made publicly available through our services (if any). To request that information posted on our services by a minor be removed, please send a letter or email to the address referred above with (i) your name, (ii) a complete description of the content you would like removed, and (iii) the web address(es) of the content you would like removed. Please be aware that our fulfillment of this request does not ensure complete or comprehensive removal of the content or information you have posted on our services.

 

Under California Civil Code Section 1789.3, California users are entitled to the following specific consumer rights notice: The Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or

(800) 952-5210.

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5.       Information Security   

 

We take the security of your information seriously and use appropriate technical and organizational measures to protect your information against unauthorized or unlawful processing and against accidental loss, destruction or damage. We also limit access to information about you to employees who reasonably need access to it to provide products or services to you, or in order to do their jobs. However, because no security system can be 100% effective, we cannot completely guarantee the security of any information we may have collected from or about you.

 

6.       Changes and Updates

 

We may occasionally update this privacy policy without further notice to you. When we do, we will also revise the "last updated" date posted at the top of this privacy policy page. Please revisit this page to stay aware of any changes. In general, we only use your personal information in the manner described in this privacy policy in effect when we received that personal information. Your continued use of our website constitutes your agreement to this privacy policy and any future updates.

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7.         Applicable Law

 

Rodado, Inc. operates its website and apps from its offices in the State of California. This privacy policy shall be construed in accordance with, and governed by the laws of the United States and the State of California, without reference to their rules regarding conflicts of law. You hereby irrevocably consent to the exclusive jurisdiction of the state or federal courts in San Francisco, California, USA for all disputes arising out of, or related to, this privacy policy or our use of your data. If, for whatever reason, a court of competent jurisdiction finds any term or condition in this privacy policy to be unenforceable, all other terms and conditions will remain unaffected and in full force and effect.

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8.         How to Contact Us

 

If you have any questions, comments, or concerns about this privacy policy, your personal information, or our third-party disclosure practices, or have any questions about viewing or updating information we have about you, please contact us at support{at}rodado.media.

Rights and Choics
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