VANITASPRODUCTIONS.COM PRIVACY POLICY

Effective Date: December 1, 2020

This Privacy Policy (“Privacy Policy”) is incorporated into Vanitas Productions LLC’s (“us,” “we,” “our,” or “Vanitas Productions”) terms of use (“Terms of Use”) and applies to the use of any online service that includes a link to this Privacy Policy, including, without limitation www.vanitasproductions.com, and all features, content, and other services that we own, control, and make available through online services that include a link to this Privacy Policy (individually and collectively, the “Site”), whether by accessing the Site via a personal computer, a wireless or mobile device, and/or any other technology or device now known or may hereafter exist (each, a “Device”).

This Privacy Policy applies to all users of the Site (“User”, “you” or “your”), regardless of the Device used to access the Site. This Privacy Policy explains how we collect, use, and share personal information through your use of the Site, including any information you provide while you register for and/or browse the Site. This Privacy Policy does not apply to information that is collected outside of the Site.

By visiting the Site or otherwise using the Site, you agree to the terms of this Privacy Policy, as well as our Terms of Use. If you disagree with the terms of this Privacy Policy, please do not use the Site. We may modify this Privacy Policy from time to time, and at any time, without notice to you, for any reason, in our sole discretion. We may notify you of material changes to the Privacy Policy by updating the Effective Date above, by e-mail, or by notification upon login; the form of such notice is at our discretion. Once we post modifications of the Privacy Policy on the Site, these changes become effective immediately and if you use the Site after they become effective it will signify your agreement to be bound by the modifications. We encourage you to review the Privacy Policy whenever you use our Site to stay informed about our information practices and the choices available to you.

INFORMATION WE COLLECT

Information you provide to us

We collect information that you submit to us. For example, the process of subscribing to updates regarding screenings, content, and/or exclusive offers on the Site requires you to provide us with an e-mail address. We will collect any information you voluntarily provide, and we may also request optional information to support your use of the Site. Additionally, if you send an e-mail to us, we will collect your e-mail address and the full content of any e-mail you send to us, including attached files and other information provided therein.

Information we collect automatically from your Device(s)

When you use our Site, we may collect information about the Device you use to access the Site, including hardware model, operating system and version, Internet Protocol (“IP”) addresses and other unique device identifiers, mobile network information, and information about the device’s interaction with our Site. We also may collect information about how you use the Site, including your access times, browser types, and language. We may use this data alone or in aggregate form, as a statistical measure, but not in a manner that is intended to identify you personally. This type of data enables us to understand how often individuals use parts of the Site so we can analyze and improve them. To collect this information, we use cookies and web beacons, and may in the future use other similar technologies.

For example, we use Google Analytics, Intercom, and other similar third party services, to collect statistical information about how the Site is used and accessed. These services use information such as your IP address, browser type, and unique identifiers stored in cookies on your device to record how you interact with the Site. These third party services help us to know how many users we have, which parts of the Site are most popular, what browsers are used (so we can maximize compatibility), the country or region where our users are located, and the demographics and interests of our users. This enables us to better understand who is using the Site and to improve and tailor the Site accordingly.

Most common web browsers today, such as Firefox and Internet Explorer, allow you to modify your settings to block cookies entirely, alert you every time they are being sent, or allow their use by only those websites you choose. You can also delete cookies that are currently stored on your computer’s hard drive. If you choose to disable cookies, certain features on our website may not be available or work properly. Through the use of web logs or log files, we may also gather information such as the date, time, browser type, navigation history, and IP address of all visitors to our website(s). We use this information for our internal security audit log, trend analysis, and system administration, and to gather broad demographic information about our user base. We may associate this information with your personal information. By visiting our Site, you affirmatively consent to our collection, use, and distribution of your data.

Location information

We may collect different types of information about your location, including general information, such as the city, state, and/or zip code associated with your IP address used to access the Site. We may use such location information to customize the Site. For example, if you provide a zip code that indicates that you live in New York, the Site may be customized with New York-specific information and/or features. In order to do this, your location information may be passed along to our affiliates, agents, and/or vendors. Options you have to control the automatic collection of location information are explained below under “WHAT ARE MY CHOICES?”.

Information from Social Media Networks and other third parties

We may obtain information about you or your use of the Site from third parties and sources, such as our vendors, like web host providers and/or analytics providers. You may also give us permission to access your information, including personally identifiable information from services offered by third parties, including social media networks. The information we obtain from third party services depends on your account’s privacy settings with those third parties and the third parties’ privacy policies, so be sure to read those policies and to adjust your settings to meet your privacy preferences. When you access the Site through social media networks and other third party platforms, you are authorizing us to collect, store, and use such information and content in accordance with this Privacy Policy. If we combine or associate information from other sources with personal information that we collect through the Site, we will treat the combined information as personal information in accordance with this Privacy Policy. Please keep in mind that any information provided to us by a third party may also be subject to that third party’s privacy policy.

Payment information

We use a third party payment processor, Stripe, to process payments made to us. In connection with the processing of such payments, we do not retain any personally identifiable information or any financial information such as credit card numbers. Rather, all such information is provided directly to our third party processor, Stripe, whose use of your personal information is governed by their privacy policy, which may be viewed at Stripe Privacy Policy. Stripe is certified to PCI Service Provider Level 1, the most stringent level of certification.

Aggregated and/or de-identified information

We may aggregate or de-identify certain information that we collect from you. Aggregated and/or de-identified information is designed so that we cannot identify you personally.

Sweepstakes, Contests, and/or Promotions

We may offer sweepstakes, contests, surveys, and other promotions (each, a “Promotion”) jointly sponsored or offered by third parties that may require submitting personal information. If you voluntarily choose to enter a Promotion, your personal information may be disclosed to third parties for administrative purposes and as required by law (e.g., on a winners list). By entering, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice, and/or likeness in advertising or marketing materials.

HOW WE USE YOUR INFORMATION

In general, the information that you submit or share with us and that we collect is used in the following ways:

For the purposes for which you provided such information;

To enable your access to the Site;

To provide, maintain, protect, develop, and improve the Site, including through the use of statistical analysis;

To customize the content you receive from us and our trusted partners;

To communicate with you including via e-mail, text messages, social media; and

To offer you additional information, opportunities, promotions, and functionality from us or on our behalf, or from our partners.

We may use aggregated and/or de-identified data or other data that is not personally identifiable for any purpose, including without limitation in statistical analysis, to help us analyze patterns in the use of the Site.

By accessing and using the Site, you consent to our use of your information about you in the manner described in this Privacy Policy. If you do not agree or do not consent to the use of your information in these ways, you should not use the Site.

WHEN WE DISCLOSE YOUR INFORMATION

We do not disclose your information except in the limited circumstances described below. By accessing and using the Site, you consent to us sharing your information under the circumstances described in this Privacy Policy.

With your consent

We may share or disclose your information if you ask or authorize us to do so.

To third party service providers

We engage third party services to perform a variety of services and functions for us. We may share your information with such third party services subject to confidentiality obligations consistent with this Privacy Policy and on the condition that the third party services use your information only on our behalf and pursuant to our instructions and applicable law.

Information shared via third party social buttons, widgets, and/or other embedded content

Some portions of our Site carry embedded content controlled by third parties for services such as social sharing, commenting, and displaying video and images. When you interact with these services they may collect information from and about you and your interaction with their content, including the URL of the web page you are visiting. This activity will be subject to the privacy policy of, and your settings for, the third party network or service. Please be aware that they may track your activity, including through the use of cookies or similar technology, without you needing to interact with them. If this concerns you, ensure you log out of their services before using ours.

To comply with legal requirements and to protect you, us, and others

Notwithstanding anything to the contrary in this Privacy Policy, we reserve the right to retain and disclose your information at our discretion if we believe in good faith that such retention and disclosure is necessary to: (a) comply with relevant laws or to respond to subpoenas, warrants, or similar process served on us; (b) protect and defend our rights or property, you, or third parties; or (c) ensure the safety and security of our Site, systems, and of our customers and third parties.

In connection with a business transfer

In the event we go through a business transition such as a merger, acquisition by another company, bankruptcy, reorganization, or sale of all or a portion of our assets, your information may be sold or transferred as part of that transaction. You acknowledge that such transfers may occur and are permitted by this Privacy Policy and that the new entity may continue to process your information as set forth in this Privacy Policy.

If the information has been aggregated, de-identified, or otherwise does not identify you personally

We may share or disclose information that has been aggregated, de-identified, otherwise does not identify you, or information that you choose to make public. For example, we may develop information concerning the Site’s users, using de-identification processes to help ensure that such information cannot reasonably be re-associated or connected with you as an individual. This Privacy Policy does not limit our use or disclosure of de-identified information (i.e., information from which your name and any other personally identifying information has been removed) in any way, and we reserve the right to use and disclose such information to our partners and any other third parties at our discretion in accordance with applicable law. If you do not agree or do not consent to the disclosure of your information in this manner, you should not use the Site.

WHAT ARE MY CHOICES?

You may choose to block cookies on our site. To find out more about our use of cookies, see “INFORMATION WE COLLECT” above .

You have a right at any time to stop us from contacting you, or from sharing your information with third parties, for marketing purposes. When you receive promotional communications from us or from third parties, you may indicate a preference to stop receiving further promotional communications and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the promotional e-mail you receive or by contacting us. Despite your indicated e-mail marketing preferences, we may still send you relationship and/or transactional e-mails regarding the Site, including, for example, administrative confirmations and notices of updates to our Terms of Use and this Privacy Policy.

If you access the Site through a mobile device and you do not want your device to provide us with location-tracking information, do not agree to allow your device to share this information with us or disable the location-tracking functions on your device, provided your device allows you to do this. Your device manufacturer should provide instructions on how to disable location-tracking functions. If you initially consent to the collection of location information, you can subsequently stop our collection of location information at any time by changing the preferences on your mobile device or uninstalling the application from your mobile device by following your device’s uninstall process.

California residents may have additional rights. To learn more, see “YOUR CALIFORNIA LAW RIGHTS” below.

HOW LONG WE KEEP YOUR INFORMATION

We will hold your personal information on our systems for as long as necessary to provide any and all features, content, or other services through the Site which are relevant to you, for so as long as reasonably required to satisfy the purpose for which you submitted the information, or as long as required by applicable law.

LINKS TO THIRD PARTY WEBSITES

Links to third party websites may be made available through the Site. Clicking on such links will direct you to the website or application of a third party. We are not responsible for the privacy practices or the content of such websites. Any information you provide via those sites is subject to the privacy policies on those websites and is not covered by this Privacy Policy. We encourage you to read the privacy statements of each and every website you visit or application you use. This Privacy Policy applies solely to information collected by us through the Site and does not apply to third party websites or applications. The ability to access third party information from the Site and to link to other websites and locations from the Site is for your convenience and does not signify our endorsement of such third parties, their products, their services, their websites and locations, or the content they make available on the Site or on their websites and locations.

HOW YOUR INFORMATION IS PROTECTED

We are committed to protecting the security of your information. We use a variety of industry-standard security technologies and procedures to help protect your information from unauthorized access, use, and/or disclosure. These measures vary based on the sensitivity of the information that we collect. Even though we have taken significant steps to protect your information, no company, including us, can fully eliminate security risks associated with information. We cannot guarantee that our security measures will prevent every unauthorized attempt to access, use, or disclose your information.

HOW TO CORRECT YOUR INFORMATION

You have the right to request a copy of the information that we hold about you that identifies you personally. If you would like a copy of some or all of this information, please contact us. We may charge a reasonable fee for this service. We want to make sure that your information is accurate and up-to-date. You may ask us to correct or to remove information that you think is inaccurate. We also provide you with tools and account settings to access or modify some of the information you provided to us and associated with your account.

OUR POLICY REGARDING CHILDREN

Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our website from those we actually know are under eighteen (18), and no part of our website is structured to attract anyone under eighteen (18).

YOUR CALIFORNIA LAW RIGHTS

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their “personal information” (as defined under the California Online Privacy Protection Act (“CCPA”)), if any, for their direct marketing purposes in the prior calendar year, as well as the type of “personal information” disclosed to those parties.

If you are a California resident under the age of eighteen (18) and you contact us to have your information removed, please provide us with detail regarding the content or other information you have posted and attest to us that you have posted it. We will then make reasonable, good faith efforts to remove the content from public view prospectively, or to anonymize it so you cannot be individually identified, to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.

We may share personal information, as defined by the CCPA, with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with the CCPA, please contact us.

GOVERNING LAW

This Privacy Policy and all disputes arising hereunder or relating hereto shall be governed by, and will be construed under, the laws of the state of New York, without regard to choice of law principles. Those who choose to access the Site from locations outside the United States do so on their own initiative and are responsible for compliance with local laws if and to the extent local laws are applicable. We may limit the website’s availability, in whole or in part, concerning any person, geographic area or jurisdiction, at any time in its sole discretion.

INFORMATION STORAGE AND PROCESSING

For certain aspects of our Site, we use Amazon Web Services (AWS) who provide us with cloud storage solution. AWS has demonstrated compliance with a range of internationally recognized standards for content, data and infrastructure security, such as information security management system- ISO-27001, System and Organization Controls Report- SOC1/2, and The Payment Card Industry Data Security Standard; in addition, AWS has demonstrated alignment with the MPAA Content Security Best Practices and the AWS infrastructure is compliant with all applicable MPAA controls. For more information on AWS’ privacy policy please see: AWS privacy policy.

CONTACT INFORMATION

If you have questions or concerns about our Privacy Policy, please contact us.