Privacy Policy
MSG NETWORKS PRIVACY POLICY
INTRODUCTION
This Privacy Policy (“Policy”) describes the information that MSGN Holdings, L.P. (“MSGN”) and the MSGN Family (as defined below) collects, how we use it, and when and with whom we may disclose it. Except as described in this Policy, the Policy applies to any and all websites, mobile applications, software and any other electronic and/or digital products and/or other services that are made available by the MSGN Family, and our offline services (collectively, the “Services”). This Policy applies regardless of the device used to access the Services.
All services that are governed by this Policy will include a link to, and/or copy of, this Policy on the home page of the applicable website or similar location (e.g., a “settings” page) for any applicable mobile applications. Some services offered by or affiliated with the MSGN Family may be governed by a separate privacy policy, and if this Policy is not posted on the home page for a particular service or entity that is part of the MSGN Family, this Policy does not apply. In those instances, the service-specific privacy policy shall apply to that specific service. Please be advised that this Policy does not cover everything related to our Services. For example, in some instances, you may be providing personal data to third parties. Those third parties’ own privacy policies will apply to the handling of the personal data that they collect.
For purposes of this Policy, the terms “MSGN Family,” “MSGN,” “we,” “us,” and “our” include, without limitation, MSG Networks Inc., MSGN Holdings, L.P. and each of their respective parent companies, subsidiaries, divisions, affiliated entities and business units as may change from time to time (including, without limitation, MSGN Songs, LLC, MSGN Publishing, LLC, MSGN Interactive, LLC, SportsChannel Associates and The 31st Street Company, LLC).
DATA CONTROLLERS
Under applicable law, MSGN Holdings, L.P. is considered the “data controller” of the personal data that the MSGN Family handles under this Policy. In other words, MSG Networks Inc. is responsible for deciding how the entities that are part of the MSGN Family collect, use and disclose this data. MSG Networks Inc.’s contact information appears at the end of this Policy in the Data Controllers Contact Information section.
Before you submit any information on, through, or in connection with the Services, please carefully review this Policy. By submitting any personal data directly to us or using any part of the Services, you understand the manner in which we collect, use, and disclose your information as described in this Policy. We will continue to evaluate this Policy as we update and expand the Services and our offerings, and we may make changes to it. Any changes will be posted here, and you should check this page periodically for updates. Your continued use of the Services will signify your continued understanding of the terms of the updated Policy.
This Policy is split into sections. For your convenience, links to each of those sections follow:
INFORMATION WE COLLECT
HOW WE USE YOUR INFORMATION
WHEN WE DISCLOSE YOUR INFORMATION
OUR LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA
INTERNATIONAL TRANSFER
PERSONALIZED CONTENT AND ADVERTISING AND YOUR CHOICES
YOUR DATA RIGHTS AND CHOICES
NOTICE TO CALIFORNIA RESIDENTS
PRIVACY INFORMATION FOR NEVADA RESIDENTS
LINKS
SECURITY AND RETENTION OF YOUR INFORMATION
INFORMATION FROM CHILDREN
CONTACTING US ABOUT THIS POLICY
CHANGES TO THIS POLICY
DATA CONTROLLER CONTACT INFORMATION
- INFORMATION WE COLLECT
We collect information in multiple ways, including when you provide information directly to us, and when we passively collect information from you, such as information collected from your browser or device.
A. Information You Provide Directly to Us
We may collect information from you during your use of or access to the Services, such as:
- When you register for an account or authenticate through another account provider (e.g., a cable provider) in order for you to access the Services;
- When you make a purchase;
- When you enter a sweepstakes or contest or register for a promotion;
- When you request certain features (e.g., newsletters, updates, and other products);
- When you download or use one of our mobile applications;
- When you communicate with us; or
- When you post User Content, including comments, to or on any of our Services.
The information you provide directly to us may concern you or others and includes, but is not limited to: (i) name; (ii) email address; (iii) age; (iv) mailing address; (v) hobbies; (vi) sports and entertainment interests; (vii) telephone number; (viii) fax number; (ix) viewpoints on certain events; (x) birthdate; and (xi) in certain circumstances, payment and identity verification information, such as (1) credit card number, (2) social security number (or comparable national identifier), (3) driver’s license number when needed for payment in connection with a purchase, and/or (4) record of authentication to access the Services through a third party provider. Payment card information is processed by our third party payment processors. Certain Services may not be accessible or available absent account registration and/or your provision of certain requested information.
Please be careful and responsible whenever you are online. If you choose to post User Content (as described in our Terms of Service through the Services, such as via social networking services, on message boards, chat areas, comments and/or other postings, that information: (i) is publicly available; (ii) may be collected and used by third parties without our knowledge; and (iii) may result in your receipt of unsolicited messages from other individuals or third parties.
B. Information That is Passively and/or Automatically Collected
(i) Device/Usage Information
We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services. As described further below, we may collect and analyze information such as (a) IP addresses, geo-location information, unique device identifiers and other information about your computer or mobile phone or other mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
(ii) Location Information
We also may automatically collect location information, including general location information (e.g., IP address, zip code) from your computer or mobile device. If you access the Services through a mobile device, we may ask you to allow us to access your precise geo-location information so that we can deliver customized content and advertising and confirm compliance with any applicable territorial restrictions. We and our service providers may also collect other information based on your location and your device’s proximity to “beacons” and other similar indoor proximity systems, including, for example, the strength of the signal between the “beacon” and your device and the duration that your device is near the “beacon”. The type of location data we collect depends on a number of factors, including the type of device you are using (e.g., laptop, smartphone, tablet, connected TV) and the type of connection enabled on your device (e.g., Wi-Fi, Bluetooth, broadband, cable, or cellular). The Services rely on this location information, including geo-fencing technology, in order to provide certain location-based services, content, promotional offers and other information that may be of interest to you or that may be available to you based on your subscriptions to Services we provide. We may also use location information to improve the functionality of the Services and our other products and services. If you do not wish to have this location information collected and used by the MSGN Family and its service providers, you may disable the location and Bluetooth features on your device. Please note that, if you disable such features, you will not be able to access or receive some or all of the services, content, features and/or products made available via the Services. To deliver customized content and advertising, we may disclose your location information, including geo-location information, to our agents, vendors, or advertisers.
Depending on the device you are using, we may use third party services to provide mapping services. For example, the MSGN Family may use Google maps on certain devices—you can learn more about the information that Google collects through its mapping services at http://www.google.com/privacy.html.
(iii) Cookies and Other Electronic Technologies
We may also collect data about your use of the Services through the use of web server logs, cookies and/or tracking pixels. A web server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of MSGN Family’s Services you have visited; (iv) enhance your user experience by delivering content specific to your interests; (v) perform searches and analytics; and (vi) assist with security administrative functions. Some cookies are placed in your browser cache, while those associated with Flash technologies are stored with your Adobe Flash Player files. Tracking pixels (sometimes referred to as “web beacons” or “clear GIFs”) are electronic tags with a unique identifier embedded in websites, online ads and/or email, and are designed to provide usage information like ad impressions or clicks, measure popularity of the Services and associated advertising, and access user cookies. We may also use these automated technologies to collect and analyze other information related to the devices you use to access the Services, such as IP addresses, browser types, browser language, operating system used, the domain name of your Internet service provider, unique device identifiers, and other information about your devices used to access the Services. These automated technologies may also collect information on the websites you have visited before and after you visit the Services, and the advertisements you have accessed, seen, forwarded, and/or clicked on when using the Services or other websites. We or third-party technologies we use may place or recognize a unique cookie on your browser to enable you to receive customized content, offers, services or advertisements on our websites or other sites. The cookies may be associated with demographic or other data linked to or derived from data you voluntarily have submitted to us (e.g., your email address), which we may share with vendors to deliver advertisements for our services on our behalf. As we adopt additional technologies, we may also gather additional information through other methods.
Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer, Google Chrome, Mozilla Firefox, or Apple Safari). Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.
We use third parties to assist us in serving advertisements, tracking aggregated and/or anonymized site usage statistics, and providing content-sharing services to support the Services. These third parties may also use cookies and similar technologies to collect similar information about your use of the Services. We do not control these third-party technologies, and their use is governed by those parties’ privacy policies.
C. Information Collected By and From Social Media and Other Content Platforms
If you access the Services through a third-party connection or log-in, such as through a social network, like Facebook or Twitter, you may allow us to have access to certain information in your profile. This may include your name, e-mail address, photo, gender, birthday, location, an ID associated with the applicable third party platform or social networking account, user files like photos and videos, your list of friends, people you follow and/or who follow you, or your posts or “likes.” For example, if you access the Services through Facebook, we may collect the following information about you from Facebook: (i) Facebook ID/User Name; (ii) first and last name; (iii) anything that you have made public in your Facebook profile; (iv) gender; (v) locale; (vi) age range; (vii) profile rank; (viii) your location; (ix) your Facebook “likes”; and (x) your comments. If you permit, we also may collect your birthday and email. If you do not wish to have this information disclosed from Facebook, do not use Facebook Connect to access the Services. We may also collect other information through other social networks that you make available to us. For a description on how social networking sites handle and disclose your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings. We may combine information that we collect from or about you with information about you that we obtain from such social media and other content platforms and information derived from any other subscription, product, or service we provide.
D. Information from Affiliates and Non-Affiliated Third Parties and Partner
We may also obtain information about you from our affiliates including Madison Square Garden Sports Corp.; Madison Square Garden Entertainment Corp. and Sphere Entertainment Co. and each of their respective subsidiaries, divisions, affiliated entities and business units (collectively, the “MSG Family”), as may change from time to time. We also may obtain information about you from third parties such as marketers, partners (including our league and team partners), researchers, sponsors, and others. We may combine information that we collect from you with information about you that we obtain from our affiliates and/or such third parties and information derived from any other subscription, product, or service we provide.
E. Pay TV Account Information
In some instances, other vendors, such as those who provide the necessary functionality to authenticate your account with your cable, satellite, telco or other provider of video programming services (each a “Pay TV Provider”) may collect your account credentials and certain other information, including without limitation billing zip code information, in order to verify your identity and the fact that you have a valid, current and active account with such Pay TV Provider in order to convey that authentication to us and enable us to provide you the Services.
- HOW WE USE YOUR INFORMATION
The MSGN Family may use your information for the following purposes:
- For the purposes for which you provided it;
- To provide the features, services, and products available through the Services;
- To send you information about your relationship or transactions with us;
- To send you alerts or other communications;
- With your consent, to send you SMS messages;
- To notify you about new features and offerings of the Services, including, but not limited to, discounts, events, news about our Services, products, content offerings, other services, and/or special offers;
- To administer sweepstakes and contests;
- To process and respond to your inquiries;
- To contact you with information that we believe may be of interest to you;
- To attribute content that you make available through the Services;
- For internal research and reporting and data analytics;
- To improve the content and features of the Services and/or develop new Services;
- To allow us and our advertising partners to personalize the content and advertising that you see on the Services or other websites and mobile applications (see the “Personalized Content and Advertising” section below;
- To protect the safety of all who use our Services ;
- To enforce the legal or contractual terms that govern your use of the Services;
- To administer and troubleshoot the Services; and
- Subject to applicable law, to disclose your information to reputable third parties who may provide you with information about their products and/or services that may be of interest to you.
We may also combine information that we collect from you with information we obtain about you from other members of the MSGN Family and/or non-affiliated third parties.
Subject to applicable law, we may also use the information collected from the “Information We Collect” section, such as device identifiers and MAC addresses, to associate users’ activities, customize content, or tailor advertising to those users across different devices and browsers (for instance, tablets, mobile devices and applications, connected TVs and websites).
We may aggregate and/or de-identify any information collected through the Services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others.
- WHEN WE DISCLOSE YOUR INFORMATION
We may disclose your information to any agent or company that is part of the MSGN Family for any of the purposes listed in the “How We Use Your Information” section. The MSGN Family may disclose your information to non-affiliated third parties under the following circumstances.
A. Consent. If you consent, we may disclose your information to non-affiliated third parties in order to provide services or products that you have requested and/or services that we believe will interest you.
B. Service Providers. We may provide access to your information to select third parties who perform services on our behalf and for any other legitimate business and operational purposes. These third parties provide a variety of services to us, including, without limitation, billing, sales, marketing, advertising, market research, fulfillment, data storage, analysis and processing, and legal services.
C. Other Third Parties. Except as provided herein, we may disclose your information to reputable third parties so that they may contact you to offer products, services and promotions, such as sweepstakes and contests that you may find valuable. We may also disclose your information to third party advertising networks or other parties with whom we have a contractual relationship. You can instruct us not to provide your contact information to these third parties by sending an email to [email protected] with “REMOVE THIRD PARTIES” in the subject line. If you receive a communication from a third party and you do not wish to receive future communications from that party, you should also tell them to remove you from their marketing list. For European Economic Area (“EEA”) residents that we can reasonably identify, we will obtain your consent before sharing your information with third parties for these marketing purposes.
We may also allow third-party advertising technologies (e.g., ad networks and ad servers) on our Services that use cookies and similar technologies to deliver relevant and targeted content and advertising to you about the Services on other websites you visit and applications you use, as explained further in “Personalized Content and Advertising” below.
D. Protection of MSGN Family and Others. By using the Services, you acknowledge, consent and agree that we may access, preserve and disclose your information, including, but not limited to, any user content, if required or permitted to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) enforce our Terms of Service, this Policy, or other contracts with you; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of the MSGN Family, its agents and affiliates, its users and/or the public. We may also disclose information to law enforcement agencies in emergency circumstances where the disclosure of such information is consistent with the types of emergency disclosures permitted or required by law.
E. Business Transfers. Each data controller reserves the right to disclose and transfer all of your information, including your contact information, in connection with a proposed (including due diligence) or actual merger, acquisition, transfer of control, distribution or sale of all, or components, of its business.
4. OUR LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA
The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your “personal data” as such term is defined under applicable law. To the extent that those laws apply, our legal grounds are as follows:
- To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our customers, or to take steps at customers’ requests in anticipation of entering into a contract with them.
- Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.
- Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
- Customer service
- Marketing
- Protecting our customers, personnel, and property
- Analyzing and improving our business
- Managing legal issues
- We may also process personal data for the legitimate interests of our business partners, such as to assist with marketing.
- Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.
- To protect the vital interests of the individual or others: For example, we may collect or disclose personal data to help resolve an urgent medical situation.
- INTERNATIONAL TRANSFER
The Services are operated, offered, and provided in the United States and are governed by United States law. If you are a resident of the European Union or other location outside the United States, please be advised that any information you provide through the Services will be transferred to the United States or other designated locations outside of the United States for certain processing/hosting operations. We have taken commercially reasonable steps to ensure that your personal information is appropriately protected and is processed only in accordance with this Policy.
- PERSONALIZED CONTENT AND ADVERTISING AND YOUR CHOICES
A. Online Analytics
We may use third-party web analytics services on our Services, such as those of Google Analytics. These service providers use the sort of technology previously described in the “Information We Collect” section to help us analyze how users use the Services including by noting the third-party website from which you arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
B. Tailored Advertising
We or our third party advertising partners may use technologies such as cookies, pixels and similar tools that allow for the delivery of relevant content and advertising on other websites or mobile applications you visit and/or use. Such content and advertising may be about the Services or based on your activity on the Services. The ads may be based on various factors such as the content of the page you are visiting, information you provide such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and may be tailored to your interests.
Also, third parties and partners use cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (i) inform, optimize, and serve ads based on past visits to our websites and other sites and (ii) report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our websites and use of our Services. We also may disclose a hashed version of your email address with third-party advertising partners, and content that you post publicly when using the Services (e.g. user-generated content) for purposes of delivering tailored advertising to you when you use services provided by those third-party advertising partners and/or you visit other websites and/or use mobile applications. Those parties that use these technologies may offer you a way to opt out of ad targeting as described below. You may receive tailored advertising on your computer through a web browser. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link the Digital Advertising Alliance’s Consumer Opt-Out link or TRUSTe’s Advertising Choices Page to opt-out of receiving tailored advertising from companies that participate in those programs.
To opt out of Google Analytics for display advertising or to customize Google display network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt out of tailored advertising. In that case, the ads will just not be tailored. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
When using a mobile application, you may also receive tailored in-application advertisements. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator. We do not control how the applicable platform operator allows you to control receiving personalized in-application advertisements; thus, you should contact the platform provider for further details on opting out of tailored in-application advertisements.
If you use different devices (e.g., home or work computer, laptop, table, mobile phone, connected television or other Internet-connected device) to access our Services, we may be able to associate you with each of your devices to better understand how you use our Services across the various devices that you use, and to deliver you tailored advertisements.
Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out. In that case, the advertising will not be tailored to your interests.
- YOUR DATA RIGHTS AND CHOICES
A. Marketing Communications
You can unsubscribe from marketing emails we send to you by clicking the “unsubscribe” link they contain. If you have provided contact information while using the Services and later decide that you would rather not have the MSGN Family use that information for marketing purposes in accordance with this Policy, you can also opt out by sending us an email at [email protected] (including your name and email address) and “Marketing Opt-Out” in the subject line. For clarity, individuals in the EEA and the United Kingdom have the right (subject to verification and authentication) to opt out of all of our processing of their personal data for direct marketing purposes. To exercise this right, they may contact us as at [email protected] with “EEA/UK Opt-Out” in the subject line. Please note that we may send you certain transactional and informational emails based on services you have requested, such as purchasing a subscription and you may not opt-out of those emails.
B. Rights Regarding Your Information
Depending on your jurisdiction, you may have the right, in accordance with applicable data protection laws, to make requests related to your “personal information” or “personal data” (as such terms are defined under applicable laws, and collectively referred to herein as “personal data”). Specifically, you may have the right to ask us to:
- Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.
- Provide you access to and/or a copy of certain personal information we hold about you.
- Correct or update personal information we hold about you.
- Delete certain personal information we have about you.
- Provide you with information about the financial incentives that we offer to you, if any.
- Restrict or object to certain uses of your information.
- Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.
You may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising” as described below. If you are a California resident, please see the “Notice to California Residents” section below for more information about our privacy practices and your rights as a California resident.
As provided in applicable law, you also have the right to not be discriminated against for exercising your rights. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address.
To exercise any of these rights, use the form here or email us at [email protected] with your name and type of request you are making. You can also exercise your right to update and/or correct certain information collected by the MSGN Family by visiting your account page(s). If a member name and password are required to access the feature, you will need to provide such information to update your registration information.
Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. To exercise such an appeal right, please email us at [email protected]. You also have the right to lodge a complaint with a supervisory authority.
C. Notice of Right to Opt Out of Sales of Personal Information and Processing/Sharing of Personal Information for Targeted Advertising Purposes
Depending on your jurisdiction, you may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising.”
As explained in the “When We Disclose Your Information” section above, we sometimes disclose information to unaffiliated third parties we collaborate with or that provide offers that we think may be of value to you. We also provide personal information to third-party advertising providers for targeted advertising purposes. Under applicable law, the disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information or the processing/sharing of personal information for targeted advertising purposes.
If you would like to opt out of the disclosure of your personal information for purposes that could be considered “sales” for those third parties’ own commercial purposes, or “sharing” or processing for purposes of targeted advertising, please visit the following page: Your Privacy Choices.
Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of minors under 16 years of age.
D. App Notifications and Location Data
To view and manage notifications and preferences relating to our apps, including certain options regarding the collection and use of location data, visit the settings menu of the app and of your operating system.
- NOTICE TO CALIFORNIA RESIDENTS
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and disclose your “personal information” as defined in the California Consumer Privacy Act (“CCPA”).
We describe the categories of information we collect, our business purposes for collecting such information, the sources and uses of such information and the entities with which we disclose such information in the “Information We Collect”, “How We Use Your Information,” and “When We Disclose Your Information” sections of this Policy. We provide additional information required by the CCPA below.
A. Categories of personal information we collect, use and disclose.
Throughout this Policy, we discuss in detail the types of Information we collect from and about users and discuss how we use and disclose such information. The following are the “categories” of personal information under the CCPA that we collect from California consumers and that we may, as discussed throughout this Policy, use and disclose for our business purposes:
Identifiers (such as name, address, email address); commercial information (such as transaction data); financial data (such as credit card information); device identifiers (such as IP address and unique device identifiers); internet or other network or device activity (such as browsing history or app usage); general geolocation data from IP addresses and precise geolocation information when you use an applicable MSGN Family app; audio or visual information; physical characteristics, such as if you voluntarily submit a photo or video; characteristics of potentially protected classifications, such as gender, and marital status; any user-generated content or feedback that you provide; professional or employment related data; and other information that identifies or can be reasonably associated with you.
B. How we use these categories of personal information.
We and our service providers may use the categories of personal information we collect from and about you for the following business and commercial purposes (as those terms are defined in applicable law).
- Our or our service providers’ operational purposes;
- Auditing consumer interactions on our site (e.g., measuring ad impressions);
- Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
- Bug detection and error reporting;
- Customizing content that we or our service providers display on the Services (e.g., contextual ads);
- Providing the Services (e.g., account servicing and maintenance, customer service, advertising and marketing, analytics, and communication about the Services);
- Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features);
- Other uses that advance our commercial or economic interests, such as third-party advertising and communicating with you about relevant offers from third party partners;
- Other uses about which we notify you.
Examples of these types of uses are discussed in our main privacy policy in the “How We Use Your Information” section. We may also use the categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any user or device.
C. Categories of personal information we disclose for business purposes
We may disclose the following categories of information about you or your use of our Services to service providers for business purposes (as defined by applicable law) or as required by applicable law:
Identifiers (such as name, address, email address); commercial information (such as transaction data); financial data (such as credit card information); device identifiers (such as IP address and unique device identifiers); internet or other network or device activity (such as browsing history or app usage; general geolocation data from IP addresses and precise geolocation information when you use an applicable MSGN Family app; audio or visual information; physical characteristics, such as if you voluntarily submit a photo or video; characteristics of potentially protected classifications, such as gender, and marital status; any user-generated content or feedback that you provide; professional or employment related data; categories of information considered “sensitive” under California law (such as precise geolocation, and username/password); and other information that identifies or can be reasonably associated with you.
We may also disclose this information to third parties for legal, compliance or security purposes, or in connection with a business transfer, as described further in “When We Disclose Your Information” above.
D. Sale/Sharing of personal information.
The CCPA sets forth certain obligations for businesses that “sell” personal information or “share” personal information for cross-context behavioral advertising purposes. Under the CCPA, “sale” and “sharing” are defined such that they may include allowing third parties to receive certain information for advertising purposes. We “sell” or “share” the following categories of information to third-party advertising partners and vendors that support our advertising efforts (such as advertising analytics services):
Identifiers (such as name, address, email address); commercial information (such as transaction data); internet or other network or device activity (such as browsing history or app usage; general geolocation data from IP addresses and precise geolocation information when you use an applicable MSGN Family app.
Advertising, including targeted advertising, allows us to provide you offers relevant to you. If you would like to opt out of our use of your information for such purposes that are considered a “sale” or “sharing” for cross-context behavioral advertising purposes under California law, you may do so as outlined on the following page: Your Privacy Choices. Please note that we do not knowingly sell the personal information of minors under 16 years of age.
E. California Privacy Rights.
California residents can make certain requests about their personal information under the CCPA. Specifically, if you are a California resident, you may request that we:
- provide you with information about: the categories of personal information we collect, disclose or sell about you; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties to whom we disclose personal information. Such information is also set forth in this Privacy Policy;
- provide access to and/or a copy of certain information we hold about you;
- correct inaccurate personal information we hold about you;
- delete certain information we have about you; and/or
- provide you with information about the financial incentives that we offer to you, if any.
Please note, in the limited circumstances that we process sensitive personal information as defined by the CCPA, we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA.
California residents can also designate an authorized agent to make access and/or deletion requests on their behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.
We will take reasonable steps to verify your identity before responding to a request for access and/or deletion from you or your designated agent. If we are unable to verify you, we may be unable to respond to your requests.
The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.
Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you.
If you are a California resident and would like to exercise any of your legal rights under the CCPA, please use our online consumer request form here or contact us at [email protected] with “CCPA Rights” in the subject line.
F. Shine the Light.
California Law permits customers who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes. To make such a request, please send an email to [email protected] with “REMOVE Third Parties” in the subject line.
G. Additional California Rights for Minors
If you are a California resident under the age of 18 and are a registered User of our Services, you may request that we remove from our Services any content you post to our Services that can be accessed by any other User (whether registered or not). Please note that any content that is removed from our Services may remain on our servers and in our systems. To request removal of content under this provision, please send an email to [email protected] with “California Minors Opt-Out” in the subject line and provide us with a description of the content and the location of the content on our Services, and any other information that we may require in order to consider your request. Please note that removal of content under this provision does not ensure complete or comprehensive removal of the content or information posted on the Services by you.
H. California Online Privacy Protection Act Notice Concerning Do Not Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information collected on the Services for third party purposes, and that is why we provide links to the Network Advertising Initiative and the Digital Advertising Alliance opt-out pages, as well as choices provided by Google Ads and Google Analytics. However, we do not recognize or respond to browser-initiated DNT signals, except for legally required browser based signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. To learn more about Do Not Track, you can do so here.
9. PRIVACY INFORMATION FOR NEVADA RESIDENTS
Under Nevada law, certain Nevada consumers may opt out of the sale of “covered information” for monetary consideration. We do not sell “covered information” as defined under Nevada law; however, if you are a Nevada resident who has purchased services from us, you may submit a request to opt out of any potential future sales here. Please note we may take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event that our practices change.
- LINKS
Links to third-party websites, applications and other services may be made available through the Services. We are not responsible for the privacy practices or the content of such third-party services. Any information you provide via those services is subject to the applicable privacy policies and is not covered by this Policy.
- SECURITY AND RETENTION OF YOUR INFORMATION
We have implemented administrative, technical, and physical security measures to protect against the loss, misuse and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.
We generally retain personal data for so long as it may be relevant to the purposes above. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information. For example, we retain your email address as an authentication credential (where applicable) as long as you have an account with us and an additional period of time after that for our legitimate interests and for our fraud and legal compliance purposes. If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. To dispose of your information, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.
- INFORMATION FROM CHILDREN
The Services are not directed to children under the age of 16. If we discover we have received any “personal information” (as defined under the Children’s Online Privacy Protection Act) from a child under the age of 13 in violation of this Policy, we will take reasonable steps to delete that information as quickly as possible. If you believe the MSGN Family has any information from or about anyone under the age of 16, please contact us at the address listed below.
For residents of the EEA, where processing of personal information is based on consent, the MSGN Family will not knowingly engage in that processing for users under the age of consent established by applicable data protection law. If we learn that we are engaged in that processing with such users, we will halt such processing and will take reasonable measures to promptly remove applicable information from our records.
- CONTACTING US ABOUT THIS POLICY
Please do not hesitate to contact us with any questions, concerns, requests or comments by email at [email protected] or write to us at MSGN Holdings, L.P., 11 Pennsylvania Plaza, 3rd Floor, New York, New York 10001, Attn: Communications Department and with a copy to MSGN Holdings, L.P., 2 Pennsylvania Plaza, 19th Floor, New York, New York 10121, Attn: Legal Department.
- CHANGES TO THIS POLICY
We reserve the right to change this Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this Policy will be deemed to mean you understand the applicability of those changes.
- DATA CONTROLLER CONTACT INFORMATION
MSGN Holdings, L.P.
11 Pennsylvania Plaza, 3rd Floor,
New York 10001
Effective Date: April 21, 2023
© Copyright 2023 MSGN Holdings, L.P. 11 Pennsylvania Plaza, 3rd Floor, New York, NY 10001. All rights reserved. Use of any Service which includes a link to this Policy signifies your acceptance of this Policy.
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