Last updated: November 1st, 2020
- WHAT INFORMATION PANGRAM COLLECTS FROM YOU
PANGRAM may collect two (2) types of information about you: Personal and Non-Personal.
1.1 Personal Information
Personal Information refers to information that lets PANGRAM know the specifics of who you are and which may be used to identify, contact, or locate you (e.g. name, mailing address, telephone number and email address). PANGRAM may collect Personal Information when you use the PANGRAM Properties including, without limitation, setting up account information, filling out surveys, corresponding with PANGRAM, or otherwise volunteering information about yourself.
1.2 Non-Personal Information
Non-Personal Information refers to information that, by itself, does not identify you as a specific individual (e.g. demographic information or website visitations). PANGRAM may collect Non-Personal Information through any of the methods discussed above as well as automatically through the use of industry-standard technologies described further below.
1.3 Types of Data Collected
We collect all types of data from our visitors, including hashed emails, etc in order to track visitors’ cross-device, via email, by partners like TELEFERENCE.
1.4 Switzerland Residents
If you are a California resident and would like more information about how your data is used by our partners you can find it here:www.teleference.com.
2. HOW PANGRAM COLLECTS YOUR INFORMATION
The Personal Information practices set forth apply to all PANGRAM’s customers worldwide.
Prior to using one or more of the PANGRAM Properties, PANGRAM may require certain Personal Information and Non-Personal Information to create an individual account (“Account”) or to enable features or functionality of the PANGRAM Properties. Failure to provide all required information required by PANGRAM may prevent access to any or all PANGRAM Properties, and failure to maintain accurate information may result in suspension or termination of access to any or all PANGRAM Properties.
2.2 Information Collected Through Technology
While you are able to visit the PANGRAM Site and remain anonymous, PANGRAM or its third-party service providers may still collect Non-Personal Information about your use of the PANGRAM Properties (e.g. your Internet browser, operating system, IP address, connection speed, and the domain name of your Internet service provider). Such information may be gathered by the following methods:
(a) Cookies. Cookies, including local shared objects, are small pieces of information that are stored by your browser on your computer’s hard drive which works by assigning to your computer a unique number that has no meaning outside of the PANGRAM Site. Cookies do not generally contain any Personal Information. Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. Not accepting cookies may make certain features of the PANGRAM Properties unavailable to you.
(b) IP Address. You may visit many areas of the PANGRAM Site anonymously without the need to become a registered User. Even in such cases, PANGRAM may collect IP addresses automatically. An IP address is a number that is automatically assigned to your computer whenever you begin Services with an Internet services provider. Each time you access the PANGRAM Site and each time you request one of PANGRAM’s pages, the server logs your IP address.
(c) Web Beacons. Web beacons are small pieces of data that are embedded in web pages and emails. PANGRAM may use these technical methods in HTML emails that PANGRAM sends to Users to determine whether they have opened those emails and/or clicked on links in those emails. The information from the use of these technical methods may be collected in a form that constitutes Personal Information.
(d) Tracking Content Usage. If you use the PANGRAM Services and you post audiovisual materials including, without limitation, text, logos, artwork, graphics, pictures, advertisements, sound and other related intellectual property contained in such materials (collectively, “Content”) to your website or to a third party website, PANGRAM tracks and captures Non-Personal Information associated with User accounts and the use of Content.
2.3 Cross Device Opt-Out:
If you wish to opt-out from receiving cross-device site advertising (i.e. tracking a user across devices), you can do so by accessing your device setting or visiting and employing the controls described on theNAI’s page.
3. HOW PANGRAM USES YOUR INFORMATION
3.1 System Administration
PANGRAM may use Non-Personal Information for the purposes of system administration, assisting in diagnosing problems with PANGRAM servers, monitoring PANGRAM’s system performance and traffic on the PANGRAM Properties and to gather broad demographic information about PANGRAM customers.
3.3 Notices to Registered Users
If you have registered for an Account, PANGRAM may use your Personal Information to send emails regarding your registration, including confirmation to verify the accuracy of any information you have provided, and instructions on how to post Content. PANGRAM may also send you emails to verify your identity or to notify you if PANGRAM believes your use of PANGRAM Properties violates any applicable agreement for the use of the PANGRAM Properties.
PANGRAM may use Non-Personal Information to assist in optimizing the delivery of advertisements to viewers of your Content.
3.5 Advertising Opt-Out:
If you wish to opt-out of receiving targeted advertising, you can do so by visiting one of the appropriate correspondinglinks.
3.6 Promotional Emails
PANGRAM may use your Personal Information to send you emails periodically listing promotions or events relating to the PANGRAM Properties or from PANGRAM’s marketing partners or sponsors. You have the choice to opt-out of receiving such promotional emails by sending an email to [email protected] and/or following the instructions in such correspondence. Once PANGRAM has processed your opt-out request, PANGRAM will not send you promotional emails unless you opt back into receiving such communications.
3.7 Contact Information
If you contact PANGRAM by telephone, email, or letter, PANGRAM may keep a record of your contact information and correspondence. If you report a problem with the PANGRAM Properties, PANGRAM may collect this information in a file specific to you. You may contact PANGRAM at [email protected] to request the removal of this information from PANGRAM’s database.
4. HOW TO ACCESS AND CHANGE YOUR PERSONAL INFORMATION
Upon request, PANGRAM shall allow Users to update or correct Personal Information previously submitted, but only to the extent, such activities will not compromise privacy or security interests. Additionally, upon request, PANGRAM shall delete Personal Information from the database where such information is stored; however, it may be impossible to entirely delete a User’s entry without some residual information being retained due to the manner in which data backups are maintained. Requests to delete Personal Information shall be submitted to [email protected].
5. DISCLOSURE OF INFORMATION TO THIRD PARTIES
PANGRAM does not sell, trade or rent Personal Information collected through the PANGRAM Properties to any third party. Notwithstanding the foregoing, PANGRAM shall: (1) fully cooperate with law enforcement agencies; and (2) may be required to disclose Personal Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation.
Here are the third party data processors, storage, and infrastructure partners:
- Billing services (includes Recurly, Stripe, PayPal) to enable payment for the services and the provisioning of the services
- Operational data (includes AWS, Akamai, Limelight, Verizon) that enable us to actually provide the streaming services
- Paywall services (InPlayer) to provide services allowing our customers to monetize their content through Pay per View and Subscriptions
- Communication and customer service tools (includes Akita, Pardot, Salesforce, Helpscout, and Zendesk) to help assist customers and communicate with them
- Data tools (includes Google Data Studio, Profitwell) in order toanalyze and report within the company to improve the service
6. SAFEGUARDING YOUR PERSONAL INFORMATION
6.1 Security Measures
PANGRAM takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of Personal Information. These include, but are not limited to, internal reviews of: (a) PANGRAM’s data collection; (b) storage and processing practices; (c) electronic security measures, and (d) physical security measures to guard against unauthorized access to systems where PANGRAM stores Personal Information. All PANGRAM employees, contractors, and agents who access Personal Information are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution or unauthorized use or disclosure of Personal Information.
6.2 Third-Party Links
The PANGRAM Properties may contain links to third parties who may collect Personal Information and Non-Personal Information directly from you. Additionally, PANGRAM may use third parties to provide components of the PANGRAM Properties. In either case, such third parties may have separate privacy policies and data collection practices, independent of PANGRAM. PANGRAM: (a) has no responsibility or liability for these independent policies or actions; (b) is not responsible for the privacy practices or the content of such websites; and (c) does not make any warranties or representations about the contents, products or services offered on such websites or the security of any information you provide to them.
7. WHAT ARE YOUR DATA PROTECTION RIGHTS?
PANGRAM would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access – You have the right to request PANGRAM for copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that PANGRAM correct any information you believe is inaccurate. You also have the right to request PANGRAM to complete the information you believe is incomplete.
The right to erasure – You have the right to request that PANGRAM erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that PANGRAM restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to PANGRAM’s processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that PANGRAM transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email:
write to us: [email protected]
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology
For further information, visit allaboutcookies.org.
- Keeping you signed in
- Understanding how you use our website
- Track features such as delivering content specific to your interests
- Informing you of new, relevant services.
8.3 What types of cookies do we use?
There are a number of different types of cookies, however, our website uses:
- Functionality – PANGRAM uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and the location you are in. A mix of first-party and third-party cookies are used.
- Advertising – PANGRAM uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed, and information about your browser, device, and your IP address. PANGRAM sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.
8.4 How to manage cookies?
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
- PRIVACY POLICIES OF OTHER WEBSITES
SPECIAL NOTE REGARDING CHILDREN UNDER 13 YEARS OF AGE
The use of the PANGRAM Properties is not intended for minors under the age of 18 (“Minors”). Minors are not authorized by PANGRAM to use the PANGRAM Properties, even if Minors set up an Account or accept the terms of any agreement for PANGRAM Properties. Parents or guardians may authorize Minors between the ages of 13 and 17 to use the PANGRAM Properties, provided they assume all responsibility and legal liability for the conduct of such Minor including, without limitation, monitoring the Minor’s access and use of the PANGRAM Properties. PANGRAM does not intentionally collect nor maintain any personally identifiable information from Minors. If you discover your Minor child has submitted his/her information to PANGRAM, you may request to have such information deleted from PANGRAM’s database by sending an email request to [email protected] together with the email address that was submitted by the Minor. Upon receiving the request, PANGRAM shall delete such information within twenty (20) business days. If PANGRAM learns that a Minor is using the PANGRAM Properties, PANGRAM will require verified parental or guardian consent, in accordance with the Children’s Online Privacy Protection Act of 1998 (“COPPA”).
12. RIGHTS OF CALIFORNIA RESIDENTS – THE CALIFORNIA CONSUMER PRIVACY ACT OF 2018 (CCPA)
If you are a resident of the State of California in the United States, you are entitled to certain rights under the California Consumer Privacy Act of 2018 (CCPA). The categories of Personal Information we collect about or from you are described in section 1 above, and the business purposes for which we collect such Personal Information are described in section 3 above.
As a business subject to the CCPA, PANGRAM does not sell Personal Information. PANGRAM may share Personal Information with third-party service providers or business partners for our own business purposes as described in section 5 above. However, we disclose your Personal Information to these third parties only where you have consented to disclosure of Personal Information to such third parties or where such third parties have agreed to contractual
limitations around their use, retention, and disclosure of Personal Information.
As a resident of the State of California, you have the following rights under the CCPA:
- You have the right to request access to the Personal Information we collect from or about you.
- You have the right to request details about how we process or disclose your Personal Information.
- You have the right to request that we delete the Personal Information we have collected about you, subject to
- You have the right to not be denied any goods or services for exercising your rights under the CCPA.
To exercise any of these rights, you may contact PANGRAM by following the instructions in section 14 below. We may need to verify your identity before we are able to process your requests.
- RIGHTS OF EUROPEAN DATA SUBJECTS – THE GENERAL DATA PROTECTION REGULATION (GDPR)
13.1 GDPR Rights
If you are in one of the EU/EEA countries, you are entitled to certain rights under the General Data Protection Regulation (GDPR) EU Regulation 2016/679 and applicable national data protection regulations. By visiting the PANGRAM Websites or communicating with PANGRAM, you acknowledge that we may process your Personal Information for the purposes described above, either on the basis of your consent or if we have other lawful grounds to do so. Under the GDPR, you have the following rights with respect to your Personal Information:
- You have the right to withdraw consent to the processing, where consent is the basis of processing. For the Personal Information we collect on the PANGRAM Websites, this means you may withdraw your consent to processing by leaving the PANGRAM Websites, suspending your account if you have registered on our Websites, and requesting that we delete your Personal Information.
- You have the right to access your Personal Information that we hold and request further details about how we process it, under certain conditions. See section 7.
To exercise any of these rights, you may contact PANGRAM at [email protected]
13.2 Cross-border Personal Information transfers and the EU-US Privacy Shield
If you are in the European Union, you have a right to access your Personal Information. If you wish to access your information held by PANGRAM, please follow the contact information at the end of this notice. PANGRAM may be liable for onward transfers to third parties in violation of the Privacy Shield Principles. We will investigate and attempt to resolve requests, complaints, and disputes regarding the use and disclosure of your information in accordance with this Privacy Notice and may require further information from you in order to identify you and to address the matter at issue.
14. CONTACT PANGRAM
2nd Floor, 17 King Edwards Road,London HA4 7AE,
United Kingdom.[email protected].