Privacy Policy

Collection of your Personal Information

In order to better provide you with products and services offered to you, operate, tailor content, personalize, adjust and improve our Properties, and to send you messages or personalized information about our services, including for marketing and promotional purposes, Prism may collect information about you that is provided by you or other sources, such as your:

• First and Last Name
• Mailing Address
• E-mail Address
• Phone Number

If you provide this information to Prism, including on this website, when you choose to sign-up to receive newsletters or other marketing materials, when you submit information to Prism through the Prism website or when you use and/or purchase Prism products and services, we collect this information. If you purchase Prism’s products and services, we collect billing and credit card information as well. This information is used to complete the purchase transaction. Derivative data may also be collected or generated from commercial transactions, such as purchase history, customer preferences, and geo-locational data.

Prism may also collect anonymous demographic information, which is not unique to you, such as your:

• Age
• Gender

We do not collect any personal information about you, unless you voluntarily provide it to us or you provide it to a third party who then provides it to us to share information collected from or about you. We combine the information provided by these other sources with information we have collected from or about you. We only collect this information from those other sources when they have confirmed to us that they are legally entitled to share it with us.

You may be required to provide certain personal information to us when you elect to use certain products or services available on the Properties. These may include: (a) registering for an account on our Properties; (b) signing up for special offers from selected third parties; (c) sending us an email message; (d) submitting your credit card or other payment information when ordering and purchasing products and services on our Properties. To be clear, we will use your information to communicate with you, as needed, in relation to services and/or products you have requested from us, and to perform the services and acts described elsewhere in this Privacy Policy.

We use Cookies to provide and support our Properties and each of the uses outlined and described in this policy. Please see our Cookie Policy in the Cookies section below for more information.

Further, when you visit the Properties, we may automatically collect certain information about your device, including information about your web browser, internet protocol (IP) address, time zone, and some of the cookies that are installed on your device, and as you browse the Properties, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Properties, and information about how you interact with the Properties (collectively, “Device Information”). We may also collect information from and about you which may be considered personal information which identifies you or your device or is reasonably associated with you. We may also collect data including, but not limited to, government identifiers, financial account login information, precise geolocations, genetic data, biometric information, race, ethnicity, religious and/or philosophical beliefs, union memberships, content of non-public communications, and data relating to your sex life and/or sexual orientation (collectively, “Sensitive Personal Information”). Additionally, when you make a purchase or attempt to make a purchase through the Properties, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number (collectively, “Order Information”).

The information that is collected by Prism pursuant to this Privacy Policy may be collectively referred to herein as “Information” or “personal information.”

Use of your Personal Information

Prism collects and uses your Information to operate its website(s) and deliver the services you have requested, such as to process and fulfill orders you may place for purchase. Prism may also use your personally identifiable information as follows:

• For the purposes for which you provided it
• To communicate with you
• To process and respond to your inquiries
• When in line with the preferences you have shared with us, to send you alerts or other communications via SMS messages or other media or networks
• For internal research and reporting
• To inform you of other products or services available from Prism and its affiliates
• To improve and optimize the Properties
• Screen purchases for potential risk or fraud
• When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

Prism may offer you the ability to receive newsletters or marketing periodically by email about our products and services, and the products and services of Prism affiliates. You can stop receiving further newsletters or marketing emails by unsubscribing from the link in the footer of each email we send to you.

Sharing Information with Third Parties

General. Prism does not sell, rent or lease its customer lists to third parties. Prism may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. Prism may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your Information except to provide these services to Prism, and they are required to maintain the confidentiality of your Information.

As detailed further below, Prism may disclose your Information, without notice:

• with vendors, partners, and sponsors engaged by Prism in order to provide you with goods or services you have requested, or online advertising selected by us;
• if required to do so by applicable law, regulation or legal process;
• if necessary, to exercise, establish or defend our legal rights;
• if necessary, to protect the rights, property or safety of any person; and
• in connection with the sale of our business or assets.

Finally, we may also share your Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Vendors. Vendors provide goods and services (for example, billing, consumer services support, consultancy, information technology hardware and software) to Prism in order to support, operate and develop the Properties and to deliver marketing communications on our behalf. Vendors use your Information to execute, deliver and/or from time to time improve the services they provide. We do not share Information with vendors to use for their own direct marketing purposes or any other purpose other than those set out in this section without your consent.

Law. We will disclose your Information in the good faith belief that we are required to do so by law, including but not limited to disclosure to law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you, us or our affiliates to legal liability. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.

Legal Rights. We will disclose your Information where necessary for the purpose of exercising, establishing or defending our legal rights or those of our affiliates. For example, we will review your communications and other Information in order to investigate allegations of hacking or any other breach or alleged breach of any applicable Terms of Service or this Privacy Policy and disclose your personal information, including communications, to our legal advisors, consultants and law enforcement or other government officials.

Protecting Others. We disclose your Information with third parties where we believe this is necessary to protect the rights, property or safety of any person. For example, we disclose Information relating to an online account if we in good faith believe the user of that account is using it in ways that are harmful to others (e.g., making inappropriate contact with minors).

Sale of Our Business or Assets. Separately, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, Prism’s customer information, including Information and communications, may be transferred to our successor(s) or assign(s).

Tracking User Behavior

Prism may keep track of the websites and pages our users visit within the Properties, in order to determine what Prism services are the most popular. This data is used to deliver customized content and advertising within Prism to customers whose behavior indicates that they are interested in a particular subject area.

Automatically Collected Information

Information about your computer hardware and software may be automatically collected by Prism. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the Properties, to maintain quality of the Properties, and to provide general statistics regarding use of the Properties.

Cookies

Use of Cookies. Prism uses cookies and/or similar technologies on the Properties (collectively referred to as “Cookies”). A Cookie is a small bit of record-keeping information that many websites and other online products and services often store on a user’s computer or device in order to identify it and associate activity with it.

When visiting the Properties, you may have options to enable or disallow Cookies. Most web browsers automatically accept Cookies, but you can usually modify your browser setting to decline Cookies, if you do not want to accept them. We use Cookies to optimize your visit, make your browsing and/or user experience as effective as possible, and let you know about offers and features that we think will interest you. This means that if you disallow Cookies, your use of the Properties may be impaired.

Depending on the Property you are using, and the country you are based in, Cookies may be set on your computer or device by either:

• Prism – to recognize and associate activity with your computer or device when it visits a Property. Prism Cookies cannot be used to recognize or associate activity with your computer or device when it visits other, third party websites or online properties.
• Third Parties – to enable third-party features or functionality to be provided on or through our Properties or other online properties (e.g., advertising and analytics). The third parties that set these Cookies may be able to recognize your computer or device both when it visits the Properties or other online properties that use the third party’s features and functionality.

Types of Cookies. There are four categories of Cookies (necessary, performance, functionality and advertising), as well as technologies that are similar to cookies, that may be served through our Properties. Cookies may also be set by third parties, including our affiliates, vendors and partners. To learn more about your opt-out choices for cookies, please see the Managing Cookies section below. To learn more about your opt-out choices for technologies that are similar to cookies, please see the Similar Technologies section below.

• Necessary Cookies. These Cookies are essential in order to enable you to move around websites or online properties and use their features, such as accessing secure areas of a website.
• Performance (or Analytics) Cookies. These Cookies collect information about how visitors use a website or online property, for instance, which pages visitors go to most often, and if they get error messages from web pages. These Cookies don’t collect information about the actual identity (e.g., name) of a visitor. All information these Cookies collect is aggregated. They are only used to improve how a website or other online property works. We generally contract with third parties (such as Google Analytics), to provide these services on our behalf.
• Functionality Cookies. These Cookies allow the website or online property to remember choices you make (such as the language or the region you are in) and provide enhanced, more personalized features. These Cookies can also be used to remember changes you have made related to accessibility (e.g., text size, fonts) and customization. They may also be used to provide services you have asked for such as watching a video. The information these Cookies collect may be anonymized and they cannot track your browsing activity on other websites.
• Advertising Cookies. These Cookies are used to deliver advertisements that are more relevant to you and your interests. They also help limit the number of times you see an advertisement as well as measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information is shared with other organizations or advertisers.

Prism may partner with third-party online advertising and analytics companies to tailor and deliver advertisements, products, services, and promotions on Prism’s Properties, as well as other online properties which we do not control. To help select the ads of greatest interest to you, these companies may use Cookies to collect and track information such as demographic data (e.g., gender, occupation, etc.), aggregated information, search keywords, geo-location, and device-related data (for example, browser type, language, IP address, Advertising ID, time/date) to select advertisements that are more relevant to your interests and to better personalize the experience for you. In some instances, third parties may also use Cookies to collect anonymized or device-related information about your visits to Prism’s Properties in order to monitor the effectiveness of the ads (e.g., by using analytics Cookies) and to provide third-party advertisements about goods and services likely to be of greater interest to you.

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. You can learn more about opting out of targeted advertising by using the following links: Facebook: https://www.facebook.com/settings/?tab=ads; Snapchat: https://support.snapchat.com/en-US/a/advertising-preferences. Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Prism may use, combine and share anonymized or aggregated information obtained from Cookies with third parties such as vendors or advertising partners. For example, we may use information such as interests or preferences to group you with other people with similar interests or preferences and place you into a market segment. We may then display advertisements which we believe people in your market segment will find relevant. We may also share Information obtained from Cookies with third parties such as vendors or advertising networks in order to permit them to provide services on our behalf or to partner with us in selecting and serving advertisements for us or our advertising partners.

Similar Technologies. Adobe Flash Player is an application that allows sites to deploy dynamic web content. For example, we may use Flash Cookies to deliver video content to you on our Properties. Adobe Flash and similar applications use technology to remember settings, preferences, and usage in ways that are similar to browser cookies, but are managed through a different interface than your web browser. You can access your Flash management tools from http://www.adobe.com/ directly to manage your Cookie settings.

From time to time, we may use web beacons (or clear GIFs) on our websites or other online properties or include them in the email messages we send you. Web beacons (also known as “web bugs,” “pixel tags,” or “pixels”) are small strings of code that provide a method of delivering a graphic image on a web page or in an email message for the purpose of transferring data. We use web beacons for many purposes, including site traffic reporting, unique visitor counts, advertising, email auditing and reporting, and personalization. For example, we may use these in emails to understand and analyze whether the email was opened or any links were clicked, in order to improve our future communications with you and other users. As a web beacon forms part of a webpage or email it does not have the same opt-out options as other Cookies. Generally, you can render them ineffective by opting out of any cookies they set, by turning off images in your email service, or by viewing your emails as “text” rather than “HTML.”

If you would like to find out more about Cookies and how to disable cookies you may find the following link useful: http://www.allaboutcookies.org/. But please be aware that this is a third-party website that we do not own or operate. Therefore, we cannot guarantee any of the information therein. For more information on how to opt out of Cookies see the Managing Cookies section below, and for more information on how to turn off images in your emails or to view them as text see the “Help” section of your email service provider.

We may also use log files, which are files that track actions occurring on the Properties and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

Managing Cookies. You can review your options to manage Cookies by:

• opening the “Help” menu on the browser menu bar. Most browsers will tell you how you can disable or delete Cookies or set your browser to alert you when Cookies are being sent to your computer;
• visiting your mobile device developer’s website or reviewing your device manual. Most mobile device developers will tell you how you can manage the settings on your mobile device to opt out of and/or delete Cookies from your mobile device, or to limit the use of and/or opt out of targeted advertising;
• contacting Prism via the Contacting Us section of this Privacy Policy.

If you reject all Cookies, you may not be able to use certain features of our websites and other products and services.

We may embed photos and/or video content on our Properties from third-party sources, and these sites may set their own Cookies. Similarly, our Properties may have buttons that enable you to share content on social media or other sites, and these services may set a Cookie on your device. This Cookie Policy does not apply to Cookies set by such features, and Prism does not control these Cookies set by third parties. We encourage you to review the third-party privacy policy or cookie policy for more information about these Cookies and how to manage them.

Permission to Use Cookies. By using the Properties you agree, and we will assume you consent, to receive Cookies unless you manage your cookie choices by one of the means set out above. Please also note that the use of information obtained by third-party providers through cookies placed by them is also subject to their own privacy policies. We encourage you to review the privacy policies of these third-party providers, as their privacy practices may vary from ours.

Links

The Properties may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site, and to read the privacy policy and terms of use of any other site that collects personally identifiable information.

Security of your Personal Information

Prism takes a range of security measures designed to protect your personal information and keep it confidential (unless it is non-confidential by nature, for example, publicly-available information). For example, when personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.

We also take steps to ensure that the personal information collected is protected from misuse and alteration. In addition, we request vendors who process personal information on our behalf to themselves take a range of security measures designed to help protect your personal information.

However, the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving, as are the technical and organizational industry standards relating to management of those risks. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) complete security, integrity, and privacy of any and all information and data exchanged between you and us through the Properties cannot therefore be guaranteed.

Accessing Information and Retention Period

If for any reason you are concerned with the way we are using your personal information, or would like to correct, view, update or request that we delete such personal information, you can send your request to us using the Contacting Us section of this Privacy Policy.

Your personal information will be retained by Prism only as long as is reasonably necessary for the purposes for which it is collected. We delete your personal information if you terminate your account or contract with us (as applicable), withdraw your consent or where you request us to delete your personal information in accordance with this Privacy Policy, subject to data retention permitted by applicable law. As an exception, we will not delete your personal information where we still have a legitimate interest in using your personal information. For example, we may still retain your Information to resolve disputes, enforce any applicable Terms of Service or other user agreements, or comply with legal requirements; in this case, your personal information will be blocked from use for any other purpose. In any case, we will not retain or use your personal information longer than necessary for the purposes outlined in this Privacy Policy. Due to technical reasons, residual copies of Information that has been removed from your account and/or the Properties may remain in our backup systems.

Your Choices

About Information Provided by You. You have choices over the Information provided by you and by other sources, and how that Information is used by Prism. If you do not want to provide Prism with personal information, then you can choose not to provide it. Please note that if you choose not to provide us with personal information, we may not always be able to provide you with the relevant Prism product or service that you want. For example, without providing an email address, you would not be able to create a Prism account (see our Terms of Service).

About Information Provided by Third Parties. You may be able to control how third parties collect and share your Information by changing your preferences or opting out of collection directly with those third parties. Before disclosing Information to third parties, we recommend you check their respective privacy policies for further details.

About Prism Using Your Information. You can exercise choices over how Prism uses your personal information and update your preferences at any time:

• to remove yourself from receiving email marketing or newsletters from Prism, simply click the unsubscribe link in the email;
• to disable selected Cookies from collecting information relating to the effectiveness of advertising campaigns or analytics data and from serving you with personalized advertising on our Properties or third-party properties please see the Cookies section of this Privacy Policy.

If you opt out of receiving email marketing communications from us, please note that we may still contact you occasionally to provide you with service-related information.

If you are a user located in the European Economic Area (“EEA”) and would like to know more about your rights in connection with your personal information, please see the Users in the EEA section below.

Users in the EEA

We only process or transfer your personal information where we can rely on legal grounds and appropriate safeguards to do so. You also have additional rights regarding your personal information if you are located in the European Economic Area (“EEA”). Additionally, if you are a visitor to our websites or other online products and services from outside the U.S., we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Properties), or otherwise to pursue our legitimate business interests described above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

Disclosure to Users outside the US and the EEA

If you are a visitor to our websites or other online products and services from outside the U.S. and the EEA, the personal information you provide will be collected, processed and stored directly on, or transferred to, servers in the United States or other countries where Prism or its affiliates, or our other partners or vendors maintain facilities or business operations.

No matter where the Information is located, Prism takes commercially reasonable measures to safeguard your privacy rights in accordance with this Privacy Policy. If you do not agree to the collection, processing, storage and transfer of your Information, please do not provide your Information when requested and stop using our websites and other online products and services.

Legal Basis for Processing Your Personal Information

We only process your personal information where we can rely on legal grounds to do so. We process your personal information for the purposes set out below.

Performance of the Services. We process your personal information for the performance of our services, to provide or support of our products, or for any other feature you request or enable. This includes, for example, using your personal information to provide global customer service.

We also process your personal information based on your consent. This includes, for example, providing:

• newsletters and direct e-mails about our Properties; and
• certain other marketing features.

We also process your personal information where we have a legitimate interest to do so. This includes, for example, processing:

• to provide you with requested customer service or technical support;
• to debug and improve our current and future Properties;
• in order to give you exclusive content, personalize your online experience with us and contact you in accordance with applicable marketing preferences; and
• for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity.

And, of course, we process your personal information for compliance with a legal obligation to which we are subject.

Your Rights to Your Personal Information

You have the following rights in addition to your rights to view, correct, update, or request the deletion of your personal information as set out in detail in the Accessing Information section of this Privacy Policy. To access or delete your personal information, you can also make a request by using the contact details set out in the Contacting Us section of this Privacy Policy.

You may object to the processing of your personal information based on a legitimate interest on grounds relating to your particular situation. You may control the extent to which we market to you and you have the right to request that we stop sending you marketing messages at any time. You can make a request by using the contact details set out in the Contacting Us section of this Privacy Policy.

In certain circumstances, you can request that we transfer personal information that you have provided to us.

Where we rely on your consent in order to process your personal information, you have the right to withdraw such consent to further use of your personal information at any time. You can use the methods described in the Accessing Information section of this Privacy Policy to update your marketing preferences.

For each of the rights described above, you can also send your request to us by using the contact details set out in the Contacting Us section of this Privacy Policy.

We hope that we can satisfy queries you may have about the way we process your personal information. However, if you have unresolved concerns you also have the right to complain to data protection authorities. You can bring the complaint in your member state of residence, place of work or where an alleged infringement of data protection law occurred.

International Transfers

Your personal information will be transferred to and processed in the United States where many of our central databases operate or other countries where Prism and its affiliates, vendors and partners maintain facilities or business operations. We use European Commission approved contract clauses to protect your personal information. If you have questions, please contact us using the contact details set out in the Contacting Us section of this Privacy Policy.

Your California Privacy Rights

Customers who are California residents may request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share our customer’s personal information with unaffiliated third parties for their own direct marketing purposes, without their approval.

If at any time you wish to opt out of having your personal information shared with third parties and/or receiving information from Prism about new products, services, or promotions, please contact Prism to notify them of this via the Contacting Us section below. We will be happy to honor your request.

California Consumer Privacy Act (“CCPA”). If you are a California resident, you have the following specific privacy rights:

• You have the right to request a report showing the “personal information” (as defined in the CCPA) collected, shared, and sold about you in the past twelve (12) months;
• You have the right to request that we delete any of your “personal information” (as defined in the CCPA) we have collected from you (subject to certain limitations set forth in the CCPA); and
• the right to opt out of the sale of your “personal information” (as defined in the CCPA).

We shall not discriminate against you based upon the exercise of any of the above rights. You or your authorized agent may submit a request to exercise any of the above enumerated right by contacting us in accordance with the Contacting Us section of this Privacy Policy.

California Privacy Rights for Minor Users. If you are a California resident and under the age of eighteen (18), you have the right to view, correct or delete any Information provided by you or publicly posted by you. You may do so by contacting us in accordance with the Contacting Us section of this Privacy Policy. We will be happy to review, update or remove Information and/or content as appropriate. Residual copies of Information and/or content that have been deleted may remain in our backup systems. We may still retain your Information to resolve disputes, enforce our user agreement, or comply with legal requirements; in this case, your personal information will be blocked from use for any other purpose.

Children Under Thirteen

Prism does not knowingly collect or store any personal information from children under 13 in the United States or under the relevant age threshold in other jurisdictions where the child is located. If you are under thirteen (13) years old in the United States, or under the relevant age threshold in the jurisdiction where you are located, you cannot use the Properties without the permission of your parent or guardian.

However, we may collect technical information required for delivering the service and for the support of our internal operations from all users of our Properties. If parents or guardians believe that we have unintentionally collected their children’s other personal information or otherwise used their children’s personal information for another purpose, they may reach out to us via the Contacting Us section of this Privacy Policy. Parents should contact Prism immediately if they have any concerns. Please see the Contacting Us section of this Privacy Policy for further details.

Do Not Track

Your browser may allow you to set a Do Not Track (DNT) signal indicating that you do not wish your online activity to be tracked. Currently, our system does not support and cannot act on DNT signal headers that we may receive. However, the choices that we provide you concerning collection and use of your personal information will continue to operate as described in this Privacy Policy.

E-mail Communications

From time to time, Prism may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication relating to Prism. In order to improve our Properties, we may receive a notification when you open an email from Prism and/or when you click on a link therein.

If you would like to stop receiving marketing or promotional communications via email from Prism, you may opt out of such communications by clicking on the “unsubscribe” link/button.

External Data Storage Sites

We may store your data on servers provided by third party hosting vendors with whom we have contracted.

Changes to this Privacy Policy

Prism reserves the right to update or otherwise change this Privacy Policy from time to time in order to reflect changes to our practices or for other operational, legal or regulatory reasons. Any such updates or changes will be effective immediately upon being posted, unless otherwise stated in the change. To the extent required by law, we will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account, by placing a prominent notice on our site, or by placing a modified version of the Privacy Policy at this webpage location updating any privacy information on this page. Your continued use of the Properties and/or services available through the Properties after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.

Contacting Us

Prism welcomes your questions or comments regarding this Privacy Policy. If you need to contact Prism with respect to this Privacy Policy, and/or believe that Prism has not adhered to this Privacy Policy and wish to make a complaint, please contact Prism at:

Prism Interactive, Inc.
Subject: Privacy Policy Inquiry
Email Address: legal@prisminteractive.a