Privacy Policy

EFFECTIVE DATE: December 10, 2024

Studio71, LP (“Studio71,” “we” or “us”) is a media company for leading digital content creators (“Creators”) and brands.  We publish and distribute original and syndicated content (“Content”) across multiple platforms, provide ad delivery and optimization services to leading brands and advertisers, help Creators manage, promote and monetize Content and digital channels, and develop and produce Content (our “Services”).

Studio71 understands the importance of privacy and transparency. This privacy policy (“Policy”) describes how Studio71 collects, uses, discloses and otherwise processes the personal data described in this Policy, as well as the rights and choices individuals have regarding such personal data. If you are a resident of California, please also review our California Privacy Statement (Section 12.B of this Policy), for information about the categories of personal data we collect and your rights under California privacy laws.

Table of Contents

 

1. Scope and Background

Except as otherwise noted below, this Policy applies to the personal data that Studio71 collects and processes related to:

    • Users of our websites, including www.studio71.com/us/, mobile apps, and online services where this Privacy Policy is posted (collectively, our “Site”);
    • Our Services and the Content we publish and distribute, including data about individuals that access, view, or interact with Content or ads that we distribute or publish (each an “End User”), to the extent we collect their personal data;
    • Creators, including Creators that we work with and prospects;
    • Current, former and prospective customers, vendors and business partners;
    • Individuals who receive news, information and marketing communications from us, register for or participate in events we sponsor, or respond to surveys, and research we conduct; and
    • Individuals that communicate opt-with us or otherwise engage with us related to our Site or Services.

This Policy does not apply to the personal data that we collect and process about Studio71 employees and personnel or job applicants and candidates.

In some cases, additional or supplemental privacy notices (each an “Additional Notice”) may be provided and will apply to certain personal data collected and processed by us. The Additional Notice will control to the extent there is a conflict with this Policy, with respect to your personal data that is subject to that Additional Notice.

Our collection, use and disclosure of your personal data any dispute over privacy, is subject to this Policy and any applicable Additional Notices, as well as the Terms and Conditions of Use for our Site and any waiver, release or other agreement between you and Studio 71 related to our Services, our Site or the events, promotions or other products or services provided by us (collectively, the “Terms”), including any applicable limitations on damages and the resolution of disputes contained in such Terms.

2. Personal Data Collected

As further described below, we collect personal data directly from individuals, both Creators and End Users, as well as from third parties and automatically (e.g. via cookies on our website) related to the use of our Site or other interactions with us. Personal Data Collected Directly.  The personal data we collect from you depends upon your role as a Creator or an End User and how you use our Site, interact with our Content, or otherwise interact or engage with us, but generally includes:

      • Creator profiles and information. We collect account and registration information from Creators we work with, including name and email address, phone number and other contact information, user ID, information about social media handles and profiles, and, in some cases, third-party account credentials, such as login credentials for YouTube, Facebook, Twitter, TikTok and Instagram, or other third-party social media sites and content platforms (“Third-Party Accounts”). We also collect other personal data Creators submit or provide to us, such as contact information, demographics, photos, preferences, and other content a Creator provides or chooses to make available to us (including through the Creator dashboard), which may include revenue, viewership, copyright strikes, and financial information. When Creators provide us access to their Third-Party Accounts so that we can help them manage their social media profiles and distribute and manage Content and ads, we may also access or receive information and content from those Third-Party Accounts (“Third-Party Account Information”).
      • End Users. End Users may access or view Content we manage or distribute on third party sites, social media platforms, streaming services and other third party platforms (collectively, “Third Party Platforms”), without registering or submitting personal data to us. We do not collect names, contact information, or other directly identifying information about End Users.  Generally, the information that we collect or receive about End Users is limited to aggregate information (e.g., how many End Users accessed certain Content or viewed certain ads). In some cases, we may collect or receive online identifiers, information about the Content or ads a particular End User accesses or views, and other information (as described further below) but we do not link this with name, contact information or direct identifiers.
      • Payments and purchases. We collect bank information, address, birthdate, or other payment information for Creators. We may also collect payment and billing information from our vendors and customers.
      • Communications, requests and interactions. We may collect and maintain records of communications and interactions we have with individuals (including Creators, customers and vendors), such as contact details, the content of the communication (including our responses) and the date and time. This includes transcripts and other records of communications and information that individuals submit in chat sessions and text communications or post or submit through our social media channels, as well as information provided in webforms and related to any customer support requests. We may also collect information about your preferences, including communications preferences and any other preferences or requests you provide when interacting with us.
      • Surveys, research, and other requests. We may collect personal data provided in response to surveys or questionnaires sponsored or conducted by us or on our behalf, such as our Podcast Sponsorship Profile or Podcast Survey.


    Personal Data Collected Automatically or Derived.  We automatically collect data (e.g., via cookies, pixels and similar tools) through our Site, and we may also derive personal information about Creators and End Users. Such information includes:

    • Device and browsing information. We use cookies, log files, pixel tags and other tracking technologies (some of which are provided by third parties) to collect information about users of our Site, such as IP address, general location information (e.g., derived from your IP address), domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring and exiting URLs, operating system, language, clickstream data and similar device and usage information. For more information, see Section V. Cookies and Tracking, below.
    • Profiling information. We also derive information about Creators (e.g., based on their social media profiles and Content) and End Users (e.g., based on the Content accessed), such as preferences, age, the Content, products or services they may be interested in, and other personal characteristics. We do this so that we can better tailor ads and Content recommendations, prepare aggregate reports and metrics, and improve our Services.

Personal Data from Other Sources. We may collect personal information about you from third party sources, such as public databases, joint marketing partners, social media platforms or other third parties.

      • Third Party Platforms. When End Users access or view Content through Third Party Platforms, we may receive data about End Users and their device from the relevant third party operator, as well as our vendors or service providers that we work with to distribute Content and ads through these Third Party Platforms, including country/location, user ID, online identifier, device information, viewing info.
      • Analytics and advertising companies. We also work with third party analytics, ad networks and others to target, measure and show ads through Third Party Platforms and to collect analytics and metrics about our Content. The advertisers and ad services may also collect, and in some cases provide us with, data about End Users related to ad delivery and measurement (e.g., IP addresses, device IDs, IFAD), online activities and demographic information. We may also work with these third parties to collect information about visitors to our Site and target and measure our own ad campaigns to Site users and prospective customers and Creators on third party sites.
      • Social media sites. If you post information about Studio71 or the Creators we work with, or engage with us or our Creators, on social media platforms and other sites, we may collect personal information about you from those third-party sites and platforms. The operators of these sites and platforms control the information they collect and share about their users. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.
      • Publicly available data and other data sources. We may also engage with third parties to enhance or update our customer information and to collect information about prospective customers and Creators, including information customers and Creators post and share on social media and other websites, as well as personal information from public sources and other publicly available data.

     

    3. Purposes of Collection and Processing

    Generally, we collect, use and otherwise process the personal data we collect for the following purposes:

      • To provide our Services. We use the personal data we collect to provide our Services, including to manage, distribute and promote Content, work with third parties to deliver ads through our content, and collect analytics and measurement data about Content and ad performance.
      • Services and support. To communicate with Creators and others, respond to inquiries, fulfill your requests, process your payments, communicate with you, and for similar service and support purposes.
      • Analytics and improvement. To better understand how users access and interact with our Site and Content, and for other research and analytical purposes, such as to evaluate and improve our services and business operations, to develop services and features, and for internal quality control and training purposes.
      • Marketing and advertising. For marketing and advertising purposes. For example, to send prospective Creators and customers information about our Services. We also may use personal data collected to target and measure our ad and marketing campaigns and to otherwise manage and improve our marketing and advertising campaigns so that we can reach you with more relevant Content and ads, including ads and Content that are targeted to your likely interests and preferences and that include more relevant content and information.
      • Security and protection of rights. To protect our business and operations, as well as the Site and other products or services we provide and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms and Conditions of Use or this Policy.
      • Legal proceedings and obligations. To comply with the law and our legal obligations, to respond to legal process and related to legal proceedings.
      • General business and operational support. To consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions, and related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions.



    4. Disclosures of Personal Data

    We may disclose the information, including personal data, that we collect to others, as reasonably necessary for the purposes described above and as otherwise directed or authorized to by you, which may include:

      • Vendors and service providers. To vendors, service providers, contractors, or agents who process such information on our behalf, in order to provide services to us or perform functions on our behalf, including IT service providers, content delivery networks, analytics providers, and data providers that that we work with to enhance our data.
      • Affiliates and subsidiaries. To our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal data will be subject to this Policy.
      • Business Partners. We may share personal data about current, prospective and former Creators with third parties with whom we have a business relationship. These third parties may also use this information to contact Creators directly about potential services, products, offerings and other promotional or commercial content. You can opt out of our sharing for these purposes by contacting us at legal@studio71us.com.
      • Third Party Platforms. If you access Content through Third Party Platforms, websites and other devices, we may disclose certain information to them, including information activity and usage data, IP address, device identifier, preferences and privacy settings, in order to deliver Content and personalize ads to you. Depending on what Third Party Platform services you use, we may also share information so that content and features available from us can be suggested to you in the Third Party Platform’s user interface.
      • Advertisers, ad networks and ad partners. To advertisers, ad networks and other advertising partners (“ad companies”), as well as Platform Operators, that we work with show you ads that may interest you—including ads on behalf of brands and other customers that we work with. In some cases, these third parties may set and access their own cookies, pixel tags and similar technologies within Content or on our Site and have access to information about you which they collect over time and across different online services and devices; these third parties help us understand the effectiveness of ad campaigns, including the audience that viewed the ads and how they responded, as well as the popularity and relevance of Content. These third parties may collect or receive information about your viewing of or interaction with our Content and ads on Third Party Platforms.
      • Protecting rights and interests. To law enforcement and others where we believe doing so is necessary to protect the Site, Services and Content, as well as our rights and property, or the rights, property and safety of others. For example, in order to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse; (ii) situations involving potential threats to the health, safety or legal rights of any person or third party, or (iii) enforce, and detect, investigate and respond to violations of, our Terms and Conditions of Use. We may also disclose personal data, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
      • Legal compliance. To regulators, law enforcement and other third parties in order to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding, in response to a subpoena, warrant, court order or other legal process, or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.
      • Business transfers. We may disclose your information to another entity in connection with an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer, including during negotiations related to such transactions.


    Aggregate and Non-identifiable Information. We may share aggregated information derived from the personal data we collect, that does not identify or refer to any particular individual. Where we have committed to maintaining and using personal data in a deidentified form, we agree not to reidentify deidentified data except as permitted by applicable law.

    5. Cookies and Tracking

    We and our third-party service providers use cookies, pixels, java script, log files, and other mechanisms to automatically collect information browsing, activity, device and similar information on our Site and within our Content. We use this information to, for example, analyze and understand how users access, use and interact with Content, our Site and ads, as well to identify and resolve bugs and errors and to assess secure, protect, optimize and improve the performance of our Site and Services. You have certain choices about our use of cookies within the Site as described in this section.  For more information on the types of personal data we collect via cookies and similar mechanisms, please see Section 2. Personal Data We Collect.

    Cookies. Cookies are alphanumeric identifiers that we transfer to your device. Some cookies make it easier to navigate our Site, while others allow us to track your activities in our Site, support the security and performance of the Site, or allow us to track activity and usage data within Service.

    Pixel tags. Pixel tags (sometimes called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Site and Content to, among other things, track the activities of users, help us manage content and compile usage statistics. We may also use these in HTML e-mails we send, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

    Third-Party analytics and tools. We use third party tools, such as Google Analytics, to evaluate usage of our Site and Services and to help us improve performance and user experiences. These third-party tools may use cookies and other tracking technologies, such as pixel tags, to perform their services. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout. Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt out of targeted advertising by following the instructions in the “Third-Party Ad Network” section.

    6. Advertising and Targeting

    We work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“third-party ad companies”) to personalize content and display advertising on our Site and/or in our Content (including our websites), as well as to manage our advertising on third-party sites, mobile apps and online services. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect activity information related to our Site and Content, as well as IP address, location information, unique ID, cookie and advertising IDs, and other identifiers.  We and these third-party ad companies use this information to provide you more relevant ads and content within our Content and on third-party sites and apps, and to evaluate the success of such ads and Content.

    Ad Preferences. We make available several ways for you to manage your preferences regarding third-party advertising and cookies on our Site.  Most of these technologies are browser and/or device specific, which means that you need to set the preference for each browser and each device you use to access our Site; in addition, if you delete or block cookies, you may need to reapply these preferences.  Further, opting out of cookies and advertising as discussed below does not mean that you will no longer receive advertising content from us. You may continue to receive generic or “contextual” ads from us.

      • Cookie preference manager. You can review or change your preferences for targeting cookies and tags on our websites by adjusting your cookie settings. In addition, our website responds to “global privacy control” signals—or GPC—which means that if we detect a browser GPC signal, we will apply that to opt out that browser from certain third-party cookies on our website.  See Section. 12 Additional Privacy Information for Certain Jurisdictions, below, for more information about GPC.
      • Industry ad choice programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our websites and use of our mobile applications, and those of third parties, in order to display more relevant targeted advertising to you. You can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at https://aboutads.info/choices(Digital Advertising Alliance). You may also download the DAA AppChoices (https://youradchoices.com/appchoices) tool in order to help control interest-based advertising on apps on your mobile device.
        • Please note that opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or contextual ads. You may also continue to receive targeted ads from companies that do not participate in the above programs.
      • Browser settings and controls. If you wish to prevent cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to Site who disable cookies will be able to browse the Site, but some features may not function.
      • Social Media. Our website and mobile application may include social media features, such as Instagram, Facebook, Twitter, and LinkedIn widgets. These features may collect electronic and other internet activity information, such as your IP address and which page you are visiting on our website. These widgets may set a cookie or utilize other tracking technologies to accomplish this. Social media features and widgets are hosted by a third party and your interactions with those features are governed by the privacy policies of the companies that provide them.
      • Custom Lists and Matching. Unless you have opted out, we may share certain hashed customer list information (such as your name, email address and other contact information) with third parties so that we can better target ads and content to our users, and others with similar interests, within third party sites, platforms and services. You may opt out of being targeted by us in this manner, as set forth in Section VII. Your Privacy Choices.


    7. Your Privacy Choices

    You have certain choices regarding our processing of your personal data.  For example:

      • Marketing communications. You can opt out of receiving marketing emails from us by using the unsubscribe link in the footer of each marketing email we send to you.
      • Cookie preferences. You can review or change your preferences for non-essential, third-party cookies and tags on our website, other than those that are necessary to operation and functionality, by adjusting your cookie settings.  These preferences are browser and devices specific.  So, you will need to set your preferences for each browser and device you use, and if you subsequently delete or block cookies you may need to reapply these settings.  You may also adjust your advertising preferences as set forth in Section VI. Advertising and Targeting.
      • Updates. You can update much of the personal data we maintain about you, by contacting us using the information listed in Section IX. ‘Contact Us’ below.

    For more information about our privacy practices and your privacy choices, you may contact us as set forth in the ‘Contact Us’ section below.

    8. Children

    Our Site and Services are not designed for children, and we do not knowingly collect personal data from children. If we discover that a child under 13 has provided us with personal data in violation of applicable law, we will delete such information from our systems. If you’re a parent or guardian and you believe we have collected your child’s information in violation of applicable law, please contact us as set forth below, in Section IX. ‘Contact Us’

    9. Security

    We have implemented safeguards that are intended to protect the personal data we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

    10. Changes to this Policy

    This Policy is current as of the Last Updated date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. If we make material changes to how we collect, use and disclose the personal data we have previously collected about you, we will post prominent notice on our Site.

    11. Contact Us

    If you have questions about this Policy or our privacy practices, you may contact us at legal@studio71us.com.

    12. Additional Privacy Information for Certain Jurisdictions

    Residents of certain states have additional rights under applicable privacy laws, as described in this section. If you are a resident of California, please review Section 14.B below for additional information about the categories of personal data we collect about you and your privacy rights under applicable California privacy laws. Please review Section 14.A below for additional information about rights residents of other U.S. states. may have under applicable state privacy laws.


    A. Certain State Privacy Rights
    Consumers who are residents of certain U.S. states (including Virginia, Colorado, Connecticut and Utah) may have additional rights under applicable privacy laws, subject to certain limitations, including:

    • Correction: to correct inaccuracies in their personal data, taking into account the nature and purposes of the processing of the personal data.
    • Deletion: to delete their personal data provided to or obtained by us.
    • Access: to confirm whether we are processing their personal data and to obtain a copy of their personal data in a portable and, to the extent technically feasible, readily usable format.
    • Opt-Out: to opt out of certain types of processing, including:
      • to opt out of the “sale” of their personal data.
      • to opt out of targeted advertising by us.
      • to opt out of any processing of personal data for purposes of making decisions that produce legal or similarly significant effects.
    • Appeal: to appeal our denial of your privacy request, which you can do by submitting a request through our legal@studio71us.com or submitting a request to us online Section 7. Your Privacy Choices, for additional information about the privacy choices we provide and how to exercise them.) We will respond to your request as required under the applicable privacy law(s).

      B. California Privacy Statement

      Below, we provide information, as required under California privacy laws, including the California Consumer Privacy Act and its implementing regulations, each as amended (together, the “CCPA”), which require that we provide California residents certain specific information about how we handle their personal information, whether collected online or offline. This section does not address or apply to our handling of publicly available information made lawfully available by state or federal governments or other personal information that is subject to an exemption under California privacy laws.

      Categories of Personal Information We Collect. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The table below sets out generally the categories of personal information (as defined by the CCPA) about California residents that we may collect and disclose to others for a business purpose or commercial purpose. In addition to the categories of third parties set forth below, we may disclose personal information to others where required by applicable law.  

      Category  Description Categories of Third-Party Disclosures for Business or Commercial Purposes
      Identifiers Includes direct identifiers, such as name, alias, user ID, username, account number or unique personal identifier; email address, phone number, address and other contact information; IP address and other online identifiers.  
      • Vendors and service providers
      • Advisors and agents
      • Government entities and law enforcement
      • Affiliates and subsidiaries
      • Advertising networks
      • Data analytics providers
      • Social networks
      • Internet service providers
      • Operating systems and platforms
      Government Identifiers In certain instances, we may also collect SSN, driver’s license number, passport number, tax ID and other government identifiers (such as where necessary to verify identity or comply with our legal obligations).
      • Vendors and service providers
      • Advisors and agents
      • Government entities and law enforcement
      • Affiliates and subsidiaries
      • Social networks
      Customer Records Includes your account and profile information, such as username and password, email, address, telephone number, and other contact information, account credentials, communications preferences, billing and payment information, and other information individuals provide us in order to register for our Services.
      • Vendors and service providers
      • Advisors and agents
      • Government entities and law enforcement
      • Affiliates and subsidiaries
      • Data analytics providers
      • Social networks
      Commercial Information Includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. [For example, this may include demographic information that we receive from third parties in order to better understand and reach our customers or identify prospective customers.]
      • Vendors and service providers
      • Advisors and agents
      • Government entities and law enforcement
      • Affiliates and subsidiaries
      • Data analytics providers
      • Social networks
      Internet and Electronic Network Activity Information Includes browsing history, clickstream data, search history, access logs, information regarding your interactions with our Site, Content, marketing emails and ads, and other and other usage data.
      • Vendors and service providers
      • Advisors and agents
      • Government entities and law enforcement
      • Affiliates and subsidiaries
      • Advertising networks
      • Data analytics providers
      • Social networks
      • Internet service providers
      • Operating systems and platforms
      Geolocation Data Includes location information about a particular individual or device.
      • Vendors and service providers
      • Advisors and agents
      • Government entities and law enforcement
      • Affiliates and subsidiaries
      • Social networks
      Audio, Video and Electronic Data Includes audio, electronic, visual, or similar information, photographs and images, call recordings (e.g., of customer support calls), and CCTV footage (e.g., collected from visitors to our offices).
      • Vendors and service providers
      • Advisors and agents
      • Government entities and law enforcement
      • Affiliates and subsidiaries
      • Advertising networks
      • Data analytics providers
      • Social networks
      • Operating systems and platforms
      Professional Information Includes professional and employment-related information such as current and former employer(s) and position(s), business contact information and professional memberships.
      • Vendors and service providers
      • Advisors and agents
      • Government entities and law enforcement
      • Affiliates and subsidiaries
      • Social networks
      Education Information Information about an individual’s educational history, such as the schools attended, degrees you were awarded, and associated dates.  For example, we may collect current grade and school of registrants and participants in our training and other programs.
      • Vendors and service providers
      • Advisors and agents
      • Government entities and law enforcement
      • Affiliates and subsidiaries
      • Social networks
      Protected classifications We collect some information that may be considered a protected classification under California/federal law, such as your gender, date of birth, marital status, and disability status.
      • Vendors and service providers
      • Advisors and agents
      • Government entities and law enforcement
      • Affiliates and subsidiaries
      • Social networks
      Inferences Includes inferences drawn from other personal information that we collect to create or derive information that reflects your preferences, characteristics, behavior, attitude and abilities.
      • Vendors and service providers
      • Advisors and agents
      • Government entities and law enforcement
      • Affiliates and subsidiaries
      • Advertising networks
      • Data analytics providers
      • Social networks
      Sensitive personal information In limited circumstances, we may collect personal information that is considered sensitive personal information under the CCPA, and government identifiers, such as Social security number, driver’s license or state identification card number, or passport number (as described above).
      • Vendors and service providers
      • Advisors and agents
      • Government entities and law enforcement
      • Affiliates and subsidiaries
      • Social networks


    Sales and Sharing. California privacy laws define a “sale” as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” (as defined by the CCPA) Identifiers, Customer Records, Commercial Information, and Usage Data to third-party advertising networks, analytics providers, and social networks. We do not sell or share sensitive personal information, nor do we sell or share any personal information about individuals who we know are under sixteen (16) years old.


    Sources of personal information. In general, we may collect the categories of personal information identified in the table above directly from you and through the following categories of sources:

      • Our affiliates and subsidiaries
      • Third-party platforms
      • Third-party sites and services
      • Ad networks
      • Analytics providers
      • Social networks
      • Internet service providers
      • Operating systems and platforms
      • Our vendors and service providers


    Purposes for Collecting and Disclosing.  As described in more detail in Section 3. Purposes of Collection and Use, in general, we collect and otherwise process the above personal information as directed or authorized by you and for the following business or commercial purposes:

      • To provide our Services
      • Services and support
      • Analytics and improvement
      • Marketing and advertising
      • Security and protection of rights
      • Legal proceedings and obligations
      • General business and operational support


    Sensitive personal information. Notwithstanding the purposes described above, we do not use or disclose sensitive personal information beyond the purposes authorized by the CCPA.  Accordingly, we only use and disclose sensitive personal information as reasonably necessary (i) to perform our services requested by you, (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents, (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct, (iv) to verify or maintain the quality and safety of our services, (v) for compliance with our legal obligations, (vi) to our service providers who perform services on our behalf, and (vii) for purposes other than inferring characteristics about you.

    Retention.  We retain the personal information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection.  For example, we will retain your transactional data for as long as necessary to comply with our legal, tax, accounting and recordkeeping obligations, as well as an additional period of time as necessary to protect, defend or establish our rights, and defend against potential claims.

    CCPA Rights. California residents have the following rights (subject to certain limitations) under the CCPA:

      • Opt out of sales and sharing: to opt-out of our sale and sharing of their personal information.
      • Limit uses and disclosures of sensitive personal information: to limit certain uses or disclosures of sensitive personal information to those uses authorized by the CCPA.
      • Deletion: to request deletion of their personal information, subject to certain exceptions.
      • To know/access: to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.
      • Correction: to request correction of inaccurate personal information.
      • Non-discrimination: not to be subject to discriminatory treatment for exercising their rights under the CCPA.

Submitting CCPA Requests to Know, Correct and Delete. California residents may submit a verifiable request to exercise their CCPA rights as set forth below:

When you submit a request to know, to delete or to correct we will take steps to verify your request by matching the information provided by you with the information we have in our records. To verify your request, we will request that you provide us with your name and contact details and to confirm your email address. In some cases, we may request additional information in order to verify your request or where necessary to process your request.

Authorized agents may initiate a request on behalf of another individual by contacting us in writing at the contact information set forth above. Authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent. We will respond to verifiable requests received from California residents as required by law. If we are unable to adequately verify a request, we will notify the requestor.


Requests to Opt-Out of Sales and Sharing.California residents may submit requests to opt out of “sales” and “sharing” (e.g., targeted advertising) of their personal information via our Contact Us Page or by emailing us at legal@studio71us.com. In addition, our website responds to global privacy control—or “GPC”—signals, which means that if we detect that your browser is communicating a GPC signal, we will process that as a request to opt that particular browser and device out of sales and sharing (i.e., via cookies and tracking tools) on our website. Note that if you come back to our website from a different device or use a different browser on the same device, you will need to opt out (or set GPC for) that browser and device as well. More information about GPC is available at https://globalprivacycontrol.org/.

Rights Under California’s Shine-the-Light Law. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email legal@studio71us.com, make sure to include in your request a current California address and your attestation that you are a California resident.