Effective Date: January 23, 2020

Welcome to The Intercept, a service of First Look Media Works, Inc. (“First Look,” “we,” “our” or “us”). At The Intercept, we believe in protecting the privacy of our readers. We seek to be fully transparent with users about our data practices and their privacy implications. We encourage you to review our Privacy Philosophy and our Donor Privacy Practices, but this Privacy Policy officially governs our information practices and procedures whenever you visit use the Services (defined below) in any way.

This Privacy Policy describes the circumstances under which we collect, use, and share information about you through your use of The Intercept website available at https://theintercept.com/ and related mobile applications (the “Services”). This Privacy Policy does not apply to non-First Look websites and mobile applications that may link to the Services or be linked to or from the Services; please review the privacy policies on those websites and applications directly to understand their privacy practices.

To the extent there is a conflict between this Privacy Policy and our Privacy Philosophy or Donor Privacy Practices, this Privacy Policy will control. This Privacy Policy includes specific disclosures and additional rights for residents of the European Economic Area and Switzerland, as well as California, as set forth in the sections entitled “Your California Privacy Rights” and “Your European Privacy Rights” below.

By using the Services, you agree to our collection, use, and disclosure practices, and other activities as described in this Privacy Policy and our Terms of Service. If you do not agree, discontinue use of the Services. If you have any questions about this Privacy Policy, please contact us as set forth in “Contact Us” below.

1. COLLECTION AND USE OF YOUR INFORMATION

We collect information that you voluntarily supply to us while using the Services. The types of information that we request from you are set forth throughout this Privacy Policy.

In addition, we automatically collect information from your device through Tracking Technologies (defined below). Some examples of information we automatically collect include the following:

Device connectivity and configuration data, including the type of device you’re using (computer, mobile phone, tablet, etc.), the operating system running on that device, the type and version of browser software you’re using, the resolution of your computer monitor or other device display, and the screen colors available on your device.

Service use data, including data about the features you use, the pages you visit, the emails you view, the website that referred you, the time of day you browse, and your exiting pages.

Imprecise location data (e.g., location derived from an IP address or data that indicates a city or postal code level).

Device identifiers, including your IP address.

The Services may embed content from, or link to third party websites, locations, platforms, or services. We are not responsible for and make no representations regarding the policies or business practices of any third parties. Additionally, this Privacy Policy does not govern these third party’s content or services, and we encourage you to familiarize yourself with and consult their privacy policies and terms of use.

A list of these third parties used in connection with the Services, which may be updated from time to time, is available here. This list may not be exhaustive, and will change over time – we encourage you to check back periodically to see the most current list.

Below are the circumstances under which we will collect data from you on the Services, and how we will use and share that data. There may be other circumstances under which we will collect data from you, and in such circumstances, we will disclose to you at the time of collection how we will use and share your data.

Newsletters.

If you sign-up for our newsletter, we and our Service Providers (defined below) will collect (1) your email address and (2) information from your device relating to your receipt and viewership of any newsletters, including through Tracking Technologies. We and our Service Providers use this information to:

Send newsletters to your email address;

Send technical notices, updates, security alerts, and policy changes to your email address;

Understand how users engage with our newsletters and help us improve content in our newsletters and on the Services;

Prevent and address fraud, breach of policies or terms, and threats or harm;

Fulfill any other purpose disclosed to you at the time you provide the information or with your consent; and

Use for the maintenance and improvement of the Services.

Donations and Membership.

If you donate to The Intercept, we and our Service Providers will collect your first and last name, zip code, postal address, email address, donation amount, reason for donating, billing information, and payment card information. We and our Service Providers use this information to:

Facilitate your transaction, including processing and storing your payment card information;

Send technical notices, updates, security alerts, and policy changes to your email address;

Send newsletters, reports, stories, event invites, event discounts, and thank you letters to your email address;

Send exclusive products and thank you letters to your mailing address;

Provide you access to our in-person and online events and membership only content;

If you give $1,000 or more in a given year, publish your name on the Services and in our annual report. We do this because we believe it is important as a news organization to be transparent about our sources of funding. This disclosure threshold is also in keeping with standards set by certain of our third party donor partners. If you do not wish to have your name published, we invite you to donate at a level below $1,000;

Make your donation information visible to select agents, affiliates, and staff. We keep both of these groups as small as possible and strive to control access within our organization and in the relationships we establish;

Use for the maintenance and improvement of the Services;

Prevent and address fraud, breach of policies or terms, and threats or harm; and

Fulfill any other purpose disclosed to you at the time you provide the information or with your consent.

Comments.

If you leave a comment on any story, feature, or document on the Services, we and our Service Providers will collect your name, email address and comment content, as well as information from your device, including through Tracking Technologies. We and our Service Providers use this information to:

Send technical notices, updates, security alerts, and policy changes to your email address;

Understand how users engage with our content and help us improve content on the Services;

Contact you for the purposes of newsgathering;

Use for the maintenance and improvement of the Services;

Prevent and address fraud, breach of policies or terms, and threats or harm; and

Fulfill any other purpose disclosed to you at the time you provide the information or with your consent.

Keep in mind that any information you choose to include in comments can be seen, collected, and used by the public and your browsing activity and comments may also be collected by third parties using Tracking Technologies as described in more detail in this Privacy Policy.

Social Media Sharing.

If you like or share any stories, features, or documents through a third party social media service sharing tool available on the Services, we and our Service Providers will collect information about you in connection with your post, which may include information from your device, including through Tracking Technologies. We and our Service Providers use this information to:

Display and manage your post on the Services;

Understand how users engage with our content and help us improve content on the Services;

Use for the maintenance and improvement of the Services;

Prevent and address fraud, breach of policies or terms, and threats or harm; and

Fulfill any other purpose disclosed to you at the time you provide the information or with your consent.

The third party social media service that you interact with will also collect information associated with your post, including through Tracking Technologies.

Videos and Podcasts.

If you to watch any videos or listen to any podcasts through a third party video or podcast tool available on the Services, we and our Service Providers will collect information about you in connection with your use of the third party tool, which may include information from your device, including through Tracking Technologies. We and our Service Providers use this information to:

Manage that content on the Services;

Understand how users engage with our content and help us improve content on the Services, including any videos and podcasts we develop;

Use for the maintenance and improvement of the Services;

Prevent and address fraud, breach of policies or terms, and threats or harm; and

Fulfill any other purpose disclosed to you at the time you provide the information or with your consent.

The third party video or podcast service with which you interact will also collect information from your device, including through Tracking Technologies. Please note that when our content is hosted on a third party video or podcast services, we cannot limit access by third parties to your information. If you choose to access our content outside of the Services, you do so at your own risk.

Documents.

On some pages within the Services, we embed content from third party document services. If you view any content through a third party document service tool, we and Service Providers will collect information from your device, including through Tracking Technologies. We and our Service Providers use this information to:

Manage the content on the Services;

Understand how users engage with our content and help us improve content on the Services;

Use for the maintenance and improvement of the Services;

Prevent and address fraud, breach of policies or terms, and threats or harm; and

Fulfill any other purpose disclosed to you at the time you provide the information or with your consent.

The third party document service with which you interact will also collect information from your device, including through Tracking Technologies. Please note that when our content is hosted on a third party document service, we cannot limit access by third parties to your information. If you choose to access our content outside of the Services, you do so at your own risk.

Data Analytics.

On some pages within the Services, we and our Service Providers collect information about how you navigate the Services. If you access or view these pages, we and our Service Providers will collect information from your device, including through Tracking Technologies. We and our Service Providers use this information to:

Monitor and analyze trends, usage, and activities;

Improve the Services and other First Look websites, applications, marketing efforts, products and services;

Use for the maintenance and improvement of the Services;

Prevent and address fraud, breach of policies or terms, and threats or harm; and

Fulfill any other purpose disclosed to you at the time you provide the information or with your consent.

Accelerated Delivery of Services

On some pages within the Services, we use services to accelerate the delivery of our web pages, images, and other content. If you access or view these pages, we and our Service Providers will collect your information from your device, including through Tracking Technologies. We and our Service Providers use this information to:

Manage, deliver, and improve the functionality of the Services and content therein;

Use for the maintenance and improvement of the Services;

Prevent and address fraud, breach of policies or terms, and threats or harm; and

Fulfill any other purpose disclosed to you at the time you provide the information or with your consent.

Shortened URLS.

On some pages within the Services, we provide shortened uniform resource locators (URLs: the “addresses” of individual web pages) operated by third parties in order that our content can be shared more easily. If you click on one of these links, we and our Service Providers will collect information from your device, including through Tracking Technologies. We and our Service Providers use this information to:

Monitor and analyse trends, usage, and activities;

Improve the Services and other First Look websites, applications, marketing efforts, products and services;

Use for the maintenance and improvement of the Services;

Prevent and address fraud, breach of policies or terms, and threats or harm; and

Fulfill any other purpose disclosed to you at the time you provide the information or with your consent.

The third party link operator with which you interact will collect information from your device, including through Tracking Technologies.

Careers.

If you click on a job posting listed on the Services, you will be directed to a third party service’s website, and we and our Service Providers will collect your first name, last name, email address, phone number resume, cover letter, LinkedIn profile, and website, as well as information from your device, including through Tracking Technologies. We and our Service Providers use this information to:

Evaluate and process your job application;

Monitor and analyse trends, usage, and activities;

Improve the Services and other First Look websites, applications, marketing efforts, products and services;

Use for the maintenance and improvement of the Services;

Prevent and address fraud, breach of policies or terms, and threats or harm; and

Fulfill any other purpose disclosed to you at the time you provide the information or with your consent.

Email.

If you choose to email us, we and our Service Providers will collect information associated with your email, which may include the content therein and any information from your device, including through Tracking Technologies. Do not share any confidential information with us through this medium. If you want to share confidential information, please read and use Secure Communications (defined below) as set out here. We and our Service Providers may use any information that does not identify you from your emails in accordance with the broad rights you grant us in Section 5 of our Terms of Service. In addition, we and our Service Providers may use this information to:

Respond to your email and address your requests;

Improve the Services and other First Look websites, applications, marketing efforts, products and services;

Send technical notices, updates, security alerts, and policy changes to your email address;

Prevent and address fraud, breach of policies or terms, and threats or harm; and

Fulfill any other purpose disclosed to you at the time you provide the information and with your consent.

2. COLLECTION AND USE OF YOUR INFORMATION FROM OTHER SOURCES

We and our Service Providers may obtain information about you from other sources, and combine such information with information we have collected about you through the Services. To the extent we combine such third-party sources information with information we have collected about you on the Services, we will treat the combined information in accordance with this Privacy Policy. These third party sources vary over time, but have included third party donor partners and publicly available sources.

3. DISCLOSURE OF INFORMATION

Our agents, vendors, consultants, and other service providers (collectively “Service Providers”) may receive or be given access to your information in connection with their work on our behalf. These Service Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.

Further, with respect to all data collected as set forth in Section 1 above, we may share your information with third parties as set forth in Section 1 above and also where we have a lawful basis, including for the following purposes:

To investigate, prevent, or take action regarding illegal activities, intellectual property infringement, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of the Terms of Service;

To comply with the law, or respond to subpoenas, court orders, or other legal process, in which case we will notify you, as permitted by law, and cooperate with you to submit any lawful objections to such disclosure and/or to seek an appropriate protective order limiting disclosure of the information to that strictly required by law;

In connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business; and

To fulfill any other purpose disclosed to you at the time you provide the information or with your consent.

Donor information is also shared with our third party donor partners for purposes of those third parties providing advice, technology, and assistance to us for The Intercept membership program. We are not responsible for the policies, practices, or security of our third party donor partners.

If you use a third party video service in connection with the Services, you understand that the information such third party video service collects comes directly from you, and not us or our Service Providers, and that the third party video service may disclose the information its collects to other third parties. We are not responsible for such third party collection, use, and sharing.

4. TRACKING TECHNOLOGIES ON THE SERVICES

We and our Service Providers may collect and store your information in log files as well as through the use of cookies, web beacons (also known as “tracking pixels”), embedded scripts, and other tracking technologies now and hereafter developed (“Tracking Technologies”). The Tracking Technologies on the Services may include, without limitation:

Cookies. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. A cookie may be a session ID cookie or tracking cookie. Session cookies make it easier for you to navigate the Services and expire when you close your browser. Tracking cookies help in understanding how you use the Services, and remain longer. Cookies may remain on your hard drive for an extended period of time. You may generally disable or remove cookies by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. If you use your browser’s method of blocking or removing cookies, some features and functionalities of the Services may not work.

Web Beacons or Tracking Pixels. Web beacons are small graphic images, also known as “internet tags” or “clear gifs,” embedded in web pages and email messages. Web beacons may be used to provide information about how our visitors use the Services and how they interact with our email newsletters and with our stories that appear on other websites.

Embedded Scripts. An embedded script is programming code designed to collect information about your interactions with the Services. It is temporarily downloaded onto your device from our web server or a third party with whom we work, is active only while you are connected to the Services, and deleted or deactivated thereafter.

Third parties may also collect information from you using Tracking Technologies, and we are not responsible for and make no representations regarding their collection practices.

5. YOUR RIGHTS AND CHOICES

Accessing and Changing Your Information. You may access, update, or remove any information you have voluntarily supplied to us through the Services, by sending an email to us here. If such information has been collected by third parties through your use of the Services, you will need to contact those third parties about how to obtain access and or removal of such information. We may require additional information from you to allow us to confirm your identity.

However, we will not remove your name from our published lists if you give $1,000 or more in a given year on the Services. We also may not remove your information if it is published in any story, feature, or document on the Services to the extent your information was publicly posted in a Comment or obtained from sources outside of the Services.

Opting-Out of Collection, Use and Sharing. You can opt-out of certain data collection, use, and sharing, as specified below. However, please note that once we have shared your information, we will not be able to retrieve it. Also, the amount of time it will take to complete your request may vary based on the complexity of your request, and we may need to continue sharing your information in some instances.

To opt-out of receiving emails, follow the instructions as provided in any emails you receive to click on the unsubscribe link, or contact us here with the word UNSUBSCRIBE in the subject field of the email.

To opt-out of the use of Tracking Technologies on the Services by certain of our analytics Service Providers, please visit our list of third party opt-outs, which may be updated from time to time. We are not responsible for the effectiveness of any third party opt-outs. Additionally, you can limit the use of Tracking Technologies as explained in Section 4 above.

To opt-out of any specific use or sharing of your information, please email us here or send us a letter to First Look Media Works, Inc., 114 Fifth Ave, New York, NY 10011. In your opt-out request, you must specify the kinds of use and/or sharing by us from which you want to opt out. We will try, but cannot guarantee that we will honor all requests. Also, please note that we cannot control or opt you out of collection, use and/or sharing by third parties. Depending on the scope of your opt-out, certain features or content on the Services may no longer be accessible to you.

We may require additional information from you to allow us to confirm your identity.

Your California Privacy Rights.

Shine the Light. California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt-in to, or opt-out of, this type of sharing.

We do not share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please email us here, contact us at 855-818-6432 or send us a letter to First Look Media Works, Inc., 114 Fifth Ave, New York, NY 10011. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are not required to respond to requests made by means other than through the provided email address, 800 number or mail address.

California Residents under 18. Any California residents under the age of eighteen (18) who have posted content or information on the Services, can request that such information be removed from the Services by sending an e-mail to us here. Requests must state that the user personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view.

Special Information for California Residents. The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to access and control Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.

Right to Information Regarding the Categories of Personal Information Collected, Sold, and Disclosed

You have the right to receive information regarding the categories of Personal Information we collected, sold, and disclosed. This information is provided below in our Notice of California Consumer Data Collection and Sharing Practices.

Right to Access Information

You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request.

Right to Request Deletion of Information

You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Right to Information Regarding Participation in Data Sharing for Financial Incentives

You have the right to be free from discrimination based on your exercise of your CCPA rights. We do not have any rewards programs or other financial incentives.

Right to Opt Out of Sale of Personal Information to Third Parties

You have the right to opt out of any sale of your personal information by First Look to third parties. To exercise this right, please visit our “Do Not Sell My Personal Information” webpage. Please note that your right to opt out does not apply to our sharing of personal information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal information only for that function.

How to Submit a Request

You may submit a request to exercise your rights through any one of three means:

By filling out a Consumer Data Request Form available here. By calling us at 855-818-6432. By emailing us at mailto: [email protected] .

Notice of California Consumer Data Collection and Sharing Practices.

The following is a description of our data collection practices, including the personal information we collect, the sources of that information, the purposes for which we collect information, and whether we disclose that information to external parties. We may use any and all of the information for any of the purposes described in this Privacy Policy, unless limitations are listed. The categories we use to describe the information are those enumerated in the CCPA.

Personal Identifiers:

We collect your name, phone number, email address, and contact address when you complete a transaction, such as a donation, or sign up for our events or promotions.



We collect your email address when you sign up for our newsletter.



You provide us with payment information, which may be your credit card number or a bank account, when you complete a transaction. You have the option to store this information to your account or set up a recurring transaction.



We do not collect your social Security number, Driver’s License number, or Passport number.



We do not collect any medical information or health information about you.



We collect your IP address automatically when you use the Services.



We collect your Device ID automatically when you use the Services.

Protected Classifications: We collect your age in order to comply with laws that restrict collection and disclosure of personal information belonging to minors. We do not collect your gender, racial or ethnic origin, or sexual orientation.

We collect your age in order to comply with laws that restrict collection and disclosure of personal information belonging to minors. We do not collect your gender, racial or ethnic origin, or sexual orientation. Donation Information: When you engage in transactions with us, such as submitting a donation, we create records of the contribution you made, reason for the donation, as well as goods or services that may accompany your donation.

When you engage in transactions with us, such as submitting a donation, we create records of the contribution you made, reason for the donation, as well as goods or services that may accompany your donation. Comment Information: When you leave a comment on any story, feature, or document, we will post, display, and maintain your comment on our website.

When you leave a comment on any story, feature, or document, we will post, display, and maintain your comment on our website. Biometric Information: We do not collect information about your physiological, biological, or behavioral characteristics.

We do not collect information about your physiological, biological, or behavioral characteristics. Internet or Other Electronic Network Activity Information: We collect information about your browsing history, search history, viewing history, and information regarding your interaction with websites, applications, videos, or advertisements automatically when you utilize the Services.

We collect information about your browsing history, search history, viewing history, and information regarding your interaction with websites, applications, videos, or advertisements automatically when you utilize the Services. Geolocation Data: As described above, we collect your IP address automatically when you use the Services. We may be able to determine your general location based on the IP address. We do not collect your precise location (e.g., your GPS coordinates).

As described above, we collect your IP address automatically when you use the Services. We may be able to determine your general location based on the IP address. We do not collect your precise location (e.g., your GPS coordinates). Audio, electronic, visual, thermal, olfactory, or similar information: If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call. We do not collect your image or any thermal, olfactory, or similar information.

If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call. We do not collect your image or any thermal, olfactory, or similar information. Professional or employment-related information: If you apply for a job with First Look, we may collect name, contact information, cover letter, LinkedIn profile, and website, as well as information from your device.

If you apply for a job with First Look, we may collect name, contact information, cover letter, LinkedIn profile, and website, as well as information from your device. Education Information: If you apply for a job with First Look, we may collect information on the institutions you have attended, the level of education you have attained, your transcript, and writing samples.

If you apply for a job with First Look, we may collect information on the institutions you have attended, the level of education you have attained, your transcript, and writing samples. Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We may analyze your actual or likely preferences through a series of computer processes. On some occasions, we may add our observations to your internal profile.

We may share any of the above-listed information with Service Providers, which are external parties that we engage for business purposes and are restricted from using Personal Information for any purpose that is not related to our engagement. The categories of Service Providers with whom we share information and the services they provide are described in this our Privacy Policy.

On certain occasions, we also sell information to third parties. An external party may be considered a third party either because the purpose of sharing is not an enumerated business purpose under California law, or because our contract does not restrict them from using Personal Information for other purposes. To “sell” information means to disclose it to an external party for monetary or other benefit. We sell the following information:

Personal Identifiers: We provide your contact information to directory services providers and public safety authorities. We provide your IP address and Device ID to our analytics partners. If you make a donation, we provide your donor information to our third party donor partners. We may also disclose information to other external parties who are not listed here when required by law or to protect our Company or other persons, as described in this Privacy Policy.



Your European Privacy Rights. First Look, located at the address in the section entitled “Contact Us” below, is the controller with respect to personal data subject to this Privacy Policy. We process personal data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services; and (3) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedom related to data privacy. Personal data we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities, as described above.

If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you through the Services. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Services. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

To exercise any of these rights, contact us as set forth in “Contact us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

If you have any issues with our compliance, you have the right to lodge a complaint with a European supervisory authority.

6. CHILDREN

The Services are not directed at children under the age of 16 and we do not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe we have collected information in a manner not permitted by COPPA, please email us here or send us a letter to First Look Media Works, Inc., 114 Fifth Ave, New York, NY 10011, and we will remove such data to the extent required by COPPA.

7. DATA SECURITY

We employ practices designed to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, no physical or electronic security system is impenetrable. We cannot guarantee the security of our servers or databases, nor can we guarantee that information you supply will not be intercepted while being transmitted over the internet.

8. INTERNATIONAL TRANSFER

We are based in the United States and the information we collect is governed by United States law. Our databases are located within the United States and other jurisdictions. If you access the Services from outside the United States, you consent to transfer, processing, and storage of that data in the United States and other jurisdictions. Data protection laws in the United States and other jurisdictions may be different from those of your country of residence. If your data is collected in Europe, we will transfer your personal data subject to suitable safeguards, such as standard contractual clauses.

9. CHANGES TO THIS PRIVACY POLICY

We reserve the right to revise and/or reissue this Privacy Policy at any time. If we change this Privacy Policy in the future, we will post the revised Privacy Policy on the Services and update the “Effective Date,” above, to reflect the date of the changes. Any changes will be effective immediately upon posting of the revised Privacy Policy. By continuing to use the Services after we post such changes, you agree to the terms of this Privacy Policy, as modified.

10. CONTACT US

If you have any questions or comments about this Privacy Policy, or our compliance with applicable law, please contact us:

By email: [email protected]

By mail:

First Look Media Works, Inc.

Attn: Privacy

114 Fifth Ave

New York, NY 10011