Effective Date: June 6th, 2016

This privacy policy explains how Pilotly handles your personal information and data. We value your trust, so we’ve strived to present this policy in clear, plain language instead of legalese. The policy is structured so you can quickly find answers to the questions that interest you the most.

Pilotly is committed to respecting the privacy rights and concerns of all users of the Pilotly™ service provided on or through the website located at www.pilot.ly (the "Pilotly Site"), or on or through the software applications made available by Pilotly (we refer to the Pilotly Site and the software applications made available by Pilotly as the "Service Applications", and we refer to the Service Applications and the service provided through the Service Applications, collectively, as the "Pilotly Service"). Pilotly has established and implemented this Privacy Policy to help you make informed decisions when using the Pilotly Service. Pilotly may provide certain elements of the Pilotly Service to you through one or more of its affiliates. In this Privacy Policy, references we make to "Pilotly" (and "we", "us" and "our") means either Pilotly, Inc. By accessing or using the Pilotly Service you consent to Pilotly's collection, use, storage, deletion and disclosure of information relating to you as set forth in this Privacy Policy. The Pilotly Service interacts in a number of ways with third party social networking sites and services you have linked to your Pilotly account, such as Facebook or Twitter ("Social Networks"), or used to log in to the Pilotly Service. Your activities on your applicable Social Networks are covered by their respective privacy policies and terms of use. Please read these third party privacy policies and terms to find out how they collect and use your personal data. The Social Networks are made available by their respective corporate entities. This Privacy Policy is effective as of the date set forth above and is only applicable to the Pilotly Service and not to any other website or service that you may be able to access from any of our Service Applications. Please read our Terms of Service which, together with this Privacy Policy, govern your use of the Pilotly Service.

1. CONTACTING US


1.1 If you want to know what information we hold about you or if you have any other queries or complaints in relation to this Privacy Policy, the Pilotly Site and/or any content displayed on the Pilotly Site, our contact email is support@pilot.ly.
1.2 We provide customer service support through email and through our support pages on the Pilotly Site. In order to provide customer support, we may ask for your email address and other account information depending upon the nature of your support request. We only use information received from customer support requests, including email addresses and other account information, for customer support services and we do not transfer or share information obtained from support requests with any third parties (other than service providers that may be assisting us in providing services to you).

2. INFORMATION WE COLLECT


2.1 Registration and Your Account Information
2.1.1 Personal information means information that can be used to identify and contact you. You do not need to submit personal information to access the Service Applications or aspects of the Pilotly Service, but if you do not disclose certain personal information to us, you will not be able to access certain portions of the Pilotly Service.
2.1.2 To access the Service Applications or use certain aspects of the Pilotly Service, you will be directed to create new Pilotly log-in credentials or to use your existing log-in credentials through Facebook. By utilizing your Facebook log-in credentials to log into the Pilotly Service (including on or through any of the Service Applications), or by linking your Pilotly Service account with any Social Network account, you expressly authorize Pilotly to receive, and for Facebook and/or such Social Network to share, certain of your information that is available on or through your Facebook and/or Social Network account, including, without limitation, your profile information, friends' names, your photos, privacy settings and certain other information that may be disclosed to you (and authorized by you) during the log-in process; and to allow you to interact with your Facebook and/or other Social Network friends on the Pilotly Service. You also authorize Pilotly to generate and publish on your Facebook and/or other Social Network news feed or timeline actions you take on the Pilotly Service in accordance with this Terms of Service. If linked, you agree to allow Facebook and/or the applicable other Social Networks to receive information concerning the actions you take on the Pilotly Service.
2.1.3 When you view a movie, television episode or other content through the Pilotly Service, you authorize Pilotly to share and/or publicly display your viewing activity on or through: (i) the Pilotly Service; (ii) any Social Networks; and (iii) Pilotly's third party service providers, such as marketing service providers (the "Receiving Parties"). Pilotly will ask for your authorization each time you view, rent or purchase a movie, television episode or other content on or through the Pilotly Service if Pilotly intends to share and/or publicly display such viewing activity on or through the Receiving Parties. If you do not consent to the sharing and/or public display of your viewing activity, you may not be able to view the video content through the Pilotly Service. When you share information by way of the Pilotly Service, such activity is subject to Pilotly's Sharing Policy.
2.1.4 For clarity, as a result of your creation of a Pilotly account with your Facebook log-in credentials, and/or by linking your Pilotly Service account with any Social Network account, and/or by providing us certain additional information, we may obtain certain of your personally identifiable information, such as your name, email address, date of birth and gender, as well as various transaction related information, such as billing address and credit card number or other payment information, including any such information that you previously provided to Facebook or any other Social Network.
2.2 Log Information
2.2.1 We also keep track of your interaction with the Pilotly Service and any other users through our Service Applications. Specifically, our servers automatically record information that your browser (or our software applications) send whenever you interact with the Pilotly Service. This information includes your Internet Protocol address (IP address), your cookie ID, your browser type and version, which aspects of the Pilotly Service you use and when and how long you use them, and how you otherwise access the Pilotly Service.
2.3 Watching Movies and Television Programs
2.3.1 Our servers log and can identify what movies, television programs and other audiovisual materials you stream, how long you stream (watch) them, and where you watch them from (i.e., from the Pilotly Site, a mobile software application or other software application).
2.4 Buying and Renting Movies, Television Episodes and Other Content
2.4.1 Our servers log and can identify the movies, television episodes and other content that you purchase or rent and whether streams are successful.

3. HOW WE USE YOUR INFORMATION


3.1 As a general matter, we use the information that you provide to us or that we obtain from the Social Networks linked to your Pilotly Service account to process your user registration, and to provide, enhance and personalize the Pilotly Service. We use the information automatically collected by our servers to monitor and analyze how users use the Pilotly Service, and to maintain and improve the Service Applications and the Pilotly Service.
3.2 Specifically, we use the information that you provide to us (or that we obtain from any applicable Social Network) to:
(a) send you emails and newsletters (or otherwise communicate with you through the Pilotly Service) for the purpose of keeping you updated about (i) the Pilotly Service in general, (ii) the programming available on or through the Pilotly Service, and (iii) the features and functionality of the Pilotly Service and our Service Applications (including, without limitation, information about available software or Pilotly Service upgrades or updates);
(b) send you emails and newsletters (or otherwise communicate with you through the Pilotly Service) for the purpose of offering you upgrades, content and additional services for you to access, rent or purchase where you have consented to be contacted for such purposes;
(c) provide you with a more personalized experience based on your personal information and to otherwise improve your use of the Pilotly Site and the Pilotly Service;
(d) make available to you, and bill you for, your access to the Pilotly Service (including, without limitation, verifying the authorization of your credit card or other payment method before any purchase or rental of movies, television episodes or other content);
(e) verify your right to access premium services;
(f) track your use of the Pilotly Service, including without limitation, to track your access, streaming, purchases and rentals of movies, television programs and other audiovisual content for the purpose of paying royalties and license fees to third party providers (such as movie studios, television networks and other copyright holders and content distributors);
(g) communicate with you regarding your account and any customer service matters that may arise;
(h) respond to or confirm your requests or activity on the Pilotly Service;
(i) ask you to participate in surveys that help us make the Pilotly Service better;
(j) provide you with targeted advertising, promotions and special offers;
(k) better understand how our Pilotly Service is being used;
(l) help us quickly and efficiently respond to inquiries and requests;
(m) notify you of issues with the Pilotly Service and/or unusual account actions; and
(n) notify you and warn you of inappropriate conduct, and if necessary, to inform you of the suspension or termination of your account.

4. YOUR CHOICES ABOUT THE COLLECTION AND USE OF YOUR PERSONAL INFORMATION


Opting Out of Receiving Communications from Us
4.1 If, at any point in time, you are not interested in receiving emails, mailings or other announcements from us or our affiliates, you will be able to opt-out of receiving them by clicking on the specified link in any given email communication or by modifying your personal settings. Please note that you may not be able to unsubscribe from certain non-marketing related correspondence from us, including messages relating to your Pilotly account.
Control of Your Information
4.2 As an account holder, you may access and correct certain personal information that Pilotly holds about you by visiting your Profile page. If you interact with the Pilotly platform through a third party panel, you are not an account holder and your personal information is not held by Pilotly (please refer to the third party panel company's privacy policy). Some account holders and other individuals (including those whose information we receive under the EU-U.S. Privacy Shield and the U.S.-Swiss Safe Harbor) have certain legal rights to obtain information of whether we hold personal information about them, to access personal information we hold about them, and to obtain its correction, update, amendment or deletion in appropriate circumstances. For some information, these rights may be exercised through the My Account page mentioned above, and in all cases, requests to exercise these rights may be directed to our customer support team. These rights are subject to some exceptions, such as where giving you access would have an unreasonable impact on the privacy of other individuals. We will respond to your request to exercise these rights within a reasonable time and, where required by law or where we deem it otherwise appropriate and practicable to do so, we will honor your request.
4.3 You have the right to access, update and correct inaccuracies in your personal information in our custody or control, subject to certain exceptions prescribed by law. You can access and update most of your personal information through the use of the Pilotly Site. You may also request access, updating and correction of inaccuracies in other personal information we have in our custody or control by using the contact information provided above. Please note that Pilotly reserves the right to charge you to meet our costs in granting any data access request you make. To protect your privacy and security, we ask you to log in using your applicable log-in credentials before granting you access or allowing you to make any corrections or updates. You are responsible for maintaining the secrecy of your log-in credentials at all times.
Sharing of Information with Third Parties
4.4 We will not sell or rent your email address or any of your personal information. However, to operate the Pilotly Service, we may share your information in the following ways:
As Aggregated Data
4.4.1 we will share statistical and demographic information about our users and their use of the Pilotly Service (including on the Pilotly Site or through our Service Applications) with suppliers of content and potential affiliate partners. We may also disclose and otherwise use non-personally identifiable information about users. None of the above would include anything that could be used to identify you or to discover individual information about you;
With Service Providers
4.4.2 we do use third parties to manage portions of the Pilotly Service, facilitate our business (e.g. by hosting our servers), manage communications with you, or otherwise provide services to us in connection with the Pilotly Service. Where these third parties process information on our or your behalf, to the extent applicable, and require that they maintain reasonable security measures and do not use your information for any purpose other than to provide their services to us;
4.4.3 your personal information may be maintained and processed by our affiliates and other third parties who provide services on our behalf in the U.S. or other jurisdictions and you hereby consent to the transfer of your data to such other jurisdictions for this purpose;
As Otherwise Required
4.4.5 we will only share the personal information that we collect from you in the following circumstances, which may vary depending on where you reside and where your account originated:
Protection of rights
(a) if we have a good faith belief that: (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process anywhere in the world, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is appropriate to enforce the Terms of Service for the Pilotly Service, including any investigation of potential violations thereof, (iii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Pilotly Service, or (iv) such action is appropriate to protect the rights, property or safety of Pilotly, its employees, users of the Pilotly Service or others;
Asset transfers
(b) if we become involved in a merger, acquisition or other transaction involving the sale of some or all of our or our affiliates' assets or voting securities, user information, including personal information collected from you through your use of the Pilotly Service, may be included in the transferred assets or securities. Should such an event occur, we will use reasonable means to notify you, either through email and/or prominent notices on the Pilotly Service; and
Investigations
(c) you hereby grant Pilotly and its representatives the right to access your account and records as necessary to investigate any use of the Pilotly Service including, but not limited to, alleged violations of applicable laws and regulations, abuse, and/or harassment.

5. ADDITIONAL INFORMATION YOU SHOULD KNOW ABOUT THIRD PARTIES


5.1 This Privacy Policy does not cover the information practices of third party websites linked to the Pilotly Site or Pilotly Service. Although we encourage such third parties to adopt and follow their own privacy policies, we are not responsible for their collection and use of your personal information. You should refer to the privacy policies and terms of service of other websites or contact the respective webmasters of those websites to obtain information regarding their information collection, use and disclosure policies.
5.2 When you have clicked on a third party logo displayed on the Pilotly Site which links you to a different website, our Privacy Policy no longer applies and you must read the privacy policy of the third party site to see how your personal information will be handled on their website.

6. COOKIES


6.1 Like many websites, we employ "cookies" in certain areas of the Pilotly Site to allow us to make your online experience more convenient. Cookies are small bits of electronic information that a website sends to a visitor's browser and are stored on the visitor's hard drive. Where compatible, we also use local browser storage. We use the local storage and cookies for the following purpose:
(a) to store a user's log-in identity and password and automatically populate the log-in fields for you when you re-access the Pilotly Site;
Third Party Analytics
6.2 The Pilotly Site uses third party analytics tools. Some of these analytics tools use cookies to help analyze how users use the Pilotly Site. The information collected in the cookie about your use of the Pilotly Site (including your IP address) may be transmitted to and stored by the applicable analytics provider on servers in the United States or elsewhere. The analytics provider may use this information for the purpose of evaluating your use of the Pilotly Site, compiling reports on Pilotly Site activity for us and providing other services relating to Pilotly Site activity and Internet usage. The analytics provider may also transfer this information to other third parties where required to do so by law, or where such third parties process the information on the analytics provider's behalf. The analytics provider will not associate your IP address with any other data held by them.
6.3 You may refuse the use of cookies by selecting the appropriate settings on your browser, for more information about how to do this please consult the "Help" section of your browser. Please note that if you do set your browser to reject cookies you may not be able to use the full functionality of the Pilotly Service.
6.4 In addition, advertisers whose advertisements appear on the Site may use and place cookies on your computer and we have no control over this. Please consult the terms and conditions and privacy policy of such third party advertisers to find out how they collect and use your personal data and to establish whether they use cookies and what they may use them for.

7. SECURITY


7.1 The personal information you provide to us is stored on servers, which are located in secured facilities with restricted access, and protected by protocols and procedures designed to ensure the security of such information, including firewalls, password encryption and other password protection features. In addition, we restrict access to personal information to our employees, independent contractors and agents who need to know this information in order to develop, operate and maintain the Pilotly Service. All Pilotly personnel who have access to this information are trained in the maintenance and security of such information. Any bank account information and other user sensitive information you supply us is transmitted and protected via Secure Socket Layer technology ("SSL") and HTTPS protocol and then stored into the Balanced Payments databases using industry standard encryption methods to be accessed only as stated above.
7.2 You hereby acknowledge and agree that no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. As a result, that whilst we always strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us over or through the use of any of our Service Applications and we accept no liability for any breach of security or any unintentional disclosure, loss or misuse of any such information or data or for the actions of any third parties that may obtain any such information or data. You acknowledge and agree that you provide such information and engage in such transmissions at your own risk. Once we receive a transmission from you, we will endeavor to maintain its security on our systems.
7.3 We will store your personal information for so long as it is necessary to provide you our Pilotly Service and will periodically destroy any old personal information that we hold in relation to you in accordance with our company policies, including when it is no longer necessary in order to offer you the same high quality service. In most cases, we will keep one archival copy of your information to allow us to comply with laws or respond to legal processes. Following the termination of our relationship we will ensure that we destroy all of the personal information that we hold in relation to you within a reasonable period of time or when required by law.

8. CHILDREN'S PRIVACY


8.1 The Pilotly Service is not intended for children under the age of thirteen (13). We do not knowingly collect or maintain any personal information or non-personally-identifiable information from anyone under the age of thirteen (13) nor is any part of the Pilotly Site, Service Applications or Service directed to children under the age of thirteen (13). We will close any accounts we suspect are being used exclusively by such children and will remove and/or delete any personal information we believe was submitted by any child under the age of thirteen (13).
8.2 If you are under eighteen (18) years old, you may only use the Pilotly Service if you have obtained the consent of your parent(s) or other legal guardian. By using the Pilotly Service, you warrant that you are either eighteen (18) years old or that have obtained the consent of your parent(s) or other legal guardian to access the Service.

9. USING YOUR PERSONAL INFORMATION IN OTHER COUNTRIES


9.1 The Pilotly Service is hosted in the United States. Please be advised that through your continued use of the Pilotly Service, which is governed by United States law, this Privacy Policy and our Terms of Service, you may be transferring your personal information to the United States or at Pilotly's discretion, any other country of the world, and you hereby expressly consent to the transfer and processing of such information outside of the United States, as applicable. For the avoidance of doubt, any information we or you may share with any Social Network may be transmitted to and stored by such parties on servers in the United States.

10. DISPUTE RESOLUTION


10.1 In the event that you have any dispute or claim arising out of or relating to this Privacy Policy, you may report your claim to the Information Commissioner's Office.

11. CHANGES AND UPDATES TO PRIVACY POLICY


This Privacy Policy may be revised periodically and this will be reflected by the date above. Please revisit this page to stay aware of any changes. We only use your personal information in the manner described in the Privacy Policy in effect when we received the personal information you provided. Your continued use of the Pilotly Service constitutes your agreement to this Privacy Policy and any future revisions.

Sharing Policy

The Video Privacy Protection Act ("VPPA") requires that Pilotly (as defined in the Terms of Service) obtain your consent when Pilotly shares information about the movies, television episodes and other content you have watched, purchased or rented on or through Pilotly's online movie and television service (the "Pilotly Service" and the "Pilotly Platform"). In accordance with the VPPA, it is our policy to obtain your consent each time we intend to share and/or publicly display your viewing, purchase or rental activity (unless otherwise permitted by the VPPA), including but not limited to the name of the content you are watching, the time that you view such content, the location where you are viewing such content, other information related to the video content, such as a link to the content on the Pilotly Platform, and other information you choose to share about the content, such as a comment about the content (collectively, your "Viewing Activity"). IF YOU DO NOT CONSENT TO THE SHARING AND/OR PUBLIC DISPLAY OF YOUR VIEWING ACTIVITY, YOU MAY NOT BE ABLE TO VIEW THE VIDEO CONTENT THROUGH THE Pilotly SERVICE.
When you consent to Pilotly sharing your Viewing Activity, you are expressly permitting Pilotly to share and/or publicly display such Viewing Activity on or through (i) the Pilotly Platform; (ii) any third party social networking sites and services you have linked to your Pilotly account, such as Facebook or Twitter ("Social Networks"); and (iii) Pilotly's third party service providers, such as marketing service providers (collectively, the "Receiving Parties"). Accordingly, you expressly acknowledge that the Receiving Parties and anyone who may use their services will be able to freely view your Viewing Activity after you have provided your consent to share and/or publicly display such Viewing Activity.
In the future, Pilotly may build additional privacy settings within the Pilotly Platform that will allow you to change the way in which your Viewing Activity is shared and/or displayed. Once you have provided your consent with respect to a particular Viewing Activity, it cannot be revoked for that Viewing Activity (or any associated Viewing Activity), but you will have the option of not providing consent to share future Viewing Activity in each future instance.
For the avoidance of doubt, although we ask you to consent each time that we intend to share and/or display your Viewing Activity, by agreeing to the Pilotly Terms of Service and Privacy, you expressly provide your advanced consent to Pilotly sharing and/or publicly displaying your Viewing Activity on or through the Receiving Parties and acknowledge that anyone who may use their services will be able to freely view your Viewing Activity.