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Privacy Policy

Synacor, Inc. together with its subsidiaries, affiliates, and related entities (including, but not limited to, NTV Internet Holdings, LLC, Sync Holdings, LLC, Zimbra Software, LLC, and Cloud ID LLC) (hereinafter referred to as Synacor, “us,” “we,” “our,” or “Company”) is a cloud-based software and services company whose customers (“Customers”) include video, internet and communications providers, device manufacturers, governments, and other enterprises. Our mission is to enable our Customers to better engage with their clients and other users of their products and services. We have created this Privacy Policy to apply to the “Personal Information” (i.e., information about an identified or identifiable natural person), that we collect and use in the ordinary course of business in connection with the use of our “Services,” which include:

  • Websites, hosted email, mobile applications, and other services that we provide to or manage for our Customers (“Customer Applications”);
  • Advertising that we provide on Customer Applications, in email, in mobile applications, and to third parties for their websites; and
  • Various websites and applications that Synacor owns and operates (“Synacor Applications”).

This Privacy Policy describes, among other things, the types of Personal Information we collect from you when you use our Services, how we use it, and how you can access your information. Depending on where you reside and the applicable laws in your jurisdiction, you may have certain rights related to the use of your Personal Information which are described more fully in Section XII. The Company will at times collect, maintain, use, and share your information as is necessary to provide Services to you, meet certain business needs and functions, and comply with laws and regulations. This Privacy Policy is integrated into our Terms & Conditions of Use (“Terms & Conditions”).

By using the Services and providing us with your Personal Information (defined below), you agree to the practices described in this Privacy Policy and Terms & Conditions referenced below and to the updates to these policies posted here from time to time.

This Privacy Policy applies to any Personal Information (defined below) that you provide to us through the Website or use of our Services. The terms of this Privacy Policy are subject to any additional terms of disclaimers or other contractual terms you have entered into with Synacor and any applicable mandatory laws and regulations.

I. INFORMATION WE COLLECT ABOUT YOU

II. HOW WE USE YOUR INFORMATION

III. LINKS TO OTHER WEBSITES

IV. INFORMATION SECURITY

V. DATA RETENTION

VI. CONSENT

VII. HOW WE WILL CONTACT YOU

VIII. ACCESSING, CORRECTING OR DELETING YOUR INFORMATION

IX. CHILDREN’S INFORMATION

X. DATA PRIVACY FRAMEWORK/STANDARD CONTRACTUAL CLAUSES

XI. NOTICE TO CERTAIN RESIDENTS OF DATA SUBJECT RIGHTS

XII. NOTICE TO CALIFORNIA RESIDENTS

XIII. NOTICE TO VIRGINIA RESIDENTS

XIV. NOTICE TO COLORADO RESIDENTS

XV. NOTICE TO CONNECTICUT RESIDENTS

XVI. NOTICE TO UTAH RESIDENTS

XVII. NOTICE TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA. THE UK AND SWITZERLAND

XVIII. GEOGRAPHIC LOCATION OF DATA STORAGE AND PROCESSING

XIX. DIFFICULTY ACCESSING OUR PRIVACY POLICY

XX. “DO NOT TRACK” SIGNALS

XXI. DISPUTE RESOLUTION

XXII. CHANGES TO THIS PRIVACY POLICY

XXIII. CONTACT US

I. INFORMATION WE COLLECT ABOUT YOU

We may collect the following categories of Personal Information, which are described in more detail below: (A) information you provide to us, (B) Sensitive Information (as defined below), and (C) information we may automatically collect about you, and (D) information we may receive from third parties. All of the information listed above, is detailed below, and hereinafter referred to as “Personal Information.”

A. Information You Provide to Us

In using our Services (directly or through Synacor Applications or Customer Applications), you may provide us with Personal Information, including, without limitation:

  1. Individual identifiers such as name, username, date of birth, contact information such a mailing address, phone number, and email address;
  2. Communications with us, preferences, and other Personal Information you provide to us such as any messages (including via online chat feature), opinions and feedback that you provide to us, and other Information that you share with us when you contact us directly (such as for customer support services); and when completing registration/sign-in process, responding to surveys, requesting product information, and in other communications, opinions in online forms you share with us or when you communicate with us through email;
  3. Payment and transactional information such as services purchased. Note that we use third party payment processors to facilitate your payments and do not store your payment information;
  4. Information about your education, demography, and prior work experience to the extent that it is needed for processing your employment application; and/or
  5. Additional information as otherwise described to you at the point of collection or pursuant to your consent.

You may choose not to provide Personal Information via the Customer Applications but doing so may limit or prevent website functionality as a result.

If you choose to correspond with Synacor through email, Synacor may retain the content of the correspondence, email addresses, and our responses. If you sign-up to receive marketing emails or other communications from us and would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in email messages we send to you or by contacting us as set forth in Section XXIII (Contact Us).

If you apply for a job via the Synacor Applications, we collect (through our job application service provider) Personal Information that you provide us, such as your name, email address, physical address, phone number, and other information contained on your resume. We use a third-party service provider to manage our job postings and resume submittals. The third party is prohibited from using your Personal Information for any purposes, except for the purposes for which it was provided or otherwise related thereto, unless we obtain your consent or required by any applicable law.

B. Sensitive Information

Sensitive Information is a category of Personal Information that by law require additional protections because of the significant consequences of exposure. The precise legal definition of Sensitive Information varies according to the applicable law. Those definitions are set forth in Sections XII and XVII to the extent applicable. However, as a general matter, with your consent, Synacor may process the following categories of Sensitive Information when you use our Services:

  • Precise geolocation data

C. Information We May Automatically Collect About You

Our Services may automatically collect the following categories and technical Personal Information about you. This Personal Information is used by Synacor for the operation of the Services, to maintain quality of the Services, and to provide general statistics regarding use of the Services. This Personal Information may include:

  1. Information about the device you are using, such as operating system version, device identifier, and other similar information;
  2. IP address, which is the number associated with the service through which you access the Internet, like your ISP (Internet service provider), your company, or your university;
  3. Date and time of your visit or use of our Services;
  4. Domain server from which you are using our Services;
  5. Type of computer, web browsers, search engine used, operating system, or platform you use;
  6. Data identifying the web pages you visited prior to and after visiting our website or use of our Services;
  7. Your movement and activity within the website, which is aggregated with other information;
  8. Voice and audio information when you use audio features;
  9. People with whom you communicate via email or share content;
  10. Purchase activity;
  11. Geo-location information through the use of any of our mobile applications;
  12. Mobile device information, including the type of device you use, operating system version, and the device identifier (or “UDID”); and
  13. Mobile application identification and behavior, use and aggregated usage, performance data, and where the application was downloaded from.

We may combine some of the information collected about you to improve the Services we offer you, and enhance our marketing, analytics, and site and application functionality. However, we do not link information stored within our analytics software to any Personal Information you submit within the mobile applications. IP addresses are also used to provide us an audit trail in the case of any attempted illegal or unauthorized use of the Services.

D. Cookies and Technologies Used to Collect Information About You

We and/or certain service providers operating on our behalf may collect information about your activity, or activity on devices associated with you over time, on our sites and applications, and across non-affiliated websites or online applications. We collect this Personal Information by using certain technologies such as cookies, web beacons, software developer kits, third party libraries, and other similar technologies. Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons to collect similar or identical information.

  1. Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.
  2. Web Beacons. Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). We also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the Services. These technical methods may involve the transmission of Personal Information either directly to us or to a third party authorized by us to collect Personal Information on our behalf. Our Services use retargeting pixels from Google, Facebook, and other ad networks. We also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.
  3. Analytics. Analytics are tools we use, such as Google Analytics, to help provide us with information about traffic to our website and use of our Services, which Google may share with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network. You can view Google’s Privacy Practices here: Privacy Policy – Privacy & Terms – Google.
  4. Mobile Application Technologies. If you access our Services through a mobile device, we may automatically collect information about your device, your phone number, and your physical location.
Our use of online tracking technologies may be considered a “sale” or “sharing” under certain laws. To the extent that these online tracking technologies are deemed to be a “sale” or “sharing” under certain laws, you can opt-out of these online tracking technologies by submitting a request via [email protected] or by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC). Please note that some features of our website may not be available to you as a result of these choices.

E. Information We May Receive from Third Parties

We may collect additional Personal Information about you from others such as affiliates, other companies, social media platforms, third-party websites, and/or sources providing publicly available information (e.g., from the U.S. postal service) to help us provide services to you, and for marketing and advertising purposes.

This Privacy Policy only applies to Information collected by our Services. We are not responsible for the privacy and security practices of those other websites or Social Media Platforms or the Information they may collect (which may include IP address). You should contact such third parties directly to determine their respective privacy policies. Links to any other websites or content do not constitute or imply an endorsement or recommendation by us of the linked website, Social Media Platform, and/or content.

II. HOW WE USE YOUR INFORMATION

A. Use and Purpose of Processing Your Information

We use and process your Personal Information above for things that may include, but are not limited to, the following:

  1. To respond to your inquiries and provide you with requested information such as our newsletters;
  2. To process your request for services;
  3. For marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties, provided that you have not already opted-out of receiving such communications;
  4. To manage, improve, and foster relationships with third-party service providers, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners;
  5. Maintain, improve, customize, or administer our services, perform business analyses, or other internal purposes to improve the quality of our business, the Website, resolve technical problems, support functionality or improve security or develop other products and services;
  6. To comply with our Terms & Conditions;
  7. To comply with any applicable laws and regulations and respond to lawful requests;
  8. To provide you with the services and information you request;
  9. To processes a payment or transaction you make through or in connection with the Services;
  10. To respond to your comments, inquiries, and questions, support your use of our Services, and provide customer service;
  11. To fulfill contracts we have with you;
  12. For analytics for business purposes and business intelligence;
  13. For verification and authentication of your identity when using our Services or the services of our customers;
  14. For any other purposes disclosed to you at the time we collect your Personal Information; and/or
  15. Other purposes with your consent.

We may also use Personal Information that has been de-identified and/or aggregated for purposes not otherwise listed above.

B. Sharing or Disclosing Your Information

We may share and/or disclose your Personal Information as disclosed at the time you provide your Personal Information, as set forth in the Privacy Policy and in the following circumstances:

  1. Third-Party Service Providers. We may share your Personal Information with third-party service providers or data processors that perform certain functions or services on our behalf (such as to host the Services, manage data, perform analyses, process payments, provide customer service, or send communications for us). These third-party service providers are authorized to use your Personal Information only as necessary to provide these services to us. These third-party service providers are authorized to use your Information only as necessary to provide these services to us. In some instances, we may aggregate Information we collect so third parties do not have access to your identifiable Personal Information to identify you individually.
  2. Disclosure of Customer Information for Legal and Administrative Reasons. We may disclose your Personal Information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory, or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Information); (iv) to protect and defend the rights, property, or safety of us, our subsidiaries and affiliates, and any of their officers, directors, employees, attorneys, agents, contractors, and partners, and the website Service users; (v) to enforce or apply our Terms & Conditions; and (vi) to verify the identity of the user of our Services
  3. Information Shared with our Subsidiaries and Affiliates. We may share your Personal Information with our subsidiaries and affiliates.
  4. Business Transfers. Your Personal Information may be transferred, sold, or otherwise conveyed (“Conveyed”) to a third party where we: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganize.
  5. Online Communications. If you chose to share with us comments, post a review, participate in a survey, provide a testimonial, or other information you consent and agree that we may make it available generally to the public and it will not be returned to you unless we receive such a request in writing from you and determine, in our sole discretion, to honor such request. If you choose to use the Services by posting comments to blogs, forums, or other editorial sections available via the Services, any information you submit there can be read, collected, or used by others. When you publish any such Personal Information, it becomes public, and we do not take responsibility for what others may do with the information you choose to submit through these features.
  6. De-Identified or Aggregated Data. We may share your Personal Information on an aggregated basis for any purpose in which your specific Personal Information is blinded, masked, or otherwise not identifiable.
  7. Promotional Partners. Synacor may notify you about offers from our promotional partners, marketing partners, or advertisers through banner ads as well as promotional emails. All targeting of promotional offers is done internally, and our promotional partners will not have access to the targeting information. We may perform research on your demographics, interests, and behaviors based on the information provided to us during a promotion. We may share your Personal Information with our promotional partners if you affirmatively respond to a promotional offer.
  8. With Your Consent. We may share Personal Information consistent with this Privacy Policy with your consent.

III. LINKS TO OTHER WEBSITES

Our Services may contain links to other websites or services that are not owned or controlled by us, including links to Social Media Platforms such as Facebook, Instagram, and Twitter (“Social Media Platforms”), or may redirect you off our website away from our Services.

We are not responsible for the privacy and security practices of those websites or the information they may collect (which may include IP address). You should contact such third parties directly to determine their respective privacy policies. Links to any other party’s website or content do not constitute or imply an endorsement or recommendation by us of the linked website and/or content. We also have no control over websites that link to our Services.

We utilize framing techniques on some pages displayed via the Services to make it appear that the user is still on a Synacor or Customer website, as applicable, when the user is actually on a third-party website. Please be aware that, if you are providing your Personal Information on these third-party websites, you are providing such Personal Information to these third parties and not to Synacor, and that the privacy policies of these third parties will apply to your Personal Information.

IV. INFORMATION SECURITY

We use commercially reasonable and appropriate administrative, physical, and technical security measures to provide our Services and safeguard your information. However, no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, we do not promise or guarantee, and you should not expect, that your Information or private communications will always remain private or secure. We do not guarantee that your Personal Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Personal Information.

If you believe that your Personal Information has been accessed or acquired by an unauthorized person, you should promptly contact us as set forth in Section XXIII ( Contact Us) so that necessary measures can quickly be taken.

V. DATA RETENTION

We will retain your Personal Information for as long as needed to provide you Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted to us. We are under no obligation to store such Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information.

VI. CONSENT

In In certain states or countries, we may be required to obtain your consent prior to collecting and using your Personal Information. Synacor will request your consent prior to collection of your Personal Information when applicable. Otherwise by submitting your Personal Information to us, you agree that we may collect, use, and disclose such Personal Information as set forth in this Privacy Policy and as permitted or required by law. If you wish to withdraw consent, please contact us at [email protected].

VII. HOW WE WILL CONTACT YOU

You agree that we, our affiliates, and/or our third-party service providers with whom we collaborate and contract, may communicate with you via electronic messages, including email, text message, or mobile push notification to, for example, send you information relating to our products and services that we think may be of interest to you, communicate with you about offers, promotions, upcoming events, and other news about products and services offered by us. We will obtain your opt-in consent prior to sending you text notifications.

A. Choices Related to Contact Methods

  1. Email:

    By using our Services, you agree that we may contact you by email as set forth herein. If you do not want to receive marketing and promotional emails from us, you may click on the “unsubscribe” link in the email to unsubscribe and opt-out of marketing email communications or you should promptly contact us as set forth in Section XXIII ( Contact Us) so that necessary measures can quickly be taken.

  2. Mobile Push Notifications:

    By using our Services, you agree that we may contact you by calling or sending messages to your mobile device. You may be able to use the settings on your mobile device to enable or turn off mobile push notifications from us or [email protected].

  3. Text Messages:

    By using our Services, you agree to be reached by text message or SMS message. If you no longer want to receive text messages from us, reply STOP (or as otherwise instructed) in the text message or [email protected].

C. Choices Related to Contact Types

You may have the right, under applicable law, to limit some but not all of the sharing of your Personal Information.

  1. General Marketing Communications By using our Services, you agree that we may contact you by email as set forth herein. If you do not want to receive marketing and promotional emails from us, you may click on the “unsubscribe” link in the email to unsubscribe and opt-out of marketing email communications or see Section XXIII (Contact Us) below for more information
  2. Location Tracking You can change the privacy settings of your device at any time to turn off the sharing of location information with our Services. If you choose to turn off location services, this could affect certain features or services of our Services. If you have specific questions about the privacy settings of your device, we suggest you contact the manufacturer of your device or your mobile service provider for help.
  3. Direct Marketing by Third Parties To exercise choices regarding the marketing information you receive, you may also review the following links:

VIII. ACCESSING, CORRECTING OR DELETING YOUR INFORMATION

Upon request (as set forth below) and subject to certain exceptions and limitations, we will inform you of the existence, use and disclosure of your Personal Information and will provide you access to that Personal Information.

We encourage you to review, update, and correct Personal Information that we maintain about you, and you may request that we delete Personal Information about you that is inaccurate, incomplete, or irrelevant. We may not be able to accommodate your request, or we may not accommodate a request if we believe the change would violate applicable law.

To request that you access, correct, or delete your Personal Information, contact us at:

Email our Data Protection Officer: [email protected]

Write us: Synacor, Inc.
Attn: Legal
485 Sunset Blvd., Office #114
Hamburg, NY 14075

Call us: 1-877-492-9484

The requests above will be considered and responded to in the time-period stated by applicable law. Note, certain Personal Information may be exempt from such requests. We may require additional information from you to confirm your identity in responding to such requests. You have the right to lodge a complaint with the supervisory authorities applicable to you and your situation, although we invite you to contact us with any concern as we would be happy to try and resolve it directly.

IX. CHILDREN’S INFORMATION

Our Services are intended only for users over the age of sixteen (16). By using our Services, you agree that you are sixteen (16) years or older. If we have actual knowledge that a user is under sixteen (16) (or a higher age threshold where applicable) and has provided us with Personal Information, we will take steps to comply with any applicable legal requirement to remove such Personal Information. Contact us as provided in Section XXIII if you believe that we have mistakenly or unintentionally collected Personal Information from a child under the age of sixteen (16).

X. DATA PRIVACY FRAMEWORK/STANDARD CONTRACTUAL CLAUSES

Synacor uses Standard Contractual Clauses to show its commitment to information security and privacy principles for any transfer of Personal Information or another appropriate legal basis for data transfers, where required. Specifically, to the extent that Synacor is deemed to transfer Personal Information outside of the European Economic Area, we do so on the legal basis that such transfer is necessary to provide you with the Services you have chosen to use or consented to use. For information about how Synacor processes Personal Information, including how to opt out of such processing, see Section XVII.F.

If you have a complaint that relates to Synacor’s processing of Framework Information, and you are unable to resolve your complaint with us directly, Synacor offers an independent recourse mechanism to resolve your complaint. In order to access the independent recourse mechanism, you must file a complaint with TRUSTe Dispute Resolution (“TRUSTe) at https://feedback-form.truste.com/watchdog/request. After receiving your complaint, TRUSTe will resolve the dispute between you and Synacor in accordance with the procedures set forth in the link above. All fees of TRUSTe in connection with your use of its independent recourse mechanism described in this Section will be paid by Synacor.

If all other options available to you for resolving a complaint under the Framework are unsuccessful, and upon satisfaction of certain other conditions, you can lodge your complaint with the Framework Panel, which is an “arbitration mechanism” of three neutral arbitrators. The procedures for this arbitration mechanism are set forth in Annex I of the Framework Principles. Any decision of the Framework Panel will be binding on Synacor and enforceable in certain courts of the United States.

XI. NOTICE TO CERTAIN RESIDENTS OF DATA SUBJECT RIGHTS

Depending on where you reside and the applicable laws in your jurisdiction, you may have the right to make certain requests related to the use of your Personal Information. Even if you do not live in one of these jurisdictions, Synacor will use its best efforts to respond to reasonable requests. If you are a California, Colorado, Connecticut, Utah, Virginia or European Economic Area Resident, your privacy rights are separately addressed in Sections XII through XVI. The requests that may be made by residents from other states and jurisdictions with applicable laws are as follows:

  • Access your Personal Information. You may request a copy of the Personal Information, if any, Synacor has collected about you.
  • Delete your Personal Information. You may request that Synacor delete any Personal Information that has been collected about you.
  • Correct your Personal Information. You may request to have inaccurate Personal Information about you corrected.
  • Opt-out of Targeted Ads. You may opt-out of our sharing certain Personal Information with other parties that serve targeted ads on our behalf, if any.

To make any of the requests set forth above, you must contact us using the contact information in Section XXIII. To fulfill your request, we may need to verify your identity. Synacor only uses the information collected in this process to fulfill and maintain records of your request. We endeavor to provide responses within the time frames provided by applicable law, and, in some cases, fulfillment make take up to 30 or 45 days depending on where you reside.

XII. NOTICE TO CALIFORNIA RESIDENTS

To the extent any California data privacy law applies to the collection of your Personal Information, this supplemental notice outlines the rights that California residents may have, and how they can exercise those rights. This notice applies solely to California residents. We provide the supplemental selection below to comply with the California Consumer Privacy Act [as amended by the California Privacy Rights Act (referred to collectively hereinafter as CCPA)] and any terms defined in the CCPA have the same meaning when used below.

A. Your Rights under CCPA

  1. Right to Know and Access Specific Information.You have the right to request that we disclose certain information to you about our collection and use of your Information over the past twelve (12) months. Once we receive and confirm a verifiable consumer request from you, we will disclose to you, to the extent permitted by law:

    • The categories of Personal Information we collected about you, and whether we sell or share your information to third parties.
    • The specific pieces of Personal Information we hold about you.
    • The categories of Personal Information sold within the last 12 (twelve) months.
    • The categories of sources from which Personal Information about you is collected.
    • Our business or commercial purpose for collecting, selling, or sharing your Information.
    • The categories of third parties with whom your Personal Information is sold, shared, or disclosed for a business purpose.

    You have the right to request that the Personal Information described above be provided to you in a portable and readily useable format, to the extent technically feasible (“data portability”).

  2. Deletion Request Rights. You have the right to request that we delete the Personal Information that we collected from you, subject to certain exceptions. To the extent that we can delete your Personal Information, once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information, unless an exception applies.

  3. Right to Correct Inaccurate Information. To the extent that we may maintain inaccurate Personal Information, you have the right to request that we correct such inaccurate Personal Information taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information. Once we receive and verify your verifiable consumer request, we will use commercially reasonable efforts to correct your Personal Information.

  4. Sale and Sharing of Personal Information and the Right to Opt-Out. You have the right to opt out of the processing of your Personal Information for the following purposes:

    • Sale of your Personal Information.
    • Sharing of your Personal Information for cross-context behavioral advertising.

    The use of online tracking technologies may be considered a “sale” or “sharing” under California law. To the extent that these online tracking technologies are deemed to be a “sale” or “sharing” under California law, you may opt-out of these online tracking technologies by submitting a request via [email protected] or by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC).

  5. Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to request that we limit the ways we use and disclose your ”Sensitive Personal Information” to uses which are necessary for us to perform the Services, or deliver the goods reasonably expected by you, or and as authorized by law. Under the CCPA, Sensitive Personal Information includes: Sensitive personal information includes: (a) social security or passport number, driver’s license, or state ID; (b) financial account credentials; (c) a consumer’s precise geolocation; (d) racial or ethnic origin, citizen or immigration status, religious or philosophical beliefs, or union membership; (e) contents of messages (e.g., emails, texts, chats), unless it’s directed to Synacor; (f) genetic data; (g) biometrics, like facial recognition; and (h) information concerning your health, sex life, or sexual orientation.

  6. Right to Non-Discrimination. You have a right to not be discriminated against in the Services or quality of Services you receive from us for exercising your rights. We may not, and will not, treat you differently because of your data subject request activity. As a result of your data subject request activity, we may not and will not deny goods or Services to you, charge different rates for goods or Services, provide a different level quality of goods or Services, or suggest that we would treat you differently because of your data subject request activity.

  7. Right to Disclosure of Direct Marketers. You have a right to the categories and names/addresses of third parties that have received Personal Information for their direct marketing purposes upon simple request, and free of charge.

You may make an authenticated consumer request exercising your Right to Know and Access Specific Information including Right to Know what Personal Information is being Sold or Shared or under the CCPA twice within a twelve (12) month period. To exercise the rights described above,

B. Authorized Agent

You may use an authorized agent to submit verifiable consumer requests on your behalf provided that the authorized agent is a natural person or a business entity that you have authorized to act on your behalf. If you use an authorized agent, we will require: (1) proof of written permission for the authorized agent to make requests on your behalf, and identity verification from you; or (2) proof of power of attorney pursuant to California Probate Code sections 4000 to 4665. We may deny a request from an authorized agent that does not submit proper verification proof.