Updated: May 15, 2023
You can access and interact with our Platform in many ways, including from a computer or mobile device. This Policy applies regardless of how you access or interact with our Platform. Depending on how you interact with our Platform, there may be some cases where we need to provide you with additional information about how we collect, use, protect or disclose your Personal Data and/or what options you have regarding our collection, use or disclosure of your Personal Data. We may provide this additional information through notices on our Platform or via direct communications with you. If we do this, unless we tell you otherwise, the additional information provided in those notices will apply in addition to what is described in this Policy.
Please read this Policy carefully. If you do not want us to collect, use or disclose your Personal Data in the ways described in this Policy, please do not use or otherwise interact with our Platform, provide us with your Personal Data or authorize any third party to make your Personal Data available to us. By using or interacting with our Platform, you acknowledge that you understand that we may use your Personal Data as described in this Policy. Please note, as described in this Policy, we may receive your Personal Data from third parties that have not expressly told you that they will provide your Personal Data to us. If you have any questions about how we collect, use, protect or disclose your Personal Data in connection with our Platform, please contact us by email at email@example.com.
- PERSONAL DATA AND OTHER INFORMATION WE COLLECT
Our primary goals in collecting Personal Data are to provide and improve our Platform, conduct our Operations, communicate with people and enable visitors to our Platform to easily navigate and enjoy them.
When we refer to “Personal Data” in this Policy, we mean information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a specific person. This might be information that directly identifies someone, such as their name, or it may be information that identifies someone only when combined with other information available to us, such as a person’s activity on our Platform when associated with their username. Please note, except as provided under applicable laws, Personal Data does not include information that is publicly available through government records or information that has been de-identified or aggregated in a way that it cannot be used to identify a specific individual.
- Categories of Personal Data We Collect Depending on how you access, use or otherwise interact with our Platform, we, or third parties acting on our behalf, may collect the following categories of Personal Data about you:
- Identifiers and contact information, such as your real name, alias, email address, telephone number, postal address, physical address, unique personal identifier, government-issued identification number, online identifier, IP address and other similar information;
- Demographic information, such as your age, gender, ethnicity, national origin and other similar information;
- Financial information, such as your bank account number, credit card number, debit card number, cryptocurrency wallet information and other similar information;
- Transactional information, such as information about purchases you have made or participated in through our Platform or Operations and other similar information;
- Internet and other similar network activity information, such as your browsing history, search history, interactions with the online portions of our Platform and online advertisements and other similar information;
- Communication information, such as information contained in voice mails, chats, emails and other similar information;
- Location information, such as where you live, where you are located and other similar information;
- Preference information, such as your interests, hobbies, opinions and other similar information; and
- Other information you provide to us.
Depending on how you interact with our Platform, the Usage Data that we, or third parties acting on our behalf, may collect may include:
- Device information, such as the IP address, general geographic location, operating system, browser type, language preferences, mobile phone number, device identifier and other similar information associated with a device used to access, use or interact with our Platform;
- Information about online interactions with our Platform, such as links that are clicked, pages or screens that are viewed, access and session times, interactions with emails we send and other similar information associated with a device used to access, use or interact with our Platform;
- Information about internet and network activity, such as websites visited, search engine results and similar information associated with a device that accesses or interacts with our Platform online;
- Other information automatically collected by cookies and other technologies on our Platform;
- Any other information that a browser or device automatically sends whenever connected to a website or an online application; and
- Data from activity that is publicly visible and/or accessible on blockchains, including but not limited to, blockchain addresses and information regarding purchases, sales, or transfers of NFTs, which may then be associated with other data you have provided to us.
- HOW WE COLLECT PERSONAL DATA
A large portion of the Personal Data we, or third parties acting on our behalf, collect is directly from you and other users who provide their Personal Data to us directly. In some cases, we may collect Personal Data from third parties in the ways described in this Policy.
- Directly from You When you access, use or otherwise interact with our Platform, or otherwise engage with us in connection with our Platform, such as requesting more information about us, communicating with us, accessing, using or otherwise interacting with our Platform, we may ask you to provide certain Personal Data. Some of the Personal Data we request with respect to certain features of our Platform may not be required; however, we will let you know if specific Personal Data is required to use those features. If you do not provide us with the Personal Data required to use a certain feature on our Platform, you will not be able to use that feature, especially those features where we are legally required to collect the Personal Data and those where it is impossible for the feature to operate without the required Personal Data (e.g., collecting your payment information in order to process an order you place in the Angel store).
- From Third Parties We, or third parties acting on our behalf, may collect Personal Data about you from third parties, including, without limitation, online and offline sources, entities affiliated with us, our service providers, social media platforms, advertising networks and other public or commercial sources (collectively, “Third Party Sources”). The collection of Personal Data from these Third Party Sources can occur in a variety of ways, including, without limitation:
- By sharing our content via Third Party Sites or accessing, using or interacting with our Platform through Third Party Sites, you acknowledge that we may collect, share, store and use any Personal Data we receive from those Third Party Sites about you. In some cases, you may be able to revoke our access to your Personal Data and other content and information we receive from Third Party Sites by changing the appropriate settings for your account with the applicable Third Party Site.
- Some of the features of our Platform may provide you with the ability to register and sign into our Platform through the accounts you have with certain third parties, such as Facebook, Google, or Apple (“Third Party Single Sign On Providers”). When you use these features, we, or third parties acting on our behalf, gather the data necessary to create an account on our Platform from the applicable Third Party Single Sign On Provider, which may include, without limitation, your name, email address, IP address, device model, device operating system and web browser, time zone, carrier, screen size, processor cores, total disk space and remaining disk space. Your data associated with the applicable Third Party Single Sign On Provider will not be sold, redisclosed or edited through this process. Your ability to use this option may be limited where the applicable Third Party Single Sign On Provider requires you to use a device or operating system that meets that Third Party Single Sign On Provider’s requirements. Please note, by using these features, the applicable Third Party Single Sign On Provider will know that you are signing into our Platform and that you are a user of our Platform.
- We, or third parties acting on our behalf, may receive Personal Data about you from third parties that provide services to us through or in connection with the operation of our Platform and our Operations (“Operational Service Providers”). Operational Service Providers may include, without limitation, hosting providers and payment providers.
- We, or third parties acting on our behalf, may receive Personal Data about you from our Affiliates. This Personal Data may include, without limitation, information related to your access, use or interaction with our Affiliates and/or the services, products and other things they provide.
- We, or third parties acting on our behalf, may also receive Personal Data about you from other third parties, such as other users of our Platform and those that refer you to our Platform.
- We may receive Personal Data about you from companies that offer their products and/or services for use in conjunction with our Platforms or whose products and/or services may be linked from our Platforms. For example, third-party wallet providers provide us with your blockchain address and certain other information you choose to share with those wallet providers. We may add this to the data we have already collected from or about you through our Platform.
Please note, we may combine the Personal Data and other content and information we receive about you from multiple sources, including, without limitation, Personal Data we collect directly from you and one or more Third Party Sources.
- HOW WE COLLECT USAGE DATA
We, and third parties acting on our behalf, collect Usage Data in a variety of ways. Some Usage Data, such as the IP address of a device attempting to access, use or interact with our Platform, is necessary for us to make certain portions of our Platform available. Other Usage Data, such as information about which features of our Platform are popular, helps us improve and advertise our Platform. This section describes the primary ways Usage Data is collected in connection with our Platform.
- The systems we use to make our Platform available to you. When you access, use or interact with our Platform, these systems automatically record certain information that your browser or device sends whenever you visit a website or utilize an online application, such as information about how long your device is connected to our Platform and the activities that device engages in while connected.
- Other tracking technologies, such as web beacons, clear gifs, and pixel tags. These technologies may be used on or in connection with our Platform, including, without limitation, in emails we send. We may use these technologies to deliver cookies, count visits, understand usage and observe data on email delivery, open rates, click rates, bounces, unsubscribes and other information.
- Third party analytic tools, such as:
- Facebook Pixel, a tool that allows us to measure the effectiveness of our Facebook advertising campaigns, uses a cookie placed by Facebook. The information collected by that cookie will be transmitted to and stored by Facebook. For more information about Facebook’s privacy practices, please refer to https://www.facebook.com/about/privacy/. To opt-out, please see https://www.facebook.com/ads/preferences.
Please note, we have not yet developed a response to browser “Do Not Track” signals and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
- HOW WE USE PERSONAL DATA
We use Personal Data for various purposes to operate and improve our Platform and to conduct our Operations. The primary purposes for which we use Personal Data are:
- Marketing Purposes – we may, either on our own or jointly with our third party marketing partners (“Marketing Partners”), use the Personal Data we, or third parties acting on our behalf, collect for marketing purposes, including notifying you of special promotions, opportunities, offers and events via push notifications, e-mail and other means, all subject to our compliance with applicable laws (“Marketing Purposes”). We may also link Personal Data (including your name, mobile phone number, and email address) with other information (including information we automatically collect as described in this Policy) and use such linked information for Marketing Purposes. Our Marketing Purposes may include using Personal Data collected through cookies and other tracking technologies to facilitate the delivery of targeted ads, promotions, and offers to you, on behalf of ourselves and our Marketing Partners on and off our Platform. If you do not want us to use your Personal Data for marketing purposes, you may opt-out in accordance with the “HOW TO MANAGE YOUR PERSONAL DATA” section below.
- Non-Marketing Purposes – we may use the Personal Data we, or third parties acting on our behalf, collect for non-marketing purposes, including: (1) operating and improving our Platform; (2) validating your identity; (3) carrying out our obligations and enforcing our rights arising from any contracts we have entered into, including, without limitation, any contracts between you and us; (4) sending you emails to provide you with alerts and updates about your engagement with our Platform; (5) conducting statistical or demographic analysis; (6) complying with legal and regulatory requirements; (7) customizing your experience with our Platform; (8) protecting and defending Angel Studios against legal actions or claims; (9) preventing fraud; (10) satisfying contractual obligations; (11) cooperating with law enforcement or other governmental agencies for purposes of investigations, national security, public safety or matters of public importance when we are legally required to do so or believe that disclosure of Personal Data is necessary or appropriate to protect the public interest; (12) those you authorize or instruct us to do; and (13) other business purposes permitted under applicable law.
We will not collect additional categories of Personal Data or use the Personal Data we, or third parties acting on our behalf, collect in connection with our Platform for materially different, unrelated or incompatible purposes without providing you notice.
Please note, we may use and disclose aggregated, anonymized or de-identified information collected in connection with our Platform and other information that does not identify any individual (“Anonymized Data”) for any lawful purposes, which may include, without limitation, purposes not described in this Policy. Except as otherwise required under applicable laws, our use and disclosure of such Anonymized Data is not subject to this Policy.
- SHARING PERSONAL DATA WITH THIRD PARTIES
To operate our Platform and conduct Operations, we may share certain Personal Data that we, or third parties acting on our behalf, have collected, with certain third parties. The third parties that we may share Personal Data with include:
- Our Operational Service Providers in connection with the services they provide to us, including, without limitation, order fulfillment, marketing, data hosting, payment processing and fraud protection and prevention. We require these Operational Service Providers to exercise reasonable care to protect your Personal Data and restrict their use of your Personal Data to the purposes for which we provided to them.
- Our Marketing Partners to facilitate the delivery of targeted ads, promotions and offers to you, on behalf of ourselves and our Marketing Partners, on and off our Platform.
- Government and law enforcement individuals or private parties where necessary to enforce and comply with the law. To the extent permitted under applicable law, we may disclose any Personal Data and other information to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to and defend against legal claims, for legal process (including subpoenas), to protect our property and rights of those of a third party, to protect us against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive or legally actionable activity, to protect the security and integrity of our Platform and any equipment used to make our Platform available or to comply with applicable laws.
- Any third party to whom you consent and/or instruct us to provide your Personal Data. Data obtained through the short code program will not be shared with any third-parties for their marketing reasons/purposes.
- THIRD PARTY INFORMATION COLLECTION
Based on the nature of our Platform, third parties may collect information from or about you through or in connection with our Platform. In addition to other information provided in this Policy, including, without limitation, the section titled “How We Collect Usage Data” the categories of third parties that may collect information about you through or in connection with our Platform include:
- Third parties whose content is linked to on our Platform. Any links to other websites, applications or other third party content on our Platform, are not an endorsement, authorization or representation of our affiliation with that third party and we are not responsible for the content, privacy and security policies and practices of any third party. We encourage you to read the privacy policies or statements applicable to any third party websites, applications or content you access.
- HOW TO MANAGE YOUR PERSONAL DATA
We offer you several choices with respect to how we use your Personal Data. The mechanisms available to you to control the Personal Data are:
- To update any Personal Data you have provided us, update your preferences or otherwise contact us about our use of your Personal Data, please email us at firstname.lastname@example.org.
- To manage the communications we send you:
- For marketing and other promotional email communications you receive from us, you can opt-out of receiving such communications by following the unsubscribe instructions contained in most email messages from us. Your unsubscribe request or email preference changes will be processed promptly, though this process may take several days. During that processing period, you may receive additional marketing and other promotional emails from us. Please note, opting out of these communications will only apply to marketing and other promotional emails and will not apply to any email or other communications we send you for non-marketing purposes, including, but not limited to, emails and other communications about your orders and other interactions with our Platform.
- If you do not want us to use your personal information to deliver targeted advertisements to you according to our target audience preferences, you can opt out by sending us an email with your request to email@example.com. We do not control third parties’ collection or use of your Personal Data to serve interest-based advertising. However, these third parties, which may include our Marketing Partners, may provide you with ways to choose not to have your Personal Data used to deliver targeted to you according to their target audience preferences. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website, located at https://www.networkadvertising.org, and from members of the Digital Advertising Alliance (“DAA”) on their website, located at https://youradchoices.com. Please note, even if you opt out from receiving targeted advertisements, you may still see advertisements based on factors such as your general location derived from your IP address, your browser type and your search terms.
- Subject to certain exceptions, you can request that we delete any of your Personal Data that we collected and retained through or in connection with certain Third Party Sources and Third Party Single Sign On Providers, including, without limitation, Facebook. Once we receive and confirm your request to delete your applicable Personal Data, we will delete your applicable Personal Data from our records, unless an exception applies. We will also direct our Operational Service Providers to delete your applicable Personal Data that they have retained on our behalf. Please note, we may deny your deletion request under certain circumstances, and will inform you of the basis for the denial, which may include, without limitation, in circumstances where retaining your Personal Information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that Personal Information that are compatible with the context in which you provided it.
- To request deletion of your Personal Information, please submit a request to us by emailing us firstname.lastname@example.org. Only you, or a party that you authorized on your behalf, may make a request related to the deletion of your Personal Data. You may also make a request on behalf of your minor child. Your request for deletion must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- We cannot respond to your request or delete your Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
- Making a request does not require you to create an account with us and we will only use Personal Data provided in connection with a request for deletion to verify the requestor’s identity or authority to make the request.
- We endeavor to respond to deletion requests within a reasonable time period after we receive a deletion request. If we are unable to fully comply with your request to delete your applicable Personal Data, our response will explain the reasons why we are unable to fully fulfill your request.
- If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
- Notwithstanding the above, we cannot edit or delete any information that is stored on a blockchain, for example the Ethereum blockchain, as we do not have custody or control over any blockchains. The information stored on the blockchain may include purchases, sales, and transfers related to your blockchain address and NFTs held at that address.
- PROTECTING YOUR PERSONAL DATA
We are committed to protecting the security of your Personal Data. We maintain commercially reasonable safeguards to maintain the security and privacy of Personal Data we collect and use in connection with our Platform. Nevertheless, when disclosing Personal Data, you should remain mindful that there is an inherent risk in the transmission of information via the internet and mobile platforms. Such risk includes but is not limited to profile pictures and stories videos being accessed and “scraped” by third party websites and made publicly available on non-Angel websites and databases without our knowledge or consent; accordingly, you agree to release and hold Angel harmless for any third-party use of your Personal Data (including profile pictures and stories videos). Although we take precautions to protect against the risk of unauthorized access to your Personal Data, we cannot guarantee the security of any information, including your Personal Data, that you disclose online, and you do so at your own risk.
- CHILDREN’S PRIVACY
We do not direct or target any piece of our Platform to children under the age of 13. If we learn that we have collected the Personal Data of anyone under the age of 13, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 13 and discover that your child has submitted Personal Data to us, please contact us at email@example.com. We will make reasonable efforts to remove such information from our databases.
- CALIFORNIA PRIVACY RIGHTS
If you are a California resident, under California’s Shine the Light Law (California Civil Code Section 1798.83) you have the right to request the following information regarding our disclosure of your personal information to third parties for direct marketing purposes: (i) the categories of personal information we disclosed to third parties for their direct marketing purposes during the preceding calendar year; (ii) the names and addresses of the third parties that received the information; and (iii) if the nature of the third party’s business cannot be determined from their name, examples of the products or services they marketed. This information may be provided in a standardized form that is not specific to you.
You are permitted to obtain this information from us once a year, free of charge. To make such a request, please submit your request in writing to:
Angel Studios Inc.
Attn: CA Privacy Rights Request
295 W Center St Suite A
Provo, UT 84601
- EUROPEAN USER RIGHTS
If you are located in the EU, Switzerland, or the United Kingdom, you have certain rights with respect to your Personal Data. Following is a summary of those rights and additional information applicable to our collection and use of your Personal Data.
- Data Controller When you provide us with your Personal Data in connection with our Platform, we serve as a data controller. When we act as a data controller we determine how your Personal Data will be utilized, in accordance with this Policy.
- Legal Basis for Processing We rely on several legal bases to process your Personal Data. These legal bases include where:
- The processing is necessary to perform our contractual obligations, such as to provide you with access to our Platform;
- You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time);
- The processing is necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims; and
- The processing is necessary for the purposes of our legitimate interests, such as improving, personalizing, and developing our Platform, marketing new features or products that may be of interest, and promoting safety and security as described above.
If you have any questions about or would like further information about the legal bases we rely on to collect and use your Personal Data, please contact us at firstname.lastname@example.org.
- Rights Under the General Data Protection Regulation If you are located in the EU, Switzerland, or the United Kingdom, you have the following rights in respect of your Personal Data that we hold:
- Right of access. The right to obtain access to your Personal Data.
- Right to rectification. The right to obtain rectification of your Personal Data without undue delay where that Personal Data is inaccurate or incomplete.
- Right to erasure. The right to obtain erasure of your Personal Data without undue delay in certain circumstances, such as where the Personal Data is no longer necessary in relation to the purposes for which it was collected or processed.
- Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Data in certain circumstances, such as where the accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of the Personal Data.
- Right to portability. The right to portability allows you to move, copy, or transfer Personal Data easily from one organization to another.
- Right to object. You have a right to object to processing based on legitimate interests and direct marketing.
If you wish to exercise one of these rights, please email us at email@example.com. You also have the right to lodge a complaint with your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
- Retention of Personal Data We reserve the right to retain any Personal Data as long as it is needed to: (1) fulfill the purposes for which we collected the Personal Data; and (2) comply with applicable law.
- Transfers of Personal Data If you are located in the EU, Switzerland, or the United Kingdom, the Personal Data we collect may be stored and processed in any country in which we or our affiliates, suppliers, third party electronic payment processors, and/or agents maintain facilities, including, without limitation, the United States of America. The United States of America has not sought nor received a finding of “adequacy” from the EU, Switzerland, or the United Kingdom. We rely on appropriate safeguards and derogations for specific situations as set forth in applicable laws to protect Personal Data transferred from the EU, Switzerland, or the United Kingdom to third countries and international organizations.
- Obligations to Data Protection Authorities (DPAs) We will respond diligently and appropriately to requests from DPAs about this Policy or compliance with applicable data protection privacy laws and regulations. We will, upon request, provide DPAs with names and contact details of the individuals designated to handle this process. With regard to transfers of Personal Data, we will (1) cooperate with inquiries from the DPA responsible for the entity exporting the data and (2) cooperate with its decisions, consistent with applicable law and due process rights. With regard to transfers of data to third parties, we will comply with DPAs decisions relating to it and cooperate with all DPAs in accordance with applicable legislation.
- INTERNATIONAL TRANSFERS
Personal Data collected in connection with the use and operation of our Platform is stored and processed in the United States. If you access, use or otherwise interact with our Platform or otherwise engage with us from outside the United States, please be advised that your personal information may be initially collected by servers located in the United States or, if initially collected outside the United States, transferred to the United States. Please note, the United States has not been assessed as having adequate privacy laws by some countries and economic regions.
- CHANGES AND UPDATES TO THIS POLICY
Because the methods used to protect your Personal Data and the services we provide are continually evolving, this Policy may change at any time. Unless otherwise noted, those changes will be effective as soon as they are posted. If changes are made to this Policy, we will make it known on our Platform or by email and will indicate the last date it was updated above. Please check back periodically to see if our Policy has been updated.
Your continued use of our Platform after any changes to this Policy become effective, constitutes your continued acknowledgement that you understand that we may continue to use your Personal Data as described in this Policy.
- CONTACT US
We welcome your questions, comments and concerns about privacy. Please email us at firstname.lastname@example.org or contact us via the Contact Us page on the Angel Studios website with any questions or feedback you have pertaining to our privacy practices.