Privacy Policy

Last updated September 3, 2019

This privacy policy (“Privacy Policy”) explains how KUMO TV (“KUMO TV” or “we”) collects and processes information from members and users of the website, software applications, and other services we provide (collectively “KUMO TV’s products”). KUMO TV’s products include, but are not limited to, the KUMO TV box (the “KUMO TV box”), the KUMO TV mobile applications on iOS and Android (the “KUMO Apps”), and the website located at kumo.tv (the “Website”). “Visitor” means that you simply browse our websites without registering. “Member” means that you have ordered KUMO TV box and have created an account with KUMO TV. The term “you” or “User” refers to a Visitor or a Member.

The Privacy Policy sets out the basis on which we will process information we collect from you, or that you provide to us in connection with your use of KUMO TV’s products, regardless of how you access or use them. Please read this Privacy Policy carefully so that you understand your rights in relation to how we use and process information that you share and that we collect.

Use of information you share and we collect

In order to deliver KUMO TV’s products to its users and members, to provide support for those products, to improve those products, and to create new products and services to help users and members save time and money, KUMO TV collects information from you during your use of the Services. We collect information you share directly with KUMO TV and other information during your use of KUMO TV’s products and during your interactions with us.

Information you share

When you become a member of KUMO TV you share a limited amount of information in connection with the registration process, including your name, email address, member password and other registration information. Sharing this additional information is optional and does not impact your use of KUMO TV’s products.

The KUMO TV Box allows you to watch free content on your TV and the KUMO TV Apps allow you to keep track of your watching history. When you use the KUMO TV Box and Apps, you share related information, including your email, shipping address and billing address. You also share your payment information for the initial shipping fee before we ship the KUMO TV Box to you and for the subsequent $12.99 charge on the KUMO TV Box if your device is inactive for more than 60 days or if you wish to deactivate your account or if the free rented KUMO box is lost or severely damaged beyond repair, a $12.99 hardware fee may be incurred depending on the condition of the device.

Information we collect

  • In addition to information that you share with us, KUMO TV’s products automatically collect certain information to enable KUMO TV’s products, including the KUMO TV Box and Apps, to function properly and to help us better understand how our products work on various devices, browsers and TVs. We collect and process pseudonymous – i.e. not directly identifying – data about users and members, devices, and ads and where they’re shown.

This includes:

  • Unique cookie identifiers
  • Mobile device advertising identifiers
  • IP addresses
  • Interest information stored and/or used on the platform by clients and partners
  • Interest and other information explicitly provided by Users
  • Interest information we create
  • Other information about browsers and devices, such as type, version and settings
  • Location information based on IP address or latitude/longitude coordinates, if provided to us
  • Information about ads that are shown, such as which ads are shown to a device or member, where (which web page or app) they are shown, and at what time

This information also allows us to upgrade and improve your experience. We use this information to provide a consistent experience across the devices you use, help ensure that our content is displayed properly, understand how, where and which devices access our Services, customize and tailor content and advertisements to our members’ profiles, and improve the overall quality and delivery of our Services.

  • We take our users’ and our members’ time seriously and always want to make sure that any communication or service we provide is useful and relevant. It is in this spirit and scope that we also collect information which allows us to know whether you took an action based upon our communications. To do that we use common digital tools that allow us to see if you opened an email or visited a link we sent.
  • We are always happy to help our users and members when you reach out with questions. The information we collect during that process is used to better improve KUMO TV’s products and the experience of our users and members.

We also may use information you share, and we collect, in aggregate with other data for research and analytical purposes. We do not sell your personal information to anyone, but we may be obligated to disclose information you share, and we collect, in connection with legal requirements imposed on us and obligations we have, as further set forth below in the section titled “How do we share your information with third parties?”

If you are an individual accessing KUMO TV’s website from the European Economic Area, please see the section below entitled “Additional privacy and security information” for further information regarding additional rights you have. Our Apps and TV Box are only available to users in the United States.

How do we collect information

KUMO TV Products receive data in several ways, including the following:

  • Bid requests, which are sets of information that describe an ad space that is available to be filled. We get these requests from the “supply” side of the advertising ecosystem, meaning websites, apps, smart televisions, and others, as well as their agents. The requests contain information about the ad space, the device, and sometimes the user, including location information. They also usually have an ID that enables us to match the request with information we may already have.
  • Purveyors of connected TV devices and apps can send us information about the video content viewed on the device.
  • Mobile device IDs, which are provided by the device operating systems, like Apple’s iOS and Google’s Android, for purposes of allowing mobile apps and their advertising partners to recognize a device over time. We use these IDs the same way we use cookies, but for mobile apps instead of browsers.

How do we share your information with third parties?

We, or our third party partners, may also collect information to analyze the number and demographics of users and members of various content we may feature on our Services. We track this information so that we and our third party partners can determine what content is most interesting and relevant to our users and members, improve the content we serve, understand and improve our Services, deliver more relevant advertisements, measure advertising effectiveness, enable other enhancements.and other similar purposes.

Advertising

We may allow other companies, commonly called third-party ad servers or advertising networks (collectively, “ad networks”), to display advertisements on the KUMO TV Products. We also display advertisements from other companies on the KUMO TV Services, enabling members to interact with the advertisements or click through to websites or other properties owned or operated by other companies. This section provides additional information about the collection and use of information from or about you in connection with such advertising.

When you view an advertisement, whether or not you interact with an advertisement, the advertiser, advertising technology companies, and service providers that perform advertising-related services for us and our business partners may collect some information from or about you. The information practices of these third parties are governed by their own privacy policies and are not governed by this Privacy Policy. Please be aware that KUMO TV does not notify you when you have chosen to click through to another website or property when using the KUMO TV Services. We recommend that you familiarize yourself with the privacy policies of such websites or properties to determine how they use or share any information they separately collect from you should you choose to interact with the advertisements.

Storage of your data

As we are located in the United States and KUMO TV’s products are operated in the United States, if you are located outside of the United States, please be aware that information you share and we collect will be transferred to, and processed, stored, and used in the United States in order to provide KUMO TV’s products to you. The United States does not have an adequacy decision regarding data protection from the European Commission.

Additional privacy and security information:

Legal Bases: We describe in the section above titled ‘Use of information shared and collected’ the purposes for which we use the data collected and shared. Where we are using the data in order to provide KUMO TV’s products to you, our legal basis for such use is on the basis of our contract with you. For all other purposes our legal basis is our legitimate interest in running our business, including ensuring KUMO TV’s products function properly and improving and creating new products and services except where we obtain your consent for a particular processing, in which event the legal basis will be your consent.

Your rights: To exercise any of these rights above, please contact us at contact@kumo.tv. Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or where we are required by law to retain your personal data.

  • Access and portability: You are entitled to request access to your personal data we hold and be provided with certain information about how we use your personal data and who we share it with. Where you have provided your personal data to us with your consent, you have the right to ask us for a copy of this data in a structured, machine readable format and to ask us to share (port) this data to another data controller.
  • Correction: You have the right to ask us to correct your personal data where it is inaccurate or incomplete.
  • Right to deletion: In certain circumstances, you have the right to ask us to delete the personal data we hold about you.
  • Restriction: In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal data.
  • Objection: You can object to our processing of your personal data based on our legitimate interests and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground.
  • Withdrawal of consent: In the event we have relied upon your consent to process your personal data, you may withdraw consent at any time by contacting us at contact@kumo.tv.
  • Cease use: Finally, you may always cease using KUMO TV’s products, and you may uninstall the apps. After a reasonable time following such uninstallation, as set forth below, KUMO TV’s products would no longer have access to your personal information.

Complaints: In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at contact@kumo.tv and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to raise a complaint with a relevant supervisory authority.

Users and members residing in California

California residents are permitted to ask any Internet based company, including KUMO TV, to identify categories of personal information shared with affiliates and/or third parties for direct marketing purposes. KUMO TV does not share personal information with any affiliate or third party for direct marketing purposes without your prior approval. If you are a California resident and would like us to confirm in writing that we have not provided any of your personal information to affiliates and/or third parties for direct marketing purposes, please submit a written request to contact@kumo.tv and we will do so at no cost to you.

Data Retention

KUMO TV only keeps your information as long as is required to provide and enable you to use KUMO TV’s products, including to make purchases using the KUMO TV App, and as required to fulfill our legal requirements and defend legal claims.

After you have terminated your use of KUMO TV’s products, we will store your information in an aggregated and anonymised format. If you would like us to delete the information you provided, you can always contact us directly at contact@kumo.tv. We can explain how we can delete your profile immediately. Once you delete your profile, there is no longer any data attributable to you.

Cookies

We use “cookies” and other semi-persistent but non-personally identifying member identification markers to identify members (“IDs”). When you join as a member and create an account, information you share, and we collect, will be synced with these IDs.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites. If you are in the European Economic Area, we will only use cookies that are not strictly necessary with your consent.

Children

We created KUMO TV for the exclusive use of adults aged 18 and older. We do not knowingly collect or solicit personally identifiable information from children under the age of 18; if you are a child under 18, please do not attempt to register for KUMO TV’s products or send any personal information about yourself to us. If we learn we have collected personal information from a child under 18, we will delete that information as quickly as possible. If you are a parent or guardian of a child under 18 who you believe may have provided us personal information, and/or posted information on any publicly-viewable portion of KUMO TV’s products please contact us at contact@kumo.tv for our assistance, including to request removal of such information.

Security

We take precautions to protect and safeguard our users’ information. We have put in place physical, electronic, and procedural safeguards to protect the information we collect and process. This includes, limiting access to employees, vendors, and others; use of pseudonymization and anonymization techniques where feasible; and use of encryption techniques when transmitting information. Nonetheless, we are unable to guarantee that user or member information will not be accessed, viewed, disclosed, altered, or destroyed as a result of a breach of any of our physical, electronic and procedural safeguards.

Changes

We will continue to update our policies and practices as needed. As such, our Privacy Policy will be updated from time to time. We will notify you of any changes to our Privacy Policy by posting any changes here.

Contact Us

If you have any questions about our privacy policies and practice, please contact us at contact@kumo.tv.