This Odeum Acceptable Privacy Practices Policy sets forth the acceptable privacy practices of owners and licensors of video programs (“Publishers”) that use the Odeum Service to offer their video programs to subscribers. This policy is an addendum to Odeum’s Privacy Policy, Odeum’s Subscriber Terms of Service and Odeum’s Publisher Terms of Service.

USE

Publisher may use subscriber information for its internal business purposes only.

DISCLOSURE

Publisher may disclose subscriber information to authorized employees, independent contractors, and vendors for the purpose of allowing Publisher to operate its video service.

• Publisher shall restrict access to its Odeum account (and the credentials thereto) to only those employees and contractors who have a need to access the account. Publisher shall enter into agreements with such employees and contractors that require them to keep subscriber information confidential.
• If Publisher discloses any subscriber information to a vendor, Publisher shall (i) limit the disclosure to information that is reasonably necessary to accomplish Publisher’s business objective; and (ii) require the vendor to keep subscriber information confidential and use reasonable security measures to protect subscriber information from unauthorized disclosure.
• Publisher shall be liable for the actions or omissions of its employees, contractors, and vendors with respect to the use and disclosure of subscriber information.

SECURITY

Publisher shall take reasonable measures to prevent authorized access to its Odeum account. If Publisher downloads any subscriber information from the Odeum service, Publisher shall use reasonable security measures to prevent unauthorized access to such downloaded information and the systems hosting it.

MARKETING

• If Publisher emails a subscriber through the Odeum service, Publisher will (i) provide the Publisher’s legal name and principal address so that such information can be displayed in the footer of the email.
• If Publisher emails a subscriber directly, Publisher will (i) provide the Publisher’s legal name and principal address on the footer of the email; (ii) provide an easy-to-use unsubscribe mechanism in the email; (iii) promptly comply with unsubscribe requests (maximum 10 days).
• Publisher shall, whether through the Odeum Service or directly: (i) limit subscriber emails to transactional and relationship emails (e.g., updates regarding new content added to a subscription channel) and refrain from including any upsell or advertisement in the emails; (ii) not contact users in response to the cancellation of a subscription with Publisher (e.g., attempt to survey or “win back” lapsing subscribers); or (iii) not make any false or misleading statements or engage in any fraudulent or deceptive practices.
• Publisher shall not market video programs or services directly to children, provided that Publisher may market programs and services to parents of children.
• Publisher shall not sell or rent any subscriber information to third parties or add subscribers to any third party mail or marketing list.

PUBLISHER WEBSITES AND APPLICATIONS

If Publisher provides links to any websites or applications that it hosts, it shall publish and comply with an appropriate privacy policy.

SUBSCRIBER CHOICES

Publisher shall allow subscribers to update their account information. If a subscriber deletes an account with a Publisher, the Publisher shall promptly delete the subscriber’s account and related information.

AUDIT AND INCIDENT NOTIFICATION

Publisher shall allow Odeum to, upon written notice, conduct an audit of Publisher’s systems and practices to determine compliance with this policy. In the event that an unauthorized third party gains access to any subscriber information in Publisher’s possession, custody, or control, Publisher shall immediately notify Odeum of the circumstances, to the extent permitted by law.
 

LEGAL COMPLIANCE

Publisher shall comply with all applicable laws with respect to its access to, use of, or disclosure of subscriber information. Odeum reserves the right to suspend or terminate any Publisher that fails to comply with the terms of this policy. Odeum shall not be liable for any violation of this policy by a Publisher. Publisher agrees that each subscriber shall have the right to enforce this policy against Publisher.