C. J.’s Privacy Policy

July 17, 2013

What Channel One News CEO C.J. Kettler might say... if she was talking.

What Channel One News CEO C.J. Kettler might say… if she was talking.

 

From Jim Metrock:  Channel One’s new Privacy Policy appears to be more controversial than it’s previous version.

Privacy concerns will be a major problem for  Channel One and its fellow Alloy kiddie marketers. Ms. C.J. Kettler the new Channel One CEO may think she can continue to collect information on other people’s children, but she is dead wrong.

Channelone.com attracts teens, preteens, and children in elementary school. Channel One and their parent company Alloy Media and Marketing use this website to collect information about these young visitors. They shouldn’t be doing this. And if they are going to continue to do it, they should at least have the decency to write a privacy policy that these young people can easily understand. This intentionally confusing Privacy Policy and the companion Website Terms of Use were both developed under Ms. Kettler’s watchful eye.  Ms. Kettler has been CEO since February; the Privacy Policy and Website Terms of Use were both published on June 7.

Ms. Kettler obviously thinks this privacy policy is adequate for her young web visitors. That’s pretty sad. That shows a lack of sensitivity.  Teens, preteens and especially elementary school-age children don’t have the life experience and the legal knowledge that are necessary to navigate through Kettler’s Krazy Fine Print maze.

Let’s take one example from the 10th paragraph of the Privacy Policy:

Information you provide to us when you use our Offerings, including if you use social media or similar third party applications on a webpage on Channel One’s Sites or in any of Channel One’s Offerings (e.g., Facebook Like button, Tweet, Google+ buttons or other share functionality), and by visiting the page or activating such third party application, you affirmatively or passively are linking your profile on such third-party’s social media or other platform with your use (or a record of your use) of such Sites or Offerings, including with your registration account.

I don’t understand this. I don’t think Channel One’s attorneys even made a complete sentence here. Even if they did, I still don’t understand it.

Come on Ms. Kettler, tell your crack team of attorneys to rewrite this Policy in plain language.

Better yet, change your Privacy Policy to one sentence: Channelone.com does not obtain any information from any visitor. That’s the very best privacy policy for a kid’s website.

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Updated: June 7th, 2013

CHANNEL ONE PRIVACY POLICY

The following applies to Channel One’s mobile and online offerings, which are provided to you via our website which is accessible through www.channelone.com (and at successor, affiliated or associated domains) or through various mobile or device-oriented app stores or similar distribution platforms.  Our websites are referred to as “Channel One’s Sites”.  Our offerings, including without limitation delivered through or in the form of a media player, app, or native or downloadable software-based offering, are referred to as “Channel One’s Offerings.”

Channel One’s Sites and Channel One’s Offerings are owned or licensed and operated and distributed by Channel One, LLC (referred to herein as “Channel One” and “we” and through similar words such as “us,” “our,” etc.).

This Privacy Policy describes our policies and practices relating to the collection and use of information provided by our about our users.  As one of our users, you may be bound by or subject to other agreements or terms and conditions with Channel One, such as the “Website Terms of Use,” which can be found at www.channelone.com/website-terms-and-conditions, or, if you have registered or downloaded one of our apps, media player or other offerings, the “Online Terms & Conditions” which can be reviewed at www.channelone.com/online-terms-and-conditions.  If you are an educator, employee or other affiliate of a School that subscribes to Channel One’s television programming, curricular offerings, or the like, you or your School may be subject to the “Network Participation Agreement” which can be found at www.channelone.com/wp-content/uploads/2013/06/Network-Terms-and-Conditions.pdf or similar agreement.  In certain circumstances, this Privacy Policy will not apply due to the relationship that we may have with you (or, if applicable, your employer, School or Institution with which you are affiliate) based on one or more of these other agreements or terms and conditions.

Opt-In, etc.  This Privacy Policy is subject to your “opt-in” or other election to allow use or collection of information about you, or the opt-in or other election on your behalf by a parent, guardian, employer or other third party with authority to bind you. In these cases, the disclosures or terms dictated within the context of  such “opt-in” or other elections will apply and prevail, including in the case of any conflict with this Privacy Policy. For example, you may be asked to provide contact information on a temporary or registered basis to participate in discussions forums or in connection with entering a contest or sweepstakes event.  In those cases, please review carefully the disclosures or rules that are displayed or proposed to you at the time.

REMEMBER: IF YOU MAKE USE OF THE SITE, REGISTER WITH THE SITE, REQUEST INFORMATION THAT WE MAY OFFER OR SUBMIT INFORMATION IN ANY WAY TO OR THROUGH THE SITE YOU AGREE TO THESE TERMS. AS WE UPDATE AND EXPAND OUR SERVICES, THIS POLICY MIGHT CHANGE, SO PLEASE REVIEW IT FROM TIME TO TIME.

Special Note for Parents.  We will not knowingly accept personal information from anyone under 13 years old in violation of applicable laws. If you believe that your child under 13 has gained access to the Sites or Offerings without your permission, please contact us. We have taken commercially reasonable steps to restrict use of the Sites and Offerings to those who are at least 13 years old.  In certain select areas of Channel One’s Sites or Offerings, we may collect information from a child under 13 years old solely for purposes permitted by applicable United States law.  These purposes may include in order to obtain information that would allow us to contact a parent or guardian, to use on a one-time basis to respond to a customer support or similar request, to allow for commenting or otherwise participate interactive forum, etc., provided that in all of these instances, except as consented by a parent or guardian, the information provided by the child will be deleted based on reasonable steps taken during or after the use of such information for the permitted purpose.

Types of Information We Use or Collect.  We may collect information about you through a variety of methods, such as games, quizzes, contests, participation in our chat rooms, forums or the like or from other documents that you submit to us, transactions in which you may engage with us or our affiliated companies, via phone or through other modes of communication or through visits or uses you may make of Channel One’s Offerings.

Such information may include non-personally identifiable, such as the kind of browser (e.g, Safari, Internet Explorer) or device (e.g., iPhone, Windows PC) you are using to access the Offerings or a generalized location (e.g, city, state) where you may accessing an Offering at the time of a visit or use.

Some such information may also be personally identifiable or be treated by applicable law as “personal information” about you and/or other users.  This may include contact information (e.g., name and address), financial information (e.g., credit card or billing information), or other kinds of information which are generally considered to be personal information or may be deemed by the law to be sufficiently or potentially personally identifying (e.g., email address, IP address) that we may obtain in connection with providing services.

Information you provide to us when you use our Offerings, including if you use social media or similar third party applications on a webpage on Channel One’s Sites or in any of Channel One’s Offerings (e.g., Facebook Like button, Tweet, Google+ buttons or other share functionality), and by visiting the page or activating such third party application, you affirmatively or passively are linking your profile on such third-party’s social media or other platform with your use (or a record of your use) of such Sites or Offerings, including with your registration account.

How We Use Your Personal Information 

Registrations, etc. We may use your Personal Information to provide you with the benefits of Channel One’s Offerings.  For example, we may request that you register and provide certain personal and non-personal information for us to retain in our registration databases to provide you with access to certain Offerings we make available only to registered users.  These can include mobile apps or offerings that require log-in at our website(s).

Newsletters, etc.    We may ask you to provide, as part of an individual request or a full registration, for email, mailing and/or other information about you, including your affiliations and other personal or non-personally identifying information, to subscribe to a newsletter or other periodical offering.  We will then deliver to you based on the information you provided in connection with such request or consent to receive such newsletter or other periodicals.

Sponsorships, Promotions, etc.  We may work with sponsors, advertisers and other third parties to promote or make available to you offerings of their third party products or services.  In those instances, you may be asked for contact information or be given the opportunity to “opt-in” to be contacted by such third parties or receive such promotions.  If you want us to stop sharing your personal information with these companies, please email us. If you consent to receiving communications from a company other than Channel One, you may need to communicate with them directly if you later decide that you no longer wish to receive their communications or if you wish to change any data you provided online. In this instance, any changes or amendments to your personal information must be given directly to each company who communicates with you as these changes, amendments and/or deletions will not be exchanged between us and non-affiliated companies.

To Be Able to Contact You.  We may ask for temporary contact information in connection with certain offerings, such as to participate on discussion forums or enter a contest of sweepstake or to provide you with customer support, so that we may respond to a request or to get in touch with you when necessary. For example, we may request a reasonable amount of personal and non-personal information (e.g., email address, first name and last initial, school name) in order to communicate with you or to send you information that you have requested or in order to be able to contact a parent, guardian or institution to abide by applicable law or our contractual arrangements.

Optimize and Improve our Offerings, etc. We use and analyze information that is usually non-personally identifying (e.g., browser, device, pages visited, visit frequency, session length, zip code) and sometimes is or may, as a matter of a particular state’s or federal or other law applicable to you or our industry, be treated as personal (e.g., IP address, email, school/employer) in order to learn how our Offerings are being used and to optimize and improve our products, services and operations.  We may also use such information to detect, investigate or prevent activities that may violate our or our customers’ or advertising or similar clients’ policies or be illegal.

Advertising Services, etc. We use non-personal and, with your opt-in or on other legally acceptable basis, personal information to generate advertising revenues on Channel One’s Sites and in connection with Channel One’s Offerings.  For our parent company, Alloy, Inc., and for our own benefit, we may also use third party hosted or provided services to provide, support, optimize or develop Channel One’s Offerings.  These include website monitoring or analytics services (such as Google Analytics for website analytics, or Doubleclick or other third parties or ad serving platforms and technologies, or Comscore and Quantcast for audience segmentation and user metrics).  Some these third party services and in certain instances the third party advertisers which purchase advertising placement on our Sites and Offerings may use ‘cookies’ or other technologies to measure or obtain value based on our users’ activities, as permitted by applicable law (see below section entitled “Cookies, etc.”

Hosting, etc.  We may host our Channel One’s Sites and Offerings through third party hosting providers and utilize the services of other service providers to maintain the operation and integrity of our computer and network infrastructure systems.

Links to Third Party Websites.  The Site may contain links to other websites, including links that are placed there by us, such as third-party advertisements or text hyperlinks. Please be aware that we are not responsible for the privacy practices of any other website. This Privacy Policy applies solely to the Channel One’s Sites and Offerings.  We encourage all users to be aware of when they leave our Sites or other Offerings, to read the privacy policies of each and every third party website or other offerings they visit or use.

Opt-outs, Removal, etc. You will always be given a choice to have us remove your personal information from email or mailing lists, registrations, promotional opportunities and the like when provided by Channel One.  By emailing us at[email protected], you can request that Channel One remove or update any personal information collected from you that was collected and is still being held in computer systems controlled or operated by Channel One.  For example, if you would prefer not to receive email updates from us that may relate, for example, to new services or offerings, or other email notifications, you may opt-out of receiving these communications by emailing us.  If you are affiliated with a School or other Institution, we may be contractually permitted or required to email you or otherwise provide you mailings or other materials on the basis of our relationship with your School or other Institution.  Please be advised that once you provide your personal information to a third party in such situations, you will be agreeing or become subject to such third party’s privacy policy and you may need to contact such third party directly to have your information removed or stop receiving from them the offerings or promotions you opted into.

Cookies.  To enhance your online experience with us, many of our web pages use cookies, beacons, or other monitoring, identifying or tracking technologies.  Cookies and other technologies like these do not, by themselves, tell us your e-mail address or other personal information without your consent or opt-in.  We use cookies as a convenience feature to save you time, to understand and improve the Offerings and the Sites.  You can opt to have your browser reject technologies such as cookies or Java which is used by many such tracking technologies.  If you do that, you may need to re-register with us every time you visit the Site in order to participate in certain functions of the Site. You should also know that companies that advertise on the Site (and their agents) might use their own cookies.  This policy does not cover how these companies use their cookies.

Our Commitment to Security.  We believe we have in place the appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security and correctly use the information we collect online as well as offline. If, based on your opt-in or other election, personal information is passed on to non-affiliated companies, to the extent practical, we endeavor to require that such non-affiliated companies have in place the appropriate safeguards, but we cannot guarantee that they do so.

International Users.  If you are accessing or using Channel One’s Sites or Offerings from outside the United States, your connection will be through and to servers located in the United States and all information you provide will be processed and securely maintained in our web servers and internal systems located within the United States. IN ADDITION, IF YOU ARE LOCATED OUTSIDE THE UNITED STATES, YOU SHOULD NOTE THAT YOUR INFORMATION WILL BE TRANSFERRED TO THE UNITED STATES, THE LAWS OF WHICH MAY BE DEEMED BY OTHER COUNTRIES TO HAVE INADEQUATE DATA PROTECTION. Users of Channel One’s Sites or Offerings located outside of the United States of America who submit personal information consent to the general use of such information as provided in this Privacy Policy and to the transfer of that information to and/or storage of the information in the United States of America. This Privacy Policy and our legal obligations are subject to the laws of the State of New York and the United States of America, regardless of the location of any user. Any claims or complaints must be filed in the United States of America in the State of New York.

Transfer of Business Assets; Corporate Affiliates
The personal and non-personal information you provide is considered a company asset and may be included among transferred assets if we or any or all of its subsidiaries or affiliates or any of our assets are ever acquired by a third party.  Further, we do not consider any companies that are within our “family” of companies owned by our parent company, Alloy, Inc. (“Alloy”) to be “third parties” for purposes of this policy.   Thus, user information, whether personal or non-personal, that is in Channel One’s possession (or may be collected about Channel One’s users) may be audited, reviewed, used, collected directly or shared with companies affiliated with or owned directly or indirectly by Alloy.

Changes to this Policy
Because our business needs may change over time, we reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time. If at any time in the future we plan to use your personal information in a way that differs from this policy, we will revise this policy as appropriate. Your continued use of any of Channel One’s Sites or Offerings following the posting of any changes to this policy means you accept such changes.

How to Contact Us
If you have any questions or concerns about this privacy policy you may email us or write to the following address:

Channel One, LLC
345 Seventh Avenue, 6th Floor
New York, NY 10001
917-634-5700
Attn: Privacy

Telephone: 917-634-5700
E-mail: [email protected]

Notice to California Residents
Under California law, if you are a resident of California, you may make a written request to Channel One about how we have shared your personal information during the prior calendar year with third parties for their direct marketing purposes. In response to your written request, Channel One is allowed to, instead, provide you with a cost-free means to opt-out of such sharing, or a “Customer Choice Notice”. For purposes of this California Privacy notice, third parties include companies within our “family” of companies, such as those companies affiliated with or owned directly or indirectly by Alloy, Inc. Channel One has chosen to provide you with a cost-free means to opt-out of such sharing. If you would like to exercise your rights under California law, please send your written request to the email address or postal address below, or call us at telephone number below. Within 30 days of receiving your request, Channel One will provide you a Customer Choice Notice.

Channel One, LLC
345 Seventh Ave, 6th Floor
New York, NY 10001
Attn: California Privacy

Telephone: 917-634-5700
E-mail: [email protected]

 

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