Last revised December 26, 2019
Updated and effective: July 16, 2019
TABLE OF CONTENTS
- INFORMATION WE MAY COLLECT THROUGH THE SITE
- Information You Provide to the Site
- Community Forums, User Content, and Posting Content to Third-Party Sites
- Send to a Friend Features
- Information Third Parties Provide About You and Social Media Interactions
- Information We Collect Automatically As You Access and Use the Site
- HOW WE MAY USE THE INFORMATION COLLECTED
- HOW AND WHEN WE DISCLOSE INFORMATION TO THIRD PARTIES
- Third Parties Providing Services on Our Behalf
- When You Agree to Receive Information from Third Parties or Request That We Share Your Information
- Sweepstakes, Contests and Promotions
- Employment; EEOC
- Administrative and Legal Reasons
- Business Transfers
- THIRD-PARTY ADVERTISING COMPANIES AND ANALYTICS SERVICES
- HOW WE RESPOND TO “DO NOT TRACK” SIGNALS
- CHANGING YOUR PREFERENCES AND ACCESSING, UPDATING OR DELETING YOUR PERSONAL INFORMATION
- THIRD-PARTY CONTENT, LINKS TO OTHER SITES, AND MGM CONTENT FOUND OUTSIDE OF THE SITE
- JURISDICTION AND CROSS-BORDER TRANSFER
- RETENTION PERIOD
- SENSITIVE INFORMATION
- CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS
- INFORMATION FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA (EEA) OR SWITZERLAND; EU-US AND SWISS-US PRIVACY SHIELD
- CONTACTING US
In addition, MGM works with network advertisers, advertising agencies, analytics providers and other vendors to provide us with information regarding traffic on the Site, including without limitation the pages viewed and the actions users take when visiting the Site; to serve third-party advertisements on the Site and to serve our advertisements elsewhere online; and to provide us with information regarding the use of the Site and the effectiveness of our advertisements. These third parties may set and access their own tracking devices (including without limitation cookies and web beacons) and they may otherwise collect or have access to information about you and your visits to this or other websites or applications, and may use that information to serve you targeted advertisements on this and other websites and applications. Please review “THIRD-PARTY ADVERTISING COMPANIES AND ANALYTICS SERVICES” for additional information. Some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit optout.networkadvertising.org for the NAI and optout.aboutads.info for the DAA, which provide information regarding targeted advertising and offer an “opt out” for participating companies.
INFORMATION WE MAY COLLECT THROUGH THE SITE
Information You Provide to the Site
Where we ask you for Personal Information, we will tell you if it is optional. Otherwise, we are asking because it is necessary in order for us to provide you with the information or fulfill the transaction you requested.
The Site is intended for persons age sixteen (16) and older. We do not knowingly collect personal information from children younger than the age of sixteen (16), and we will delete any personal information later determined to be collected from a user younger than age sixteen (16).
Community Forums, User Content, and Posting Content to Third-Party Sites
The Site may provide you the opportunity to participate and post content publicly in forums, through interactive features and through other communication functionality (“Community Forums”). You may choose, through such features or otherwise, to submit or post photographs, videos, questions, comments, suggestions or other content, (collectively, “User Content”). Please note that certain information, such as your name and state of residence, may be publicly displayed on the Site along with your User Content.
You acknowledge that if you choose to post any information publicly (such as on a third-party platform, in Social Media or in Community Forums) about your purchase, the content on the Site or your viewing history, the Video Privacy Protection Act of 1998 (18 U.S.C. § 2710) (the “VPPA”) (or any similar law) does not apply. However, to the extent the VPPA or any similar law does apply in any manner, you are providing your informed, written consent to the disclosure of that information pursuant to the VPPA and any similar law.
Send to a Friend Features
Information Third Parties Provide About You and Social Media Interactions
We may receive information about you from third parties. For example, if you are on another website and you agree to receive information from MGM, that website will forward your information to us so that we may contact you. We also may supplement the information we collect with outside records from third parties, such as public databases, publicly available Social Media pages or joint marketing partners, for various purposes, such as to provide you with information, services or products, to tailor our content and the offers we show you, or to enhance our products and services.
Information We Collect Automatically As You Access and Use the Site
In addition to any Personal Information or other information you choose to submit to the Site, we, and our third-party service providers (including without limitation any third-party advertisers and content or analytics providers), may use a variety of technologies that automatically or passively collect certain website usage information whenever you visit or interact with the Site (“Site Usage Information“). This Site Usage Information may include the browser and operating system you are using, the URL or advertisement that referred you to our Site, the search terms you entered into a search engine that led you to our Site (if applicable), all of the areas within our Site that you visit, and the time of day, among other information. We may use this Site Usage Information for a variety of purposes, including without limitation enhancing or otherwise improving the Site. Site Usage Information is generally non-identifying, but it may contain Personal Information, and if we associate it with your Personal Information, we will treat it as Personal Information. As you use the Site, we will also track the videos you watch (including without limitation which videos, how often you view the videos, and where you may pause or stop watching).
In addition, we automatically collect your IP address or other unique identifier (“Device Identifier”) for your computer, mobile phone, or other device (any, a “Device“) used to access the Site. We may be able to collect or infer your approximate location through information we collect, such as an IP address. A Device Identifier is a number that is automatically assigned to your Device used to access the Site, and our servers identify your Device by its Device Identifier.
We may directly collect specific location information from your Device if you have opted-in to such collection through one of our mobile applications. You may be able to turn off the collection of location information through your Device settings. However, please note that we may still be able to collect or infer your approximate location through other information we collect, such as IP address. In addition, some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the Device used to access the Site.
The methods used to collect Site Usage Information may include, without limitation, the following:
Cookies & Local Storage. A cookie is a data file placed on a Device when it is used to visit the Site or otherwise access our online content. Certain web browsers and certain browser add-ons, such as Adobe Flash, may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included on our Site may make use of this local storage. For example, a Flash cookie is a data file placed on a Device via the Adobe Flash plugin that may be built-in to or downloaded by you to your Device. For more information about Flash and the privacy choices Adobe offers, visit www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. Cookies, Flash cookies, and other local storage devices may be used for a variety of purposes (e.g., to identify your Device when you revisit our Site, to recall your authentication information, to store information related to your navigation throughout our Site, or to enable certain features on our Site). Some cookies are essential to the functioning of the Site, and, without them, some features and services you have requested cannot be provided. Other cookies help us to understand and improve how the Site works or allow us to personalize it for you. You may be able to refuse or remove some or all of these cookie and local storage technologies, such as through your browser settings. If you choose to do so, some features of the Site may not function properly.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “pixels”, “1×1 GIFs” or “clear GIFs”) may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many emails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.
In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.
HOW WE MAY USE THE INFORMATION COLLECTED
MGM may use information collected through the Site, including without limitation your Personal Information and Site Usage Information, as follows:
(1) in accordance with our legitimate interests, for example as is necessary for the following purposes: (a) to allow you to participate in the Site and features offered through the Site and to provide customer service, including without limitation to resolve any billing or payment processing inquiries; (b) to tailor content, recommendations, advertisements, and offers we display to you, both on the Site and elsewhere online (including without limitation keeping track of how and which videos you watch); (c) to send you emails with advertisements, promotions and other offers; (d) to use for internal business purposes such as to improve the Site or our products and services and for security and fraud prevention; (e) to process your registration with the Site, including without limitation verifying that your email address is active and valid; (f) to provide you with services or information or fulfill transactions that you have requested or otherwise agreed to receive, including without limitation authorizing and processing your payments and orders; (g) to contact you with regard to your use of the Site or similar administrative communications, including, without limitation and in our discretion, changes to the Site’s policies; (h) the purposes disclosed to you at the time you provided your information; or (i) to exercise our legal rights or defend ourselves from legal claims;
(2) to fulfill our contractual obligations to you, such as to make available content that you have purchased a subscription to view;
(3) to protect the vital interest of you or another person;
(4) to comply with regulatory and legal obligations;
(5) as necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us; or
(6) with your consent.
HOW ANDCookiesCookies WHEN WE DISCLOSE INFORMATION TO THIRD PARTIES
Third Parties Providing Services on Our Behalf. We sometimes use other businesses to perform services for us, such as website hosting, conducting website usage analysis, sending email or other communications, fulfilling orders, providing marketing assistance and data analysis, processing payments (including without limitation clearing and processing credit card payments), or performing other services. We may provide access to your Personal Information to such service providers in order for them to complete a requested transaction or otherwise to perform these services.
Sweepstakes, Contests and Promotions. We may offer sweepstakes, contests or other promotions (any, a “Promotion”), that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern that Promotion, which may contain specific requirements of you (including, without limitation and except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, as required by law or permitted by the Promotion’s terms or official rules (such as on a winners list).
Employment; EEOC. If you apply for a job with us via the Site, we may ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity) in connection with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”) and similar state and local regulatory agencies. Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information to the EEOC, the OFCCP and similar state and local regulatory agencies for business-related purposes, including, but not limited to responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.
Business Transfers. In the event that MGM goes through a transition such as being sold, has all or a portion of its assets acquired or transferred, whether voluntary or involuntary (such as through bankruptcy), or merges or becomes affiliated with any other division, individual or entity (including, without limitation, during the course of any due diligence process), any customer information owned or under the control of MGM (including without limitation your Personal Information) will likely be one of the transferred assets. We reserve the right, as part of this type of transaction, to assign or otherwise transfer your information (including without limitation Personal Information) and other information we have collected from users of the Site. By providing your Personal Information, you agree that we may transfer such information to the acquiring entity without your further consent.
THIRD-PARTY ADVERTISING COMPANIES AND ANALYTICS SERVICES
MGM may work with network advertisers, advertising agencies, analytics service providers, and other vendors to serve third-party advertisements on the Site; to serve our advertisements elsewhere online; and to provide us with information regarding use of and traffic on the Site (including without limitation the pages viewed and the actions users take when visiting the Site) and the effectiveness of our advertisements. For example, if you click on an advertisement for MGM, our service provider(s) may be able to tell us the advertisement you clicked on and where you were viewing the advertisement; likewise, if you click on an advertisement you see on our Site, our service provider(s) may be able to tell which page you were visiting on our Site and pass that information to the advertiser. The advertisements you see may be served by one or more third parties, who may use information about your activities on the Site, and other websites and services you visit, across the various devices you use, to provide you targeted advertising based upon your interests. Our service providers may collect certain information about your visits to and activity on the Site and other websites and services and may use this information to target advertising to you.
These service providers may set and access their own tracking technologies on your Device (including without limitation cookies and web beacons) and may otherwise collect or have access to information about you (such as your Site Usage Information and Device Identifier). Some of these parties may collect Personal Information over time when you visit the Site or other online websites and services. Cookies and web beacons, including without limitation those set by third-party network advertisers, may be used to (among other things): target advertisements, prevent you from seeing the same advertisements too many times, and conduct research regarding the usefulness of certain advertisements to you. We may share certain information such as Device Identifiers, Site Usage Information and de-identified information with third-party advertising companies, analytics providers and other vendors for advertising and analytics purposes.
We use a variety of service providers to perform advertising and analytics services, and some of these companies may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”). You may wish to visit optout.networkadvertising.org, which provides information regarding targeted advertising and the opt-out procedures of NAI members. You may also want to visit optout.aboutads.info, which provides information regarding targeted advertising and offers an opt-out for participating companies.
The European Digital Advertising Alliance (“EDAA”) has developed a guide to online behavioral advertising and has developed an opt-out page for participating EDAA member companies available at www.YourOnlineChoices.com.
For mobile apps, you may be able to limit certain advertising practices using the settings on your phone, tablet or other mobile device. You may download the AppChoices app at youradchoices.com/appchoices to opt out of the delivery of interest-based advertisements in mobile apps.
Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive non-targeted advertisements while online or on your Device.
HOW WE RESPOND TO “DO NOT TRACK” SIGNALS
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, the Site does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.
CHANGING YOUR PREFERENCES AND ACCESSING, UPDATING OR DELETING YOUR PERSONAL INFORMATION
The Site may contain web pages or features through which you can correct or update some of the Personal Information you have provided to us through registration through the Site. In addition, if you would like to review, correct, update, suppress, restrict or delete Personal Information that you have provided to us, you may contact us as set forth under “Contacting Us,” below. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. MGM will make good faith efforts to respond to your request as soon as reasonably practicable, consistent with applicable law. Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or within our other records. Also, please note that we may need to retain certain information for our administrative purposes. You are responsible for maintaining the accuracy of the information you submit to us.
If you access the Site through one of our mobile apps, we may, with your permission, send push notifications to your Device. You may opt-out of receiving these at any time by turning push notifications off in your Device settings.
THIRD-PARTY CONTENT, LINKS TO OTHER SITES, AND MGM CONTENT FOUND OUTSIDE OF THE SITE
Certain content on the Site may be hosted and served by third parties, and the Site may contain links to third-party websites that MGM does not control. For example, our Site may provide links to third-party sites through which you can purchase merchandise, products or services or which link to a product or service offered by a third party. The Site may also contain certain third-party applications, such as email, web browser toolbars, wallpapers or other downloads or software applications. These links and applications may include, without limitation, those that use an MGM logo as part of a co-branding agreement. In addition, MGM widgets or other MGM content may be included, among other places, on web pages and websites that are not associated with MGM and over which we have no control. These third parties may collect Site Usage Information through the use of their own cookies and web beacons, independently collect data or solicit Personal Information, and may have the ability to track your use of their sites and services. MGM is not responsible for the privacy or other practices employed by any third party.
While MGM takes commercially reasonable steps designed to secure your Personal Information, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. MGM cannot ensure or warrant the security of any information we collect. You use our Site and provide us information at your own risk.
JURISDICTION AND CROSS-BORDER TRANSFER
The Site is controlled and operated by MGM from the United States of America. Visitors who use the Site and reside outside the United States of America do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable.
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Site, you consent to the transfer of information to countries outside of your country of residence, including without limitation the United States of America, which may have data protection rules that are different from those of your country. We participate in the EU-US and Swiss-US Privacy Shield Frameworks for the transfer of personal data from the European Economic Area (EEA) or Switzerland to the United States of America. For our Privacy Shield Policy, click here.
We keep Personal Information as long as needed for the purposes for which it was collected or for which you subsequently authorized it and additionally for as long as we are required to keep it because of legal obligations, professional accounting and audit standards, legal or insurance claims, or regulatory proceedings. Except as noted differently on specific pages or mobile apps, we retain your Personal Information while you have an account with us, or while you are using our app or continuing to visit us. Residents of the European Economic Area or Switzerland please see additional information here.
We ask that you not send us and not disclose any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, sex life or sexual orientation, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Site or otherwise to us.
CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request to the following email address: CAprivacyrights@mgm.com or write to us at the following mailing address: Metro-Goldwyn-Mayer Studios Inc., Attn: Data Protection Officer, 245 N. Beverly Drive, Beverly Hills, CA 90210. You must put the statement “Your California Privacy Rights” in the subject field of your email or other written communication to us. You must include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
INFORMATION FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA (EEA) OR SWITZERLAND; EU-US AND SWISS-US PRIVACY SHIELD
The following companies are controllers of Personal Information processed in connection with the Site: Metro-Goldwyn-Mayer Studios Inc., MGM and UA Services Company, Metro-Goldwyn-Mayer Pictures Inc., MGM Domestic Television Distribution LLC, MGM Domestic Branded Services LLC, MGM Television (Europe) Limited, United Artists Corporation Limited, Orion TV Productions, Inc., Orion Pictures Corporation, Orion Distribution Company LLC, Orion Releasing LLC, LW Media Holdings LLC, Lightworkers Media OTT, LLC, UAMG Holdings LLC, UAMG, LLC, Thirteen Enterprises, LLC, EFT Media Productions LLC and EFT Media Holdings LLC (collectively, “MGM”) is a data “controller,” and
You may contact us here:
Data Protection Officer
Address: Metro-Goldwyn-Mayer Studios Inc.
Attn: Data Protection Officer
245 N. Beverly Dr.
Beverly Hills, CA 90210
United States of America
Representative in the EEA
Address: United Artists Corporation Limited
Attn: EU Data Protection Representative
7 Air Street
London W 1B 5AD
Your Rights Under Applicable Laws in the EEA and Switzerland
You have certain rights under the applicable laws in the EEA and Switzerland.
You can access information about you and update or correct it. In some cases, you can also ask us to erase it, restrict or stop processing, or provide data in a “portable” form, if feasible. You may withdraw consent (“opt out”) if you have previously consented to any particular use of your information, such as receiving marketing emails or text messages. For all such requests, contact firstname.lastname@example.org.
If you reside in the EEA or Switzerland, you have the right to make a complaint to your national data protection supervisory authority.
Metro-Goldwyn-Mayer Studios Inc.
Attn: Data Protection Officer
245 N. Beverly Drive
Beverly Hills, CA 90210
United States of America
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.