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GLANCE PRIVACY POLICY FOR TV

LAST UPDATED: JUNE 2024
EFFECTIVE: JUNE 2024

Glance InMobi Pte. Ltd. and/or Glance Digital Experience Private Limited (“Glance” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy. Please read this policy carefully to understand our practices regarding your information. By installing, subscribing to, accessing, or using the Glance TV Platform, you agree to this privacy policy as permitted under the applicable law. To the extent required under applicable law, we may ask for your consent to this Policy.

This policy describes (i) the types of information we may collect when you install, subscribe to, access, and/or use the features of Glance TV Platform; (ii) the types of information we may collect or that you may provide when any advertisement is displayed by Glance on Glance TV Platform or as part of your interaction with such advertisement by Glance ; (iii) how we use that information, and the purposes for which we collect it; and (iv) how we disclose such information.

As used in this Privacy Policy, “Glance TV Platform” means and refers to Glance’s proprietary platform (application/software/website/feature or as made available in any other format) which enables end-users to explore and discover content or services through patch wall, screensavers or home screen for smart television. Content discovery may include interesting stories, news, content, events, games, advertisements, products etc. which can be viewed/ accessed on your smart devices such as television. The platform also enables partners to display their content (including advertising, games promotional, entertainment or informational content) on smart television of the end users and sites.

This policy applies only to information we collect through the Glance TV Platform and in email, text, and other electronic communications sent through or in connection with the Glance TV Platform. It does not apply to information that we may obtain from other sources (other than Glance TV Platform) who may provide your information based on their privacy policies and your interaction with their offerings. Glance TV Platform may also be permitted to collect certain information about you from the websites, applications, channels, services or landing pages (“Sites”) you access through Glance TV Platform by the provider/owner of such Sites, in which case, we will treat such information in accordance with the privacy policies of such Sites in addition to this policy, subject to the terms of the former. This policy does not apply to websites or landing pages you may access through the Glance TV Platform, nor does it apply to information that you provide to or that is collected by any third party. We encourage you to read any such non-Glance TV Platform terms, conditions, policies, notices etc. before providing information on or through them including Sites.

FOR Glance TV Platform THAT IS MADE AVAILABLE AS A PRE-LOADED FEATURE OR ON A SMART DEVICE (INCLUDING TELEVISION), PLEASE NOTE THAT, THE PROVIDER OF THE DEVICE MAY INCOPORATE RELEVANT TERMS OF THIS POLICY WITHIN THEIR OWN PRIVACY POLICIES OR PROVIDE FOR A DIFFERENT VERSION OF THE Glance TV Platform PRIVACY POLICY AND MAKE THE SAME AVAILABLE TO YOU. PLEASE REFER TO THE SETTINGS PAGE OF YOUR SMART DEVICE, OR THE TERMS OF USE OF THE APPLICATON IN WHICH GLANCE IS BUNDLED TO FIND THE RELEVANT PRIVACY POLICY.

Glance assumes no responsibility for any third-party landing pages you access or your direct interaction with any third-party including content providers, advertisers, e-commerce partners, reward partners or payment facilitators even if you elect to engage with any content such as specific content, advertisement, product purchase or survey campaign displayed through Glance TV Platform; we recommend that you review the privacy policies of such third parties that you interact with.

  1. Information We Collect and How We Collect It
    We collect certain categories of information depending on how you interact with Glance TV Platform. The information that we collect are described below:

    • Automatic Information Collection

      When you access, and use the Glance TV Platform including when you view any advertisement displayed on the Glance TV Platform, it may use technology to automatically collect certain details of your access to and use of the Platform, including interaction data, logs, time stamp, and other performance data and the resources that you access and use on or through the Platform, stories/videos/content you read, view, watch, interact with or otherwise access.

      We may also collect information about your device and internet connection, including but not limited to, the one way hashed unique device identifier, advertising identifier, device make, IP Address, coarse location derived from IP address, display features, operating system, browser type, network information (Wi-Fi, 3G, 4G). Some of these data sets may be personal information and in which case, we ensure compliance with applicable privacy laws in our collection or use of the same, to the extent applicable in such jurisdictions.

    • Third-Party Information Collection

      When you use the Glance TV Platform or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include our partners such as data enrichment partners, content providers, ad networks, attribution partners and analytics companies etc. The information provided in those cases follows the respective privacy policies of such third parties.

      In the context of advertising displayed on Glance TV Platform, our customers, partners, or vendors (“Ad-Third Parties”) may also disclose to us certain personal or non-personal information they have separately collected about you so that we can effectively provide our services. They do this in accordance with their own specific privacy policies and subject to their own applicable legal requirements and, we will treat such information in accordance with the privacy policies of such Ad-Third Parties in addition to this policy, subject to the terms of the former. We do not use the information they provide to us for any purpose other than providing or improving our services.

      These third parties may use tracking technologies to collect information about you when you use the Glance TV Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different content sites, websites, apps, and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. While we contractually require all our partners to comply with applicable privacy laws, please note that we do not control these third parties’ tracking technologies.

    • Information about advertisements presented on your Glance TV Platform:

      We may also collect some or all of the following information about an ad presented on your device: (i) the content type of the ad (what the ad is about, e.g. games, entertainment, news); (ii) the ad type (e.g. whether the ad is a text, image, or video based ad); (iii) where the ad is being served (e.g. the address of the site on which the ad appears); and (iv) certain information about post-click activity in relation to the ad including user interaction with such ad.

 

  1. How We Use Your Information

    We may use information that we collect about you or that you provide to us, to:

    1. Provide you with the Glance TV Platform features and its contents, fulfil our contract with you, such as: location-based news, events, featured stories, services or products, offers and any other information; answer requests for customer or technical support, activities on our Services, and policy changes.

    2. Provide advertisements and promotions that may be of interest to you.

    3. Notify you when any relevant Glance TV Platform updates or upgrades are available and requires notification.

    4. Estimate our audience size and usage patterns.

    5. Frequency capping of content displayed.

    6. Enrich, build custom audience segments or merged data sets (using the data referred herein and/or third party or Group provided data sets) to enable Glance TV Platform, Ad Partners or the Group to better target advertisements and offer their services.

      “Group” as used in this policy, means, with respect to Glance, its affiliates and group entities listed here .

    7. Fulfil other administrative purposes, such as: pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention; detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for that activity; ensure internal quality control and safety; authenticate and verify individual identities, including requests to exercise your rights under this policy; debug to identify and repair errors with our Services; audit relating to interactions, and other compliance activities; share information with third parties as needed to provide the Services; enforce our policies; and other uses as required to comply with our legal obligations.

    8. Improve, upgrade, or enhance our services, attribution and to deliver a better personalized experience which may include short-term, transient use, such as interest-based advertising customized to individuals’ inferred interests, preferences and locations, measure interest and engagement in our Services; and to perform analysis aimed at improving your user experience.

    9. Tailor and provide you with content and advertisements that are customized to the users’ interests and geographic locations, which Glance may derive or infer from information that it collects about how those users interact with such sites, over the top applications and apps (this type of advertising is often called “interest-based advertising” or “targeted advertising”). The information Glance collect from your device also helps to provide filtering options to manage ads appearing on the Glance TV Platform, and to provide targeting options for advertisers. Further, Glance may also obtain user data from our data partners, advertisers and/or advertisers’ partners for optimizing digital advertising and/or analytical purposes including to provide relevant advertising and reporting.See “Your Privacy Choices and Rights About Our Collection, Use, and Disclosure of Your Information” below to understand your choices regarding these Technologies.If you have any questions about our marketing practices, you may contact us anytime as set forth in  "Contact Information"  below.

    10. Fulfil the purpose for which you provide it.

    11. Honor your consent.

    12. Fulfil other purposes as requested by you, when you provide the information, for purposes stated in this policy, or as permitted by applicable law.

    Automated Decision Making. We may engage in automated decision making, including profiling, such as displaying content that may be relevant to your interests on your device. Glance’s processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent as permitted under the applicable law, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth in "Contact Information" below

    De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, information about the device from which you access our Services, or other analyses we create. If we create or receive personal data that has been de-identified or aggregated, we will not attempt to reidentify it, except to comply with applicable law.

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  2. Disclosure of Your Information

    We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction. We may disclose your information to the third parties (as set out below) for a variety of business purposes, as described above, in accordance with applicable privacy laws and regulatory requirements:

    1. To our key shareholders, Board, subsidiaries, and the Group for our administrative purposes, including activities such as IT management, for them to provide services to you or support and supplement the Services we provide.

    2. To contractors, customers, data partners, brands, measurement companies, service providers, and other third parties we engage with for providing the Glance TV Platform and its services.

    3. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, due diligence, financing, acquisition, or other sale or transfer of some or all of Glance assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by Glance about Glance TV Platform users is among the assets transferred.

    4. To third parties to market their content, products, or services to you if you have not opted out of these disclosures.

    5. If an advertisement or monetization transactions are made available to you through advertising channels of Glance and/or its Group, Glance may share your data obtained by Glance with such Group for such advertising purposes.

    6. If we, in good faith, believe doing so is required or appropriate to comply with any court order, law, or legal process, including to law enforcement authorities and legal advisors or to respond to any government, national security, or regulatory request, or legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; or assist with an investigation or prosecution of suspected or actual illegal activity.

    7. To execute our obligations and enforce our rights arising from or in relation to any contracts including with respect to billing, collection, disputes.

    8. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Glance, its Group, our customers, or others.

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  3. Your Choices About Our Collection, Use, and Disclosure of Your Information

    We strive to provide you with choices regarding the information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

    You may elect to uninstall from the Glance TV Platform or change your Television default screensaver from your OS settings, as applicable. You may also reach out to us anytime as set forth in “Contact Information” below to exercise applicable data subject rights or any other queries related to your privacy with us.

    Your Privacy Rights. In accordance with applicable law, you may have the right to:

    • Access your personal information, including data portability.
    • Request correction of your personal information.
    • Request deletion of your personal information.
    • Withdraw your consent to our processing of your personal information.
    • Object to certain processing activities.
    • Lodge a complaint with the supervisory authority.
    • Exercise other rights under applicable data protection legislation.

    If you wish to exercise any of these rights, please click here or contact us as specified in the section below. We will process such requests in accordance with applicable law. Please note that the contact information, such as your full name and email address, collected as part of the request form under this section, will only be processed for communication and rights fulfillment purposes.

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  4. Data Security

    We have implemented commercially reasonable measures designed to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

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  5. Data Retention Period

    Glance may retain the personal information we collect as described in this Privacy Policy for as long as you use your Services, or as necessary to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

    Glance may retain the information it obtains about you as per the instructions of its customers or partners who provide such information or as required to fulfil our contractual obligations. In case any information is provided by you in participation of a survey, Glance will only retain your personal data for as long as necessary to fulfil the purposes it collected it for.

    After the applicable retention period, Glance may retain and use such data in an aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, resolve disputes (including billing) and enforce agreements.

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  6. Changes to Our Privacy Policy

    We may update our privacy policy from time to time. If we make material changes to how we treat our users’ information, we will post the new privacy policy on this page and attempt to notify you.

    The date the privacy policy was last revised is identified at the top of the page. Subject to requirements of express consent under any applicable data privacy laws which we comply with, your continued use of the Glance TV Platform after we make changes is deemed to be acceptance of those changes, so please check the applicable policy(ies) periodically for updates.

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  7. Contact Information

    To ask questions, exercise applicable data subject rights or comment about this privacy policy and our privacy practices, please e-mail us at privacy@glance.com with a copy to  privacy@inmobi.com . To the extent you may enjoy any data subject rights as per privacy laws applicable to you, you may reach out to our data protection office at dpo@inmobi.com .

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  8. Order of Prevalence
    Subject to applicable laws, the English language version of this policy will prevail over any other language version issued by us for your benefit.