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Last Modified: October 9, 2013

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PRIVACY POLICY AND YOUR CALIFORNIA PRIVACY RIGHTS

This is the privacy policy (“Privacy Policy”) for the Viacom Supplier Workplace for Invoice Management (“SWIM”) registration website ("Site"), an Internet website operated by Viacom Inc. (the “Parent Company”) that provides suppliers the ability to register and provide certain financial and payment information in connection with provision of services to the Parent Company and/or its subsidiaries or corporate affiliates (together with the Parent Company, "Viacom") and to receive and/or provide information regarding ongoing billing relating to such suppliers.  This Privacy Policy governs only the content features and activities related to the Site (i.e., the SWIM registration website) and does not cover websites for any individual Viacom programming channel, any other websites or portion of a website provided by or for Viacom (including www.viacom.com), or any websites for any other company, unless specifically stated.

This Privacy Policy is intended to explain our privacy practices and covers the following areas:

1. When This Privacy Policy Applies.
2. U.S. Governing Law; Safe Harbor.
3. Collection and Use of Personal Information and Other Information.
4. Opting-out of Certain Uses of your Personal Information and Other Information.
5. Sharing and Disclosure of Personal Information and Other Information.
6. Reviewing, Updating or Deleting Certain Information.
7. Protection of Information.
8. Jurisdictional Rights.
9. Changes to this Privacy Policy and Notice.
10. Miscellaneous.

1. When This Privacy Policy Applies.

This Privacy Policy applies whether you are accessing the Site via a personal computer, a mobile device or any other technology or devices now known or hereafter developed or discovered (each, a “Device”) and whether you are accessing the Site as a registered user or other user of the Site.  This Privacy Policy governs only the Personal Information and Other Information (as those terms are defined below) collected by the Site and does not cover any such information collected in any other manner or by any other website offered by Viacom or collected by any other company, unless specifically stated.  By submitting Personal Information and Other Information to the Site, you are consenting to it being used by Viacom in accordance with this Privacy Policy.  Viacom may from time to time combine Information (as that term is defined below) with other information Viacom collects from other sources, and, if Viacom does so, the use of the resulting combined Information will be subject to this Privacy Policy.

This Privacy Policy will remain in full force and effect, even if your use of or participation in the Site or any particular service, feature, function or activity offered through the Site terminates, expires, ceases, is suspended or deactivated for any reason.  If you do not agree with this Privacy Policy, please do not participate in the Site or use any features, activities or services offered through the Site.

2. U.S. Governing Law; Safe Harbor.

The Site is hosted in the U.S. and is governed by and operated in accordance with the laws of the U.S.  Viacom makes no representation that the Site is operated in accordance with the laws or regulations of, or governed by, other nations.  By using the Site, you certify that you meet the age and other eligibility requirements for the Site as set forth in the Site’s Terms of Use Agreement.  If you do not meet such age and other eligibility requirements, please discontinue using the Site immediately as your continued use of the Site indicates that you are agreeing to the collection, use, disclosure, management and storage of your Information as described in this Privacy Policy.


If you are located in the European Economic Area (“EEA”) and Switzerland, for detailed information on Viacom’s privacy policy and practices with respect to personal information transferred from the EEA and Switzerland, please see Viacom’s Safe Harbor Privacy Policy located at http://www.viacom.com/privacypolicy/Documents/VIACOM-610657-v1-Safe_Harbor_Policy.pdf.  In the event of a conflict between this Privacy Policy and the Safe Harbor Privacy Policy as it applies to Personal Information transferred from the EEA and Switzerland to the US, the Safe Harbor Privacy Policy shall control.

If you are located outside of the U.S., the EEA and Switzerland, you use the Site at your own risk and initiative and you, not us, are responsible for compliance with any applicable local and national laws.  Please be aware that any Personal Information and Other Information you provide to Viacom or Viacom obtain as a result of your use of the Site will be collected in the U.S. and/or transferred to the U.S. and subject to U.S. law.  By using the Site, participating in any Site activities and/or providing Viacom with your Personal Information and Other Information, you (i) consent to the transfer and/or processing of any Information to and in the U.S., (ii) acknowledge that U.S. law may provide a lower standard of protection for personal data than the laws of your location, and (iii) understand that Viacom will collect, transfer, store, process and/or deal with your Information in accordance with this Privacy Policy and U.S. law.  Consequently, to the full extent permitted by law, you hereby waive any claims relating to the processing of your Personal Information or Other Information in accordance with this Privacy Policy that may arise under the laws and regulations that apply to you in or of any other country or jurisdiction.

3. Collection and Use of Personal Information and Other Information.

 The term "Personal Information" means information that is recorded in any form and that identifies or could be used by or on behalf of Viacom to identify you or contact you, such as your full name, postal address, email address or telephone number.   The term “Other Information” means any information other than Personal Information that may be collected about you (Personal Information and Other Information, together, the “Information”).  Any Personal Information that is de-identified shall no longer be considered Personal Information but will considered Other Information after such de-identification. On the other hand, when Other Information is combined with Personal Information, we will treat the combined Information as Personal Information for purposes of sharing or disclosure of such combined Information.

a.  Information Viacom Collects that You Provide Us.

i. User Registration.  To register through the Site, you will be required to provide Personal Information, such as your name, address, email address, phone number, and, if you are located in the United States, a social security number or EIN.  Additional Information may be requested during the registration process (but not required).

ii. User Name and Password.  During the registration process, you may be required to select a user name and password (together, your “User ID”). 

b. Information Collected Through Use of Cookies and Other Tracking Technologies.

"Cookies" (which may be html or browser-based files, Flash files, local shared objects or other technology) are text or other files that help store user preferences and activity. “Web beacons” (also known as image tags, gif, tracking pixels or web bugs) are small pieces of code used to collect data, such as counting page views, promotion views or advertising responses.  The Site and/or third parties may use “cookies”, “web beacons” and other similar tracking technologies (collectively, “Tracking Technologies”) to collect Other Information automatically as you browse the Site and the web.

Viacom may use Tracking Technologies to help tailor the Site’s content, allow users to move between associated sites without logging into each site, understand Site and internet usage, improve or customize the content or offerings on the Site, personalize your experience on the Site (for example, to recognize you by name when you return to the Site), save your password in password-protected areas, enable you to use shopping carts on the Site, maintain and administer the Site and for other purposes described in the "Use of Information", "Other Information Collected by Us" section below.  Such Tracking Technologies collect “click stream” data and additional Other Information regarding your visits to the Site and may also collect your IP address or some other identifier unique to the Device you use to access the Site (“Identifier”).  An Identifier is automatically assigned to any Device you use to access the Site.  Your Personal Information is not collected as part of this process but Viacom may associate Other Information collected by Tracking Technologies with Personal Information.

By visiting the Site, whether as a registered user or otherwise, you acknowledge, understand and hereby agree that you are giving Viacom your consent to track your activities and your use of the Site through such Tracking Technologies.

The Site may additionally use a variety of traffic measurement service providers, marketing analytics service providers and other third parties (collectively, “Third Party Analytics Service Providers”) to, for example, measure and analyze traffic on the Site (“Targeting Services”).

These Third Party Analytics Service Providers do not have access to Tracking Technologies set by the Site except to the extent necessary to provide services to the Site.  The Third Party Analytics Service Providers may themselves set and access their own Tracking Technologies on your Device if you choose to have Tracking Technologies enabled in your browser (or, for Flash cookies, if you have not removed them) and/or they may otherwise have access to Other Information about you.

c. Use of Information. 

 As set forth in this Privacy Policy, Viacom may share Information among the various entities making up Viacom.

i. Personal Information.  The Site uses the Personal Information Viacom collects from you in a variety of ways, including:

  • Processing your registration with the Site, such as verifying that your email address is active and valid;
  • Contacting you regarding the administration of your account, any services, features or functions you have enrolled in or registered to use, or any other transactions you have undertaken with the Site;
  • Allowing you to participate in the public areas and/or other features of the Site;
  • Responding to your questions or other requests;
  • Contacting you regarding your use of the Site, for informational purposes related to the Site or, in Viacom’s discretion, regarding changes to the Site’s policies;
  • Improving the Site or the Site’s services and for internal business purposes; 
  • Tailoring your experience on the Site and/or otherwise customizing what you see when you visit the Site;
  • Saving your User ID or other Personal Information, so you don’t have to re-enter it each time you visit the Site;
  • Otherwise to maintain and administer the Site; and
  • For other purposes disclosed at the time you provide the Personal Information.

ii. Other Information Collected by Us.  Viacom may use the Other Information collected from you through the Site in a variety of ways, including: 

  • Keeping count of your return visits to the Site or Viacom’s or partners' sites; 
  • Accumulating and reporting aggregate, statistical information in connection with the Site and user activity; 
  • Determining which features, webpages and services users like best to, among other things, help Viacom operate the Site, enhance and improve the Site’s services and the Site and display information; 
  • Preparing statistics reports;
  • Allowing you to participate in the public areas and/or other features of the Site;
  • Improving the Site or our services and for internal business purposes; 
  • Tailoring your experience on the Site and/or otherwise customizing what you see when you visit the Site; 
  • Saving certain Other Information for use on your return visits to the Site; 
  • Otherwise to maintain and administer the Site; 
  • For the uses described for “Personal Information” above; and
  • For other purposes disclosed at the time you provide the Other Information.

iii. Other Information Collected by Third Party Analytics Service Providers.  The use of Tracking Technologies by Third Party Analytics Service Providers is within their control and not Viacom’s.  Even if Viacom has a relationship with the Third Party Analytics Service Provider, Viacom does not control their websites or their policies and practices regarding your Information and you should be aware that different rules might apply to the collection, use or disclosure of your Information by third parties you encounter on the Internet.  This Privacy Policy does not cover any use of Information that a Third Party Analytics Service Provider may directly collect from you.  Use of Third Party Analytics Service Providers’ Tracking Technologies is governed by the Third Party Analytics Service Providers’ own specific privacy policies and not this Privacy Policy.  However, please see “Opting-out of Certain Uses of your Personal Information and Other Information” Section for more information on how to opt-out of the collection and/or use of Information collected by certain Third Party Analytics Service Providers.

4. Opting-out of Certain Uses of your Personal Information and Other Information.

a. Tracking Technologies Set By Third Party Analytics Service Providers.  With respect to the Tracking Technologies set by Third Party Analytics Service Providers, you have a number of options:

  • Third Party Analytics Service Providers may collect Other Information about you when you visit the Site to help identify products and services that may interest you. 
  • Some of these Third Party Analytics Service Providers may participate in the Network Advertising Initiative’s Opt-Out Tool.  Please click on the link to these tools to learn more about your choices.  
  • Please note the following with respect to opting out:
    • The opt-out tools discussed above are “cookie based.”  This means that the tools rely on cookies to remember your choices with respect to the use of your information by the parties that offer you those choices.  If you delete Tracking Technologies using the controls in your Web browser (a process described below) after opting out, you may have to opt out again to re-establish your opt-out preferences.  
    • Opt-outs are “browser-specific.”  The opt-out preferences that you choose will apply only to the Web browser that you used when you selected these preferences.  This means, for example, that if you opt-out while using Internet Explorer 9, this choice will not affect the use of Other Information collected by Tracking Technologies when you use Mozilla Firefox on the same Device.  It also means that opting-out on one Device will not affect the use of Other Information by Tracking Technologies on other Devices that you may use to access the Site.
  • You also can prevent the use of certain Tracking Technologies (other than Flash cookies) on a particular Device by using the controls in your Web browser.  To do so, you must:
    • Delete existing Tracking Technologies through the “Internet Options” sub-option of the “Tools” menu option of your browser or otherwise as directed by your browser’s support feature; and
    • Disable future Tracking Technologies through the same browser controls.  Additional information on enabling or disabling most Tracking Technologies may be available through your browser’s support feature.  (See the “help” section of your browser for more information.)
  • You can choose to have the Device you use to access the Site warn you each time a cookie or most other Tracking Technologies is being set (other than Flash cookies), or you can choose to turn off such warnings.  This is done through your browser on the Device you use to access the Site.  Additional information on warnings and removal of warnings may be available through your browser’s support feature.
  • PLEASE NOTE THAT THE USE AND STORAGE OF FLASH COOKIES TYPICALLY CANNOT BE CONTROLLED THROUGH YOUR BROWSER.  PLEASE SEE BELOW FOR INFORMATION ON HOW TO MANAGE FLASH COOKIES. 

b. Tracking Technologies Set By the Site.  With respect to the Tracking Technologies set by the Site, you have a number of options:

  • You can prevent the use of certain Tracking Technologies (other than Flash cookies) by using the controls in your Web browser.  To do so, you must:
    • Delete existing Tracking Technologies through the “Internet Options” sub-option of the “Tools” menu option of your browser or otherwise as directed by your browser’s support feature; and
    • Disable future Tracking Technologies through the same browser controls.  Additional information on enabling or disabling most Tracking Technologies may be available through your browser’s support feature.  (See the “help” section of your browser for more information.)
  • You can choose to have the Device you use to access the Site warn you each time a cookie or most other Tracking Technologies is being set (other than Flash cookies), or you can choose to turn off such warnings.  This is done through your browser on the Device you use to access the Site.  Additional information on warnings and removal of warnings may be available through your browser’s support feature.

Viacom is committed to complying with the Self-Regulatory Principles for Online Behavioral Advertising.  Click here for more information about Viacom and online behavioral advertising.

Some Device manufacturers may preset their browsers to block Tracking Technologies from websites other than those you visit directly and, if so, certain services may not work for such Devices.  Further, if you delete, reject, disable or turn off Tracking Technologies, you may not have access to certain features of the Site and some of the Site’s other services may not function properly.

c. Flash Cookies. lease note that deleting, rejecting, disabling or turning off Tracking Technologies set by Third Party Analytics Service Providers and set by the Site through the above options will not remove Flash cookies.  For more information about Flash cookies and how to remove them from your computer, please visit http://kb2.adobe.com/cps/526/52697ee8.html.

5.  Sharing and Disclosure of Personal Information and Other Information.

a. Sharing and Disclosure of Personal Information.

Generally, Viacom does not sell, rent, lease or disclose your Personal Information to third parties, except if you consent to such disclosure or as described in this Privacy Policy.

i. Disclosure to Other Entities within Viacom.  Viacom may disclose Personal Information to the various entities making up Viacom for administrative and/or other purposes. 

ii.  Disclosure to Operational Service Providers. Viacom reserves the right to provide your Personal Information and Other Information to third parties for the purpose of administering and maintaining the Site’s services, features, functions and operations.  Viacom will refer to these third parties as “operational service providers”.  Viacom uses operational service providers to efficiently provide the full range of content, activities, services, features and functions Viacom brings you and Viacom discloses your Information to operational service providers for the purpose of providing services to us. 

iii.  Disclosure to Certain Other Third Parties.   In addition to the above, Viacom will make your Personal Information and Other Information available to certain third parties in the following limited circumstances:

  • When Viacom is compelled to do so by a governmental agency, court or other entity (e.g., to respond to subpoenas, court orders or legal process) or if requested by a governmental agency or other authority as part of an investigation; 
  • If Viacom believes your actions violate any law, rule, regulation and/or the Terms of Use Agreement, including, without limitation, this Privacy Policy, Rules or Additional Terms; 
  • If you opt-in or otherwise agree to have your Personal Information shared with or otherwise disclosed to a third party for marketing purposes, in which case the third party’s use of your Information is subject to the third party’s own privacy policy;
  • If, in Viacom’s sole discretion, Viacom believes such disclosure to be necessary or appropriate: to investigate or resolve possible problems or inquiries; to protect Viacom’s business and assets or the rights, property or safety of the Site, Viacom or any of its or their operational service providers, licensors, suppliers, customers, users, or any other party; to limit Viacom’s legal liability; to defend Viacom’s interests; to enforce this Privacy Policy or the Terms of Use Agreement and/or to comply with Viacom’s legal and regulatory obligations or requests by law enforcement agencies or governmental authorities and/or
  • In the event of a bankruptcy, merger, acquisition, sale, transfer of control, joint venture or other business combination involving an entity making up Viacom.

b. Sharing and Disclosure of Other Information.  Viacom may share or otherwise disclose Other Information with third parties, but Viacom does not disclose Personal Information to them except as described in this Privacy Policy. 

6. Reviewing, Updating or Deleting Certain Information.

Generally, you may review or update certain Personal Information collected by the Site by emailing Viacom at vendorsetup@viacom.com.  Personal Information that is required to check eligibility or for internal auditing purposes, as well as Personal Information included in sales invoice, purchase invoice or tax documents may be modified with sufficient verification of the correct information. To the extent Viacom requires you to select a User ID to register for the Site, Viacom may allow you to change the password portion of your User ID, as well as certain other Information you have given Viacom in order to keep your information current, but once you select a user name you will not be able to change that user name provided to Viacom during registration and which is associated with your User ID. 

If the burden or expense of providing access to your Information is disproportionate to the risks to your privacy or if the legitimate rights of others would be violated, Viacom may decide not to provide access to such Information. In such cases, Viacom will provide to you an explanation of why access cannot be provided and contact information for further inquiries. 

7. Protection of Information.

While no data transmission over the Internet is 100% secure from intrusion, Viacom maintains commercially reasonable physical, electronic and procedural safeguards to protect your Information.  However, regardless of Viacom’s efforts and the Device you use to access the Site, it is possible that third parties may unlawfully intercept or access transmissions or private communications over an unsecured transmission.  Viacom limits access to the Site by Viacom’s own employees to those individuals who are authorized for the proper handling of such information and any employee found violating Viacom’s standards of security and confidentiality will be subject to Viacom’s disciplinary processes.  Viacom requests that its operational service providers follow similar standards of security and confidentiality.

Phishing.  Phishing attacks attempt to steal consumers’ personal identity data and financial account credentials.  “Phishers” use ‘spoofed’ emails to lead consumers to counterfeit websites designed to trick recipients into divulging Information such as credit card numbers, account usernames, passwords and social security numbers.  VIACOM DOES NOT SEND EMAILS ASKING YOU TO PROVIDE OR CONFIRM CREDIT CARD NUMBERS, SOCIAL SECURITY NUMBERS OR YOUR USERNAME OR PASSWORD!  If you receive such email communication, please forward it immediately to the Site’s Privacy Administrator at vendorsetup@viacom.com, and then immediately delete the fraudulent email from your computer.

8. Jurisdictional Rights. 

  • California Privacy Rights
    • If you are a resident of the State of California, we provide you with notice and choice over disclosure of your Personal Information to third parties for marketing purposes (see “Sharing and Disclosure of Personal Information and Other Information” above).  Therefore, pursuant to the California Civil Code, the notice and choice we provide regarding disclosure of your Personal Information to third parties for marketing purposes (and this Section) satisfies our obligation to otherwise maintain or furnish users with a list of the names and addresses of third parties who receive Personal Information from us for marketing purposes.
    • If you are a California resident and have additional questions on our sharing of your Personal Information to third parties for marketing purposes, you may send us your questions by email to the Privacy Administrator at privacy@viacom.com .
    • All requests must be labeled "Your California Privacy Rights" on the email subject line. For all requests, please clearly state that the request is related to “Your California Privacy Rights”, include your name, street address, city, state, zip code and email address (your street address is optional if you wish to receive a response to your request via email), include the name and URL (if applicable) of the website, application or other interactive service and indicate your preference on how our response to your request should be sent.  We will not accept requests via postal mail, the telephone or by facsimile. We are not responsible for notices that are not labeled or sent properly, or may not be able to respond if you do not provide complete information

9. Changes to this Privacy Policy and Notice.

Viacom reserves the right to revise this Privacy Policy at any time by posting an updated Privacy Policy without advance notice to you.  Such revisions shall be effective immediately upon posting.  Notice of material changes will be posted on the Site’s homepage and/or will be provided by emailing you or notifying you upon login about these changes; the form of such notice is at Viacom’s discretion.  However, Viacom encourages you to check this Privacy Policy and Terms of Use Agreement often for updates.   

10. Miscellaneous.

a. Accuracy and Confidentiality.   It is your responsibility to give us current, complete, truthful and accurate information, including Personal Information, and to keep such information up to date.  Viacom cannot and will not be responsible for any problems or liability that may arise if you do not give Viacom accurate, truthful or complete information or Personal Information or you fail to update such information or Personal Information.  Viacom will reject and delete any entry that Viacom believes in good faith to be false, fraudulent or inconsistent with this Privacy Policy.

b. Questions. If you have questions about this Privacy Policy or if you do not understand any information about how Viacom collects, maintains, uses or shares your Personal Information or Other Information, you may contact Viacom directly by sending an email to vendorsetup@viacom.com or please contact Viacom’s Privacy Administrator/Vendor Setup at 212-846-5070 from 9am to 9pm (Eastern time).

c. Sole Statement: This document is the sole statement of the Site’s Privacy Policy and no summary, restatement or other version thereof, or other privacy statement or policy, in any form, including, but not limited to, machine-generated, is valid.

d. Other:  Please review the Site’s Terms of Use Agreement which governs your use of the Site.  Any terms that are not defined in this Privacy Policy shall have the meaning given in the Terms of Use Agreement

This Privacy Policy was last modified on the date indicated above and is effective immediately.

 

PRIVACY POLICY AND YOUR CALIFORNIA PRIVACY RIGHTS

This is the privacy policy (“Privacy Policy”) for the Viacom Supplier Workplace for Invoice Management (“SWIM”) registration website ("Site"), an Internet website operated by Viacom Inc. (the “Parent Company”) that provides suppliers the ability to register and provide certain financial and payment information in connection with provision of services to the Parent Company and/or its subsidiaries or corporate affiliates (together with the Parent Company, "Viacom") and to receive and/or provide information regarding ongoing billing relating to such suppliers.  This Privacy Policy governs only the content features and activities related to the Site (i.e., the SWIM registration website) and does not cover websites for any individual Viacom programming channel, any other websites or portion of a website provided by or for Viacom (including www.viacom.com), or any websites for any other company, unless specifically stated.

This Privacy Policy is intended to explain our privacy practices and covers the following areas:

1. When This Privacy Policy Applies.

This Privacy Policy applies whether you are accessing the Site via a personal computer, a mobile device or any other technology or devices now known or hereafter developed or discovered (each, a “Device”) and whether you are accessing the Site as a registered user or other user of the Site.  This Privacy Policy governs only the Personal Information and Other Information (as those terms are defined below) collected by the Site and does not cover any such information collected in any other manner or by any other website offered by Viacom or collected by any other company, unless specifically stated.  By submitting Personal Information and Other Information to the Site, you are consenting to it being used by Viacom in accordance with this Privacy Policy.  Viacom may from time to time combine Information (as that term is defined below) with other information Viacom collects from other sources, and, if Viacom does so, the use of the resulting combined Information will be subject to this Privacy Policy.

This Privacy Policy will remain in full force and effect, even if your use of or participation in the Site or any particular service, feature, function or activity offered through the Site terminates, expires, ceases, is suspended or deactivated for any reason.  If you do not agree with this Privacy Policy, please do not participate in the Site or use any features, activities or services offered through the Site.

2. U.S. Governing Law; Safe Harbor.

The Site is hosted in the U.S. and is governed by and operated in accordance with the laws of the U.S.  Viacom makes no representation that the Site is operated in accordance with the laws or regulations of, or governed by, other nations.  By using the Site, you certify that you meet the age and other eligibility requirements for the Site as set forth in the Site’s Terms of Use Agreement.  If you do not meet such age and other eligibility requirements, please discontinue using the Site immediately as your continued use of the Site indicates that you are agreeing to the collection, use, disclosure, management and storage of your Information as described in this Privacy Policy.


If you are located in the European Economic Area (“EEA”) and Switzerland, for detailed information on Viacom’s privacy policy and practices with respect to personal information transferred from the EEA and Switzerland, please see Viacom’s Safe Harbor Privacy Policy located at http://www.viacom.com/privacypolicy/Documents/VIACOM-610657-v1-Safe_Harbor_Policy.pdf.  In the event of a conflict between this Privacy Policy and the Safe Harbor Privacy Policy as it applies to Personal Information transferred from the EEA and Switzerland to the US, the Safe Harbor Privacy Policy shall control.

If you are located outside of the U.S., the EEA and Switzerland, you use the Site at your own risk and initiative and you, not us, are responsible for compliance with any applicable local and national laws.  Please be aware that any Personal Information and Other Information you provide to Viacom or Viacom obtain as a result of your use of the Site will be collected in the U.S. and/or transferred to the U.S. and subject to U.S. law.  By using the Site, participating in any Site activities and/or providing Viacom with your Personal Information and Other Information, you (i) consent to the transfer and/or processing of any Information to and in the U.S., (ii) acknowledge that U.S. law may provide a lower standard of protection for personal data than the laws of your location, and (iii) understand that Viacom will collect, transfer, store, process and/or deal with your Information in accordance with this Privacy Policy and U.S. law.  Consequently, to the full extent permitted by law, you hereby waive any claims relating to the processing of your Personal Information or Other Information in accordance with this Privacy Policy that may arise under the laws and regulations that apply to you in or of any other country or jurisdiction.

3. Collection and Use of Personal Information and Other Information.

 The term "Personal Information" means information that is recorded in any form and that identifies or could be used by or on behalf of Viacom to identify you or contact you, such as your full name, postal address, email address or telephone number.   The term “Other Information” means any information other than Personal Information that may be collected about you (Personal Information and Other Information, together, the “Information”).  Any Personal Information that is de-identified shall no longer be considered Personal Information but will considered Other Information after such de-identification. On the other hand, when Other Information is combined with Personal Information, we will treat the combined Information as Personal Information for purposes of sharing or disclosure of such combined Information.

a.  Information Viacom Collects that You Provide Us.

i. User Registration.  To register through the Site, you will be required to provide Personal Information, such as your name, address, email address, phone number, and, if you are located in the United States, a social security number or EIN.  Additional Information may be requested during the registration process (but not required).

ii. User Name and Password.  During the registration process, you may be required to select a user name and password (together, your “User ID”). 

b. Information Collected Through Use of Cookies and Other Tracking Technologies.

"Cookies" (which may be html or browser-based files, Flash files, local shared objects or other technology) are text or other files that help store user preferences and activity. “Web beacons” (also known as image tags, gif, tracking pixels or web bugs) are small pieces of code used to collect data, such as counting page views, promotion views or advertising responses.  The Site and/or third parties may use “cookies”, “web beacons” and other similar tracking technologies (collectively, “Tracking Technologies”) to collect Other Information automatically as you browse the Site and the web.

Viacom may use Tracking Technologies to help tailor the Site’s content, allow users to move between associated sites without logging into each site, understand Site and internet usage, improve or customize the content or offerings on the Site, personalize your experience on the Site (for example, to recognize you by name when you return to the Site), save your password in password-protected areas, enable you to use shopping carts on the Site, maintain and administer the Site and for other purposes described in the "Use of Information", "Other Information Collected by Us" section below.  Such Tracking Technologies collect “click stream” data and additional Other Information regarding your visits to the Site and may also collect your IP address or some other identifier unique to the Device you use to access the Site (“Identifier”).  An Identifier is automatically assigned to any Device you use to access the Site.  Your Personal Information is not collected as part of this process but Viacom may associate Other Information collected by Tracking Technologies with Personal Information.

By visiting the Site, whether as a registered user or otherwise, you acknowledge, understand and hereby agree that you are giving Viacom your consent to track your activities and your use of the Site through such Tracking Technologies.

The Site may additionally use a variety of traffic measurement service providers, marketing analytics service providers and other third parties (collectively, “Third Party Analytics Service Providers”) to, for example, measure and analyze traffic on the Site (“Targeting Services”).

These Third Party Analytics Service Providers do not have access to Tracking Technologies set by the Site except to the extent necessary to provide services to the Site.  The Third Party Analytics Service Providers may themselves set and access their own Tracking Technologies on your Device if you choose to have Tracking Technologies enabled in your browser (or, for Flash cookies, if you have not removed them) and/or they may otherwise have access to Other Information about you.

c. Use of Information. 

 As set forth in this Privacy Policy, Viacom may share Information among the various entities making up Viacom.

i. Personal Information.  The Site uses the Personal Information Viacom collects from you in a variety of ways, including:

  • Processing your registration with the Site, such as verifying that your email address is active and valid;
  • Contacting you regarding the administration of your account, any services, features or functions you have enrolled in or registered to use, or any other transactions you have undertaken with the Site;
  • Allowing you to participate in the public areas and/or other features of the Site;
  • Responding to your questions or other requests;
  • Contacting you regarding your use of the Site, for informational purposes related to the Site or, in Viacom’s discretion, regarding changes to the Site’s policies;
  • Improving the Site or the Site’s services and for internal business purposes; 
  • Tailoring your experience on the Site and/or otherwise customizing what you see when you visit the Site;
  • Saving your User ID or other Personal Information, so you don’t have to re-enter it each time you visit the Site;
  • Otherwise to maintain and administer the Site; and
  • For other purposes disclosed at the time you provide the Personal Information.

ii. Other Information Collected by Us.  Viacom may use the Other Information collected from you through the Site in a variety of ways, including: 

  • Keeping count of your return visits to the Site or Viacom’s or partners' sites; 
  • Accumulating and reporting aggregate, statistical information in connection with the Site and user activity; 
  • Determining which features, webpages and services users like best to, among other things, help Viacom operate the Site, enhance and improve the Site’s services and the Site and display information; 
  • Preparing statistics reports;
  • Allowing you to participate in the public areas and/or other features of the Site;
  • Improving the Site or our services and for internal business purposes; 
  • Tailoring your experience on the Site and/or otherwise customizing what you see when you visit the Site; 
  • Saving certain Other Information for use on your return visits to the Site; 
  • Otherwise to maintain and administer the Site; 
  • For the uses described for “Personal Information” above; and
  • For other purposes disclosed at the time you provide the Other Information.

iii. Other Information Collected by Third Party Analytics Service Providers.  The use of Tracking Technologies by Third Party Analytics Service Providers is within their control and not Viacom’s.  Even if Viacom has a relationship with the Third Party Analytics Service Provider, Viacom does not control their websites or their policies and practices regarding your Information and you should be aware that different rules might apply to the collection, use or disclosure of your Information by third parties you encounter on the Internet.  This Privacy Policy does not cover any use of Information that a Third Party Analytics Service Provider may directly collect from you.  Use of Third Party Analytics Service Providers’ Tracking Technologies is governed by the Third Party Analytics Service Providers’ own specific privacy policies and not this Privacy Policy.  However, please see “Opting-out of Certain Uses of your Personal Information and Other Information” Section for more information on how to opt-out of the collection and/or use of Information collected by certain Third Party Analytics Service Providers.

4. Opting-out of Certain Uses of your Personal Information and Other Information.

a. Tracking Technologies Set By Third Party Analytics Service Providers.  With respect to the Tracking Technologies set by Third Party Analytics Service Providers, you have a number of options:

  • Third Party Analytics Service Providers may collect Other Information about you when you visit the Site to help identify products and services that may interest you. 
  • Some of these Third Party Analytics Service Providers may participate in the Network Advertising Initiative’s Opt-Out Tool.  Please click on the link to these tools to learn more about your choices.  
  • Please note the following with respect to opting out:
    • The opt-out tools discussed above are “cookie based.”  This means that the tools rely on cookies to remember your choices with respect to the use of your information by the parties that offer you those choices.  If you delete Tracking Technologies using the controls in your Web browser (a process described below) after opting out, you may have to opt out again to re-establish your opt-out preferences.  
    • Opt-outs are “browser-specific.”  The opt-out preferences that you choose will apply only to the Web browser that you used when you selected these preferences.  This means, for example, that if you opt-out while using Internet Explorer 9, this choice will not affect the use of Other Information collected by Tracking Technologies when you use Mozilla Firefox on the same Device.  It also means that opting-out on one Device will not affect the use of Other Information by Tracking Technologies on other Devices that you may use to access the Site.
  • You also can prevent the use of certain Tracking Technologies (other than Flash cookies) on a particular Device by using the controls in your Web browser.  To do so, you must:
    • Delete existing Tracking Technologies through the “Internet Options” sub-option of the “Tools” menu option of your browser or otherwise as directed by your browser’s support feature; and
    • Disable future Tracking Technologies through the same browser controls.  Additional information on enabling or disabling most Tracking Technologies may be available through your browser’s support feature.  (See the “help” section of your browser for more information.)
  • You can choose to have the Device you use to access the Site warn you each time a cookie or most other Tracking Technologies is being set (other than Flash cookies), or you can choose to turn off such warnings.  This is done through your browser on the Device you use to access the Site.  Additional information on warnings and removal of warnings may be available through your browser’s support feature.
  • PLEASE NOTE THAT THE USE AND STORAGE OF FLASH COOKIES TYPICALLY CANNOT BE CONTROLLED THROUGH YOUR BROWSER.  PLEASE SEE BELOW FOR INFORMATION ON HOW TO MANAGE FLASH COOKIES. 

b. Tracking Technologies Set By the Site.  With respect to the Tracking Technologies set by the Site, you have a number of options:

  • You can prevent the use of certain Tracking Technologies (other than Flash cookies) by using the controls in your Web browser.  To do so, you must:
    • Delete existing Tracking Technologies through the “Internet Options” sub-option of the “Tools” menu option of your browser or otherwise as directed by your browser’s support feature; and
    • Disable future Tracking Technologies through the same browser controls.  Additional information on enabling or disabling most Tracking Technologies may be available through your browser’s support feature.  (See the “help” section of your browser for more information.)
  • You can choose to have the Device you use to access the Site warn you each time a cookie or most other Tracking Technologies is being set (other than Flash cookies), or you can choose to turn off such warnings.  This is done through your browser on the Device you use to access the Site.  Additional information on warnings and removal of warnings may be available through your browser’s support feature.

Viacom is committed to complying with the Self-Regulatory Principles for Online Behavioral Advertising.  Click here for more information about Viacom and online behavioral advertising.

Some Device manufacturers may preset their browsers to block Tracking Technologies from websites other than those you visit directly and, if so, certain services may not work for such Devices.  Further, if you delete, reject, disable or turn off Tracking Technologies, you may not have access to certain features of the Site and some of the Site’s other services may not function properly.

c. Flash Cookies. lease note that deleting, rejecting, disabling or turning off Tracking Technologies set by Third Party Analytics Service Providers and set by the Site through the above options will not remove Flash cookies.  For more information about Flash cookies and how to remove them from your computer, please visithttp://kb2.adobe.com/cps/526/52697ee8.html.

5.  Sharing and Disclosure of Personal Information and Other Information.

a. Sharing and Disclosure of Personal Information.

Generally, Viacom does not sell, rent, lease or disclose your Personal Information to third parties, except if you consent to such disclosure or as described in this Privacy Policy.

i. Disclosure to Other Entities within Viacom.  Viacom may disclose Personal Information to the various entities making up Viacom for administrative and/or other purposes. 

ii.  Disclosure to Operational Service Providers. Viacom reserves the right to provide your Personal Information and Other Information to third parties for the purpose of administering and maintaining the Site’s services, features, functions and operations.  Viacom will refer to these third parties as “operational service providers”.  Viacom uses operational service providers to efficiently provide the full range of content, activities, services, features and functions Viacom brings you and Viacom discloses your Information to operational service providers for the purpose of providing services to us. 

iii.  Disclosure to Certain Other Third Parties.   In addition to the above, Viacom will make your Personal Information and Other Information available to certain third parties in the following limited circumstances:

  • When Viacom is compelled to do so by a governmental agency, court or other entity (e.g., to respond to subpoenas, court orders or legal process) or if requested by a governmental agency or other authority as part of an investigation; 
  • If Viacom believes your actions violate any law, rule, regulation and/or the Terms of Use Agreement, including, without limitation, this Privacy Policy, Rules or Additional Terms; 
  • If you opt-in or otherwise agree to have your Personal Information shared with or otherwise disclosed to a third party for marketing purposes, in which case the third party’s use of your Information is subject to the third party’s own privacy policy;
  • If, in Viacom’s sole discretion, Viacom believes such disclosure to be necessary or appropriate: to investigate or resolve possible problems or inquiries; to protect Viacom’s business and assets or the rights, property or safety of the Site, Viacom or any of its or their operational service providers, licensors, suppliers, customers, users, or any other party; to limit Viacom’s legal liability; to defend Viacom’s interests; to enforce this Privacy Policy or the Terms of Use Agreement and/or to comply with Viacom’s legal and regulatory obligations or requests by law enforcement agencies or governmental authorities and/or
  • In the event of a bankruptcy, merger, acquisition, sale, transfer of control, joint venture or other business combination involving an entity making up Viacom.

b. Sharing and Disclosure of Other Information.  Viacom may share or otherwise disclose Other Information with third parties, but Viacom does not disclose Personal Information to them except as described in this Privacy Policy. 

6. Reviewing, Updating or Deleting Certain Information.

Generally, you may review or update certain Personal Information collected by the Site by emailing Viacom at vendorsetup@viacom.com.  Personal Information that is required to check eligibility or for internal auditing purposes, as well as Personal Information included in sales invoice, purchase invoice or tax documents may be modified with sufficient verification of the correct information. To the extent Viacom requires you to select a User ID to register for the Site, Viacom may allow you to change the password portion of your User ID, as well as certain other Information you have given Viacom in order to keep your information current, but once you select a user name you will not be able to change that user name provided to Viacom during registration and which is associated with your User ID. 

If the burden or expense of providing access to your Information is disproportionate to the risks to your privacy or if the legitimate rights of others would be violated, Viacom may decide not to provide access to such Information. In such cases, Viacom will provide to you an explanation of why access cannot be provided and contact information for further inquiries. 

7. Protection of Information.

While no data transmission over the Internet is 100% secure from intrusion, Viacom maintains commercially reasonable physical, electronic and procedural safeguards to protect your Information.  However, regardless of Viacom’s efforts and the Device you use to access the Site, it is possible that third parties may unlawfully intercept or access transmissions or private communications over an unsecured transmission.  Viacom limits access to the Site by Viacom’s own employees to those individuals who are authorized for the proper handling of such information and any employee found violating Viacom’s standards of security and confidentiality will be subject to Viacom’s disciplinary processes.  Viacom requests that its operational service providers follow similar standards of security and confidentiality.

Phishing.  Phishing attacks attempt to steal consumers’ personal identity data and financial account credentials.  “Phishers” use ‘spoofed’ emails to lead consumers to counterfeit websites designed to trick recipients into divulging Information such as credit card numbers, account usernames, passwords and social security numbers.  VIACOM DOES NOT SEND EMAILS ASKING YOU TO PROVIDE OR CONFIRM CREDIT CARD NUMBERS, SOCIAL SECURITY NUMBERS OR YOUR USERNAME OR PASSWORD!  If you receive such email communication, please forward it immediately to the Site’s Privacy Administrator at vendorsetup@viacom.com, and then immediately delete the fraudulent email from your computer.

8. Jurisdictional Rights. 

  • California Privacy Rights
    • If you are a resident of the State of California, we provide you with notice and choice over disclosure of your Personal Information to third parties for marketing purposes (see “Sharing and Disclosure of Personal Information and Other Information” above).  Therefore, pursuant to the California Civil Code, the notice and choice we provide regarding disclosure of your Personal Information to third parties for marketing purposes (and this Section) satisfies our obligation to otherwise maintain or furnish users with a list of the names and addresses of third parties who receive Personal Information from us for marketing purposes. 
    • If you are a California resident and have additional questions on our sharing of your Personal Information to third parties for marketing purposes, you may send us your questions by email to the Privacy Administrator atprivacy@viacom.com .
    • All requests must be labeled "Your California Privacy Rights" on the email subject line. For all requests, please clearly state that the request is related to “Your California Privacy Rights”, include your name, street address, city, state, zip code and email address (your street address is optional if you wish to receive a response to your request via email), include the name and URL (if applicable) of the website, application or other interactive service and indicate your preference on how our response to your request should be sent.  We will not accept requests via postal mail, the telephone or by facsimile. We are not responsible for notices that are not labeled or sent properly, or may not be able to respond if you do not provide complete information

9. Changes to this Privacy Policy and Notice.

Viacom reserves the right to revise this Privacy Policy at any time by posting an updated Privacy Policy without advance notice to you.  Such revisions shall be effective immediately upon posting.  Notice of material changes will be posted on the Site’s homepage and/or will be provided by emailing you or notifying you upon login about these changes; the form of such notice is at Viacom’s discretion.  However, Viacom encourages you to check this Privacy Policy and Terms of Use Agreement often for updates.  

10. Miscellaneous.

a. Accuracy and Confidentiality.   It is your responsibility to give us current, complete, truthful and accurate information, including Personal Information, and to keep such information up to date.  Viacom cannot and will not be responsible for any problems or liability that may arise if you do not give Viacom accurate, truthful or complete information or Personal Information or you fail to update such information or Personal Information.  Viacom will reject and delete any entry that Viacom believes in good faith to be false, fraudulent or inconsistent with this Privacy Policy.

b. Questions. If you have questions about this Privacy Policy or if you do not understand any information about how Viacom collects, maintains, uses or shares your Personal Information or Other Information, you may contact Viacom directly by sending an email to vendorsetup@viacom.com or please contact Viacom’s Privacy Administrator/Vendor Setup at 212-846-5070 from 9am to 9pm (Eastern time).

c. Sole Statement: This document is the sole statement of the Site’s Privacy Policy and no summary, restatement or other version thereof, or other privacy statement or policy, in any form, including, but not limited to, machine-generated, is valid.

d. Other:  Please review the Site’s Terms of Use Agreement which governs your use of the Site.  Any terms that are not defined in this Privacy Policy shall have the meaning given in the Terms of Use Agreement

This Privacy Policy was last modified on the date indicated above and is effective immediately.

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