Privacy Policy


MSGN Holdings, L.P.

Mobile Application Privacy Policy

Effective Date:  October 1, 2015

MSGN Holdings, L.P. (“MSGN”) and the MSGN Family (as hereinafter defined) are committed to safeguarding your privacy. The purpose of this Mobile Application Privacy Policy (“MAPP”) is to ensure that you understand the measures that MSGN takes in order to protect your information and to provide transparency regarding what information it collects, how we use it, and when and with whom we may share it in connection with the provision of this MSGN mobile application and the products, services and other materials provided or made available on or through such mobile application (collectively, the “Application”).

This MAPP applies regardless of the device used to access and use the Application. Any Application that is governed by this MAPP will include a link to, and/or copy of this MAPP in the Application (e.g, on a settings page and/or during the downloading, registration or set-up of the Application). You are bound by this MAPP if you download, install, complete a registration or otherwise use any Application or similar product or service where you are presented with or may access this MAPP. If you do not agree to this MAPP, then you may not use the Application or access the content or any services in the Application.

This MAPP applies only to information collected on or through the Application. It does not apply to information collected or obtained by or through any other means (including, without limitation, information collected offline, in-person, over the telephone or by mail, e.g., from a telephonic survey, mail-in sweepstakes entry form and/or in-person at an event).  For information that is collected on or through the MSGN websites, please see the MSGN Privacy Policy located at http://corporate.msgnetworks.com/privacy.

Before you submit any information on or through the Application, please carefully review this MAPP. By downloading and/or using the Application in any manner, you consent to the collection, use, disclosure, sharing and protection of your information as further outlined below in this MAPP. We will continue to evaluate this MAPP as we update and expand the products, services, and offerings made available through the Application, and we may make changes to the MAPP accordingly. Any changes will be incorporated into this MAPP and you should check this MAPP periodically for updates. Your continued use of the Application will signify acceptance of the terms of the updated MAPP.

INFORMATION WE COLLECT

We collect information in multiple ways, including when you provide information directly to us, and when we passively collect information from you, such as information collected from your device.

1.      Information You Provide Directly to Us

We may collect information from you during your use of or access to the Application, such as:

•      When you register for an account;

•      When you make a purchase;

•      When you enter a sweepstakes or contest or register for a promotion;

•      When you request certain features (e.g. newsletters, updates, and other products); or

•      Post user-generated content, including comments, to or through the Application.

The information you provide directly to us may concern you or others and include, but is not limited to: (i) first and last name; (ii) email address; and (iii) birthdate. You are not required to provide us with such information, but, certain features may not be accessible or available, absent account registration and/or your provision of the requested information.

Please be careful and responsible whenever you are online. If you choose to post User Content (as described in our Terms of Use and End User License Agreement) through the Application, such as via social networking services, on message boards, chat areas, comments and/or other postings, that information; (i) is publicly available; (ii) may be collected and used by third parties without our knowledge; and (iii) may result in your receipt of unsolicited messages from other individuals or third parties.

2.      Information That is Passively or Automatically Collected

a.       Device/Usage Information

We may automatically collect certain information about the devices (including mobile devices) you use to access the Application. As described further below, we may collect and analyze information such as (a) IP addresses, geolocation information, unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Application; and (b) information related to the ways in which you interact with the Application, such as: platform type, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Application, the frequency of your use of the Application, error logs, and other similar information.  As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.

b.      Location Information

We may solicit your permission to collect location information from you or your device.  If you agree to allow access to your location, you agree that we and our service providers may collect information from your mobile device, including general location information (e.g., IP address, zip code) and more specific location information (e.g., GPS-based location information, longitude/latitude, etc.), and use that information to deliver the content, services, features and products (and/or to verify your rights to receive such content, services, features and/or products) that are available through the Application.  We and our service providers may also collect other information based on your location and your device’s proximity to “beacons” and other similar indoor proximity systems, including, for example, the strength of the signal between the “beacon” and your device and the duration that your device is near the “beacon”.  The type of location data we collect depends on a number of factors, including the type of device you are using (e.g., laptop, smartphone, tablet) and the type of connection enabled on your device (e.g., Wifi, Bluetooth, broadband, cable, or cellular).  The Application relies on this location information, including geo-fencing technology, in order to provide certain location-based services, content, promotional offers and other information that may be of interest to you.  We may also use location information to improve the functionality of the Application and our other services.  If you do not wish to have this location information collected and used by MSGN and its service providers, you may “opt out” by disabling the location and Bluetooth features on your device.  Please note that if you disable such features, you will not be able to access or receive some or all of the services, content, features and/or products made available via the Application.

Depending on the device you are using, we may use third party services to provide mapping services. For example, MSGN may use Google maps on certain devices—you can learn more about the information that Google collects through its mapping services at http://www.google.com/privacy.html.

c.       Automatic or Passive Collect Through Other Electronic Technologies

Through the use of various tracking technologies, we and our third party partners may automatically collect certain types of passive information whenever you use the Application, such as information about your device, including device type and identifiers, and your activities when using the device. For instance, we may automatically collect Application usage information, such as the numbers and frequency of users of the Application, pages visited and similar data. This data is used in the aggregate, that is, as a statistical measure, and not in a manner that MSGN or its third party partners intend to use to identify you personally.

3.      Information from Affiliates and Non-Affiliated Third Parties

We may also obtain information about you from our affiliates within the MSGN Family or from third parties, such as marketers, partners, researchers and others. For example, if you access the Application through a third-party connection or log-in, such as through Facebook Connect, we may collect the following information about you from Facebook: (i) Facebook ID/User Name; (ii) first and last name; (iii) anything that you have made public in your Facebook profile; (iv) gender; (v) locale; (vi) age range; (vii) profile link; (viii) your location; (ix) your Facebook “likes”; and (x) your comments.  If you permit, we also may collect your birthday and email. If you do not wish to have this information shared by Facebook with MSGN, do not use Facebook Connect to access the Application. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.

4.      Information That Others Collect

A.            Financial Information. In order to take advantage of certain functionalities of the Application, such as the ability to purchase programming or services (in the event and to the extent such functionalities are made available to you via the Application), our third party payment processor may collect certain financial information from you, such as your name, address, credit or debit card information or ACH information, applicable card expiration dates and security codes in order to process your transactions. MSGN does not collect, store or otherwise maintain this financial information, including credit, debit or similar information from individuals who make purchases using the Application.

     B.            Device Information. Third party vendors who provide analytics concerning the use of the Application may collect certain information about the device you use to access the Application, including without limitation the city, state and/or country where you were located when you downloaded the Application, device identifiers, IP address, MAC address, operating system, and application usage information.

     C.            Cable TV or Satellite Account Information: Other vendors, such as those who provide the necessary functionality to authenticate your account with your cable, satellite, telco or other provider of video programming services (each a “Pay TV Provider”), may collect such account credentials and certain other information, including without limitation billing zip code information, in order to verify your identity and the fact that you have a valid, current and active account with such Pay TV Provider.

HOW WE USE YOUR INFORMATION

MSGN may use your information for the following purposes:

•      For the purposes for which you provided it;

•      To provide the features, services and products available through the Application;

•      To send you information about your relationship or transactions with us;

•      To send you alerts or other communications;

•      To notify you about new features and offerings of the Application, including, but not limited to, discounts, events, news about our products and services, and/or special offers;

•      To administer sweepstakes and contests;

•      To process and respond to your inquiries;

•      To contact you with information that we believe may be of interest to you;

•      To attribute content that you make available through the Application;

•      For internal research and reporting;

•      To improve the content and features of the Application, develop new products and/or services,  personalize the Application, including through the use of Interest Based Advertising[A2] , or conduct analytics on your use of the Application;

•      To enforce the legal terms that govern your use of the Application;

•      To administer and troubleshoot the Application; and

•      To share your information with reputable third parties who may provide you with information about their products and/or services that may be of interest to you.

We may also combine information that we collect from you through the Application with information we obtain about you from other members of the MSGN Family and/or non-affiliated third parties. For purposes hereof, the “MSGN Family” means and includes MSG Networks Inc., MSGN Holdings, L.P. and each of their respective parent companies, subsidiaries, divisions, affiliated entities and business units as may change from time to time (including, without limitation, MSG Network, MSG Plus and MSGN Interactive).

We may aggregate and/or de-identify information collected through the Application. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others.

WHEN WE DISCLOSE YOUR INFORMATION

MSGN may disclose and/or share your information to or with any member of the MSGN Family. Unless otherwise described in this MAPP, MSGN will only disclose or share your information with any non-affiliated third parties under the following circumstances.

Consent: We may disclose your information with non-affiliated third parties based on your consent to do so. Such consent includes the disclosure of your information (a) in order to provide services or products that you have requested; (b) when we have your permission; or (c) as described in this Policy.

Service Providers. We may provide access to your information to select third parties who perform services on our behalf and for any other legitimate business purposes. These third parties provide a variety of services to us, including without limitation, billing, sales, marketing, advertising, market research, fulfillment, data storage, analysis and processing, and legal services. MSGN generally seeks contractual assurances from these service providers that they will not use your information in any manner other than to help us provide you with the services and products available from MSGN.

Other Third Parties. Unless you direct us not to, we may share your information with third parties so that they may contact you to offer products, services and promotions, such as sweepstakes and contests, that you may find valuable. We may also share your information with third-party advertising networks or others with whom we have a contractual relationship. You can instruct us not to provide your personal information to these third parties by sending an email to privacy@msgnetworks.com[A3]  with “REMOVE THIRD PARTIES” in the subject line. If you receive a communication from a third party and you do not wish to receive future communications from that party, you should also tell them to remove you from their marketing list.

Protection of MSGN and Others.  By using the Application, you acknowledge, consent and agree that we may access, preserve and disclose your information, including, but not limited to, any user content, if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) enforce our Terms of Use and End User License Agreement, this MAPP, or other contracts with you; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of MSGN, its agents and affiliates, its users and/or the public. We may also disclose information to law enforcement agencies in emergency circumstances, where the disclosure of such information is consistent with the types of emergency disclosures permitted or required by law.

Business Transfers. We reserve the right to disclose and transfer all of your information, including your personal information, in connection with a merger, acquisition or sale of all, or components, of our business.

Aggregate and/or De-Identified Information. MSGN may share aggregate and/or de-identified data with any third parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others.

PUSH NOTIFICATIONS

Users of the Application may choose to receive push notifications from the Application.  Users can manage their push notification preferences at any time by adjusting the settings for the Application on their mobile device. These settings are controlled by device manufacturers, not by MSGN or any member of the MSGN Family.

Interest-Based Advertising and Analytics

Data about your activities on the Application may be collected for use in providing advertising tailored to your individual interests on other websites and online services, as well as in the Application. This is known as interest-based advertising or behavioral advertising. These advertisements may be served by us or we may allow third parties’ advertisements to be served through the Application.  These advertisements are sometimes targeted based on your browsing activity over time and across third party websites and services.  For instance, a particular advertisement may be served to specific users (e.g., “users in New York”) and may come from third party companies called “ad networks.”  “Ad networks” include third party ad servers, ad agencies, ad technology vendors and research firms.  Other times, the advertisements are not tailored or targeted based on your browsing on other websites, but rather simply based on how you use and interact with the Application – this is referred to as contextual advertising  You may have a choice whether to have your information collected for interest-based advertising purposes, but not contextual advertising. This section of the Policy provides details and explains how to exercise applicable choice.

We participate in advertising services administered by third parties, such as Google.  For example, we may use the following features based on Google Analytics for Display Advertising:  Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting.  To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page.

The ad services may track your activities over time by collecting information through automated means, including through the use of the automated technologies described in this Policy, and they may use this information to show you advertisements that are tailored to your individual interests and/or based on prior use of the Application or your use of other Applications or websites.  We and third-party vendors, including Google and others, may use tracking technologies to:  (i) inform, optimize, and serve ads based on past visits to the Application; and (ii) to report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to the Application. We also may share with third-party advertisers a hashed version of your email address, solely in non-human readable form and content that you share publicly when using the services (e.g, user-generated content) for purposes of delivering tailored advertising.

If you would like to opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising, you may visit the opt-out pages on the NAI website and DAA website. You understand that these opt-out mechanisms are maintained by third parties, not MSGN and MSGN is not responsible for, nor does it control these mechanisms of the third parties who choose to participate in these opt-out programs.

You also may adjust the settings on your device to control receiving in-application advertisements that relate to your interests.  If you are using an iOS device, you may opt-out of receiving such in-application advertisements by accessing the following link on your device: http://oo.apple.com. If you are using an Android device and you do not wish to receive tailored in-application advertisements, you can visit Google’s Ads Preferences page from a browser on your device and make your choices there. These settings are controlled by the device manufacturers, not by MSGN or any member of the MSGN Family.

We may use third-party analytics services on the Application, such as those provided by Google Analytics.  These analytics may also be used as part of online advertising campaigns to determine how users interact with the Application after they have been shown an online advertisement.  In order to control the collection of data for analytical purposes by Google, you may install the Google Analytics Opt-out Browser Add-On.

Please note that to the extent advertising technology is integrated into the Application, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

California Online Privacy Protection Act Notice Concerning Do Not Track Signals

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information collected on the Application for third party purposes, and that is why we provide links to the Network Advertising Initiative and the Digital Advertising Alliance opt-out pages. However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. To learn more about Do Not Track, you can do so here.

CONSENT TO TRANSFER

The Application is operated and provided in the United States and governed by United States law. If you are a resident of the European Union or other location outside the United States, please be advised that any information you provide through the Application will be transferred to the United States or other designated locations outside of the United States for certain processing/hosting operations. We have taken commercially reasonable steps to ensure that your personal information is appropriately protected and is processed only in accordance with this MAPP. By using the Application, you consent to this transfer and to the use of the personal information as described herein.

OPTING OUT OF USE OF PERSONAL INFORMATION FOR MARKETING PURPOSES BY THE MSGN FAMILY

If you have provided personal information while using the Application and later decide that you would rather not have the MSGN Family use such information for marketing purposes in accordance with this MAPP, you can opt-out of future use at any time by: (i) going to the link provided at the bottom of any email you receive from an MSGN Family member and opting out of receiving information from that MSGN Family member; (ii) sending us an email at privacy@msgnetworks.com[A5]  including your name and email address; or (iii) writing us at MSGN Holdings, L.P., 11 Penn Plaza, 3rd Floor, New York, New York, 10001, Attn: Vice President, Marketing and with a copy to Vice President, Legal and Business Affairs at the same address, including your name and email address.

UPDATING YOUR INFORMATION

To keep your information accurate, current and complete, email privacy@msgnetworks.com[A6]  to update and/or correct any information previously provided.

LINKS

Links to third-party websites, applications and other services may be made available through the Application. We are not responsible for the privacy practices or the content of such third-party services.  Any information you provide via those services is subject to the applicable privacy policies of such third-party services and is not covered by this MAPP.

SECURITY

We have implemented commercially reasonable administrative, technical, and physical security measures to protect against the loss, misuse and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store.    However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.

 

YOUR CALIFORNIA PRIVACY RIGHTS

California Law permits users who are California residents to request certain information regarding our disclosure of personal information to third parties for such third parties’ direct marketing purposes. To make such a request, please send an email to privacy@msgnetworks.com[A7]  or write to us at MSGN Holdings, L.P., 11 Pennsylvania Plaza, 3rd Floor, New York, New York 10001, Attn: Vice President, Marketing and with a copy to Vice President, Legal and Business Affairs  at the same address.

INFORMATION FROM CHILDREN

MSGN does not knowingly collect any “Personal Information” (as that term is defined by the Children’s Online Privacy Protection Rule) directly from children under the age of 13. If we discover we have received any Personal Information from a child under the age of 13 in violation of this MAPP, we will delete such information as quickly as possible.  If you believe MSGN has any such information from or about anyone under the age of 13, please contact us at the address listed below.

CONTACTING US ABOUT THIS MAPP

Please do not hesitate to contact us with any questions, concerns, requests or comments by email at feedback@msgnetworks.com or write to us at MSGN Holdings, L.P., 11 Pennsylvania Plaza, 3rd Floor, New York, New York 10001, Attn: Vice President, Marketing and with a copy to Vice President, Legal and Business Affairs at the same address.

© Copyright 2015 MSGN Holdings, L.P., 11 Pennsylvania Plaza, 3rd Floor, New York, NY 10001. All rights reserved.