COMMON SENSE NETWORKS PRIVACY POLICY

LAST UPDATED: July 13, 2021 Welcome! Below you will find the privacy policy for Common Sense Networks PBC. ("we" or "us"). Common Sense Networks operates Sensical, a free, kid-focused streaming service offering thousands of entertaining, age-appropriate, short-form videos and podcasts for ages 2-12 that support kids' social, emotional, and cognitive development. We are dedicated to protecting your privacy and handling any personal information we obtain from you with care and respect. The Common Sense Networks Privacy Policy (the "Policy" or the "Privacy Policy") is designed to answer your questions regarding how we collect, protect, use and share information obtained through the Common Sense Networks service including our website at www.sensicaltv.com and other applications ("apps") that we operate and that link to this Privacy Policy (collectively, the "Services").  The Services are intended for use by adults over the age of 18 and their children for home or personal use and enjoyment.  The Service is not intended for use by students in K - 12 school environments or classrooms.  A separate Children’s Privacy Policy is also included as part of this general Privacy Policy. We hope this information increases your confidence in Common Sense Networks and enhances your experience on our Services.

Please see our separate Terms of Use, which governs the use of the Services. We encourage you to read this Policy before using the Services, and not to use the Services if you disagree with any part of this Policy. By using the Services or by clicking a box that states that you accept or agree to this Policy, you signify your agreement to the terms and conditions of this Policy.

The Services are controlled and operated by Common Sense Networks, a public benefit corporation in the United States. Subject to our obligations (if any) under our Terms of Use, we may limit the availability of the Services, in whole or in part, to any person, geographic area, or jurisdiction we choose, at any time in our sole discretion.

I. INFORMATION THAT WE COLLECT ON OR THROUGH THE SERVICES

A. Personal Information
In this Policy, when we use the term "Personal Information", we mean any information that can be used to identify (directly or indirectly) or contact a specific individual, such as the individual's name, postal address, email address, telephone number, or online identifier. We collect different types of Personal Information depending on whether you are a registered user or not, as explained below, to provide our Services and carry out legitimate interests. For information on the collection, use and disclosure of children's personal information, please see the Children’s Privacy Policy.
Please see our separate Terms of Use, which governs the use of the Services. We encourage you to read this Policy before using the Services, and not to use the Services if you disagree with any part of this Policy. By using the Services or by clicking a box that states that you accept or agree to this Policy, you signify your agreement to the terms and conditions of this Policy.

All Visitors: Visitors to the Services that are over 18 may register and opt-in to receive Common Sense Networks email newsletters by providing their email address and zip code. Please note that our newsletters are not currently available to any Registered Users under the age of 18. If you are a visitor who is under 18 you should not attempt to sign-up for our newsletters.

We also may collect Personal Information through surveys or questionnaires. Your participation in surveys and questionnaires is entirely voluntary.

Adult Registered Users: If you wish to become a Registered User, you must be 18 or older and provide us with certain Personal Information as part of the registration process, including, for example, name, email address, password and age. We additionally ask for zip code or country of residence.  The Service does not allow for Social Sign-on or log-in.  Registration must be done directly on the Service.

If you are an adult Registered User, you may also optionally choose to provide us with information about your children to create profile(s) for each child, such as their ages and first names, so we can present an experience tailored to the age of the child in the Services and within our email newsletters.  The profiles that you may create for children are not publicly available on the Service.

Child Users: To learn about our practices regarding children's privacy, please read our Children’s Privacy Policy. We do not collect Personal Information from children. Additionally, children may not register for the Services. The only information collected on children will be optionally provided by their parent(s) or caregiver as part of that adult’s registration for the Service. Such information is limited to the child’s first name (should the adult registered user decide to provide it) and the child’s age (should the adult registered user decide to provide it).  Such information you may provide to create a profile for your children will not be publicly available on the Service.  If you are a parent or guardian that discovers or learns that a child under 13 that is in your care has created an account on the Service, you may contact us at compliance@commonsensenetworks.com to request that such information be removed, and we will take immediate action to do so.

Account Deletion: If you decide that you no longer want to be a Registered User, you can delete your account and your child’s profile information at any time. To delete your account, login to your account, visit your Account Settings page and then click the "Close my Account" link located towards the bottom of the page. Once you delete your account, all of your Personal Information stored in your account and Profile on our site will be removed. Or, you can contact us at compliance@commonsensenetworks.com and request that we delete your content and account for you.

While we do allow registered users to delete their accounts and profiles on the Service, note that the California Consumer Privacy Act (“CCPA”) does not apply to the Services because we do not buy or sell consumer Personal Information. However, we support the legislation and encourage you to learn more about your rights at
B. Collection of Information by Our Service Providers
We use third-party service providers ("Payment Services"), to handle subscriptions, and other payment transactions submitted to our Services. If you wish to make payment, you will be directed to a webpage that is hosted by a Payment Service (or its service providers) and not by us (such page, a "Payment Service Page"). Any Personal Information that you provide through a Payment Service Page will be collected directly by a Payment Service rather than by us, and will be subject to that Payment Service's privacy policy rather than this Policy. We have no control over, and shall not be responsible for, a Payment Service's use of information collected through a Payment Service Page. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE COLLECTION AND USE OF INFORMATION THROUGH ANY PAYMENT SERVICE PAGE OR THE PRIVACY OR INFORMATION PRACTICES OF THE PAYMENT SERVICES.

C. Cookies and Other Technologies Certain information, like aggregated information or high-level location information, such as the browser language and country during the user session, is treated as non-personal information unless applicable law requires otherwise. We may use or disclose such information for any purpose. We will utilize analytics solutions, which ultimately leverage cookies. We are not sharing or selling this data with third parties. We will be tracking based on a User Profile ID. For instance, we may compile and share aggregate data about the geographic locations or other demographics of our Registered Users, provided that this information does not personally identify any of these Registered Users.

II. INFORMATION THAT WE COLLECT ON OR THROUGH THE SERVICES

A. How We Use Personal Information

We use Personal Information to process requests made through our Services, such as requests to receive our e-newsletters and questions or comments submitted through our Services. You may opt-out of receiving our e-newsletters at any time by clicking the "unsubscribe" or “manage my email preferences” links located at the bottom of newsletters, or by sending your request to compliance. request to compliance.

Fulfillment of Requests. We may use Personal Information about you to fulfill the purpose for which such information was provided (e.g., to send newsletters to you or respond to your requests or inquiries and provide related customer service).

Additional Communications. If you register to become a Registered User of our community or sign up to receive one of our e-newsletters, we may use the Personal Information submitted in connection with your application to contact you with surveys or important communications regarding Common Sense Networks. We may additionally use Personal Information to contact you about Common Sense Networks content, features, opportunities, and products that may be of interest to you; provided that we will not include third party products or promotional content in any communications to Registered Users unless we request and receive opt-ins from Registered Users to receive such messages or communication.

Internal Operations and Analysis. We may also use Personal Information about you for our internal business purposes, such as data analysis, audits, enhancing or modifying our products and services, and so forth.

Other uses. Personal Information may be used for certain other internal operations of the Service, including maintaining or analyzing the functioning of the Service, performing network communications, authenticating users to the Service or personalizing content, serving contextual ads or frequency capping, protecting the security or integrity of the user or the site, legal or regulatory compliance, or fulfilling a child’s request under the one-time contact or multiple contact exceptions.

We may also use Personal Information to personalize your experience on the Services by presenting content and market opportunities and products tailored to you and to allow you to participate in sweepstakes, contests and similar promotions and to administer these activities; provided that we will not include third party products or promotional content in any communications to Registered Users unless we request and receive opt-ins from Registered Users to receive such messages or communication.

III. HOW WE DISCLOSE INFORMATION COLLECTED ON THE SERVICES  

Except as expressly provided in this Policy, we will not share any Personal Information about you without your prior consent.

Profile Information. Each Registered User may have a Profile on the Site, which may include the Registered User's name or screen name and registration date. You can change or remove information from your Profile by logging into the Site and clicking the "My Account" links located in your personal Account section.

Third-Party Service Providers. We work with third-parties who provide services such as data analysis, payment processing, order fulfillment, infrastructure provision, information technology services, content personalization, email delivery services, and market research or third-parties who provide other services to help improve or operate our Services. We may share Personal Information about you with third-parties solely for the purpose of enabling them to provide these services to us. These service providers are given access to Personal Information needed to perform their functions, but are restricted from using the Personal Information for purposes other than providing services for us. When we engage a third-party who will need to access and process your Personal Information as part of their services, we ascertain that the third-party is capable and obligated to provide at least the same level of data privacy and protection as we hold ourselves to. Our third-parties are required to notify us if they determine they can no longer meet the expected level of data privacy and protection, and we monitor for compliance to our data protection terms based on the nature of the services being provided.

Law Enforcement; Emergencies; Compliance. Notwithstanding any other provision of this Policy to the contrary, we reserve the right to use your Personal Information, and to disclose it to others, as we believe to be necessary or appropriate: (a) under a requirement of applicable law, (b) to comply with legal process, (c) to respond to governmental requests, (d) to enforce our Terms of Service, (e) to protect our operations, (f) for assistance in fraud detection and prevention; (g) to protect the rights, privacy, safety or property of Common Sense Networks, you or others, (h) to permit us to pursue available remedies or limit the damages that we may sustain, and (i) in connection with a disposition of all or a substantial portion of our business, assets or stock, such as the sale of the Site or Services, a merger, consolidation, reorganization, joint venture, assignment, or bankruptcy or similar proceedings.

Personal Information about you may be transferred, stored, and processed by us or the third-parties we work with in countries whose data protection laws and regulations may be different to those of your country. We allow transfers of Personal Information made between countries or regions in a fashion that complies with applicable law.

VI. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We keep your Personal Information only for as long as it is warranted to provide our Services, fulfill our commitments to you, and/or adhere to legal or regulatory requirements. If you are a Registered User, we keep your Personal Information for the duration of our relationship. Certain Personal Information may be kept and archived for longer though, as required for recordkeeping purposes or backing up Services’ data for example. When Personal Information has expired, or is no longer needed and does not have to be retained, we may return, delete, destroy, or anonymize it, depending on what method is systematically and procedurally possible, most secure, and what our related retention commitments are.

VII. IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION

Advertising. CSN is committed to the highest standards for safe kids advertising and complies with the Children’s Online Privacy Protection Act (COPPA) and all relevant regulations. In order to make the Service free for users, however, the Service will contain advertising, but the advertising will only contain contextual display advertising and will not use User Information to target advertisements. Please refer to Section II.A for relevant uses of Personal Information as relates to advertising operations. In addition, you may request a copy of the CSN Ad Guidelines by emailing compliance@commonsensenetworks.com.

Links. For your convenience and information, we may provide links to websites and other third-party services and content that is not owned or operated by us. The third-party websites, services and content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of any entity that we do not own or control. The inclusion of a link or such third-party services/content on the Services does not imply our endorsement of the linked site, or that content or service.

Security. We seek to use reasonable administrative, organizational, technical, and physical measures to help protect the Personal Information you provide to us from loss, misuse, and unauthorized disclosure, alteration, or destruction. Only authorized personnel have access to Personal Information you provide to us and each employee with access to Personal Information is obligated to maintain its integrity and confidentiality. User data for the Services is encrypted both in transit and at rest.  Unfortunately, no data transmission can be guaranteed to be 100% secure or error free. If you have reason to believe that your interaction with us is no longer secure, you should immediately notify us in accordance with the section below entitled "Contacting Us." Please note that if you notify us by physical mail, this will delay the time it takes for us to respond to the problem.  We follow all industry standard security protocols and safeguards against breach, but in the unlikely case of a security breach, we will notify all Registered Users of such breach within 48 hours of its occurrence.

Changes to the Privacy Policy. We reserve the right to change this Policy, and any changes to our Policy will become effective upon our posting of the revised Policy on the Site. Use of the Services following such changes constitutes your acceptance of the revised Policy then in effect. If we make changes to this Policy we will take reasonable steps to alert users of the Services that the Policy has been updated.

VII. IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION

Security. We seek to use reasonable administrative, organizational, technical, and physical measures to help protect the Personal Information you provide to us from loss, misuse, and unauthorized disclosure, alteration, or destruction. Only authorized personnel have access to Personal Information you provide to us and each employee with access to Personal Information is obligated to maintain its integrity and confidentiality. User data for the Services is encrypted both in transit and at rest.  Unfortunately, no data transmission can be guaranteed to be 100% secure or error free. If you have reason to believe that your interaction with us is no longer secure, you should immediately notify us in accordance with the section below entitled "Contacting Us." Please note that if you notify us by physical mail, this will delay the time it takes for us to respond to the problem.  We follow all industry standard security protocols and safeguards against breach, but in the unlikely case of a security breach, we will notify all Registered Users of such breach within 48 hours of its occurrence.

Changes to the Privacy Policy. We reserve the right to change this Policy, and any changes to our Policy will become effective upon our posting of the revised Policy on the Site. Use of the Services following such changes constitutes your acceptance of the revised Policy then in effect. If we make changes to this Policy we will take reasonable steps to alert users of the Services that the Policy has been updated.

VIII. CONTACTING US

If you have any questions or requests about this Policy, or the practices of the Services, please contact us at compliance@commonsensenetworks.com or write to us at:

Privacy Department
Common Sense Networks
699 8th Street, Suite C150
San Francisco, CA 94103
415-863-0600