PRIVACY AND COOKIES POLICY

Effective Date: This Privacy and Cookies Policy is effective as of September 3, 2021.

This Privacy and Cookies Policy (“Policy”) applies to the website (http://alowritersinitiative.com) (“Website”) featuring the ALO Writers Initiative (“Initiative”), which is co-sponsored by Sony Pictures Television International and EbonyLife Media Limited (“Content”). In this Policy, we use "we," "us," and "our" to collectively refer to Sony Pictures Television International, a Sony Pictures Entertainment, Inc. (“SPE”) company (“SPTI”) and EbonyLife Media Limited (“EbonyLife”.   Certain defined terms in this Policy not defined herein shall have the same meaning as in the Alo Writers Initiative Official Rules (“Official Rules”) available on the Website.

To find the local SPE entity in your jurisdiction, please click here.  Sony Pictures Entertainment Inc.’s corporate offices are located at 10202 West Washington Boulevard, Culver City, California 90232 USA. 

EbonyLife’s corporate offices are located at 10 Engineering Close, off Idowu Taylor Street, Victoria Island, Lagos, Nigeria

KEY POINTS

1. Information you provide	We collect certain categories of Personal Data you provide to us.
2. Information from third parties	We receive certain information about you from third parties, such as third-party applications and data providers.
3. Use of your information	We use personal data to allow you to use the features in the Content, to process your registration, and to manage your participation in the Initiative.
4. Cookies and similar technologies	We use cookies and other tracking technologies to facilitate location identification, eligibility to Initiative and/or your access/usage of the Content.
5. Sharing your information	We disclose the personal data internally to employees of SPE and/or EbonyLife for the purposes of reviewing the Application, judging the Entry Materials, tracking Entrants for duplicate entries across multiple Entry Periods, for acknowledgement and consent by Entrant of the Submission Policy and/or Official Rules.  We also share data with third parties We engage to process data on our behalf or when such sharing is required by law, or in certain other situations.
6. International transfers	We transfer your personal data to the United States, Nigeria or other jurisdictions in which we or our service providers are located.
7. Your rights	Subject to applicable law, you may have certain rights, such as requesting access, rectification, deletion, or other actions regarding your personal data.
8. Data security	We maintain technical and organizational measures to protect personal data from loss, misuse, alteration, or unintentional destruction.
9. Other important issues	We provide other information in this Privacy and Cookies Policy about: (i) the legal basis for collecting and processing personal data, (ii) the consequences for not providing personal data, (iii) automated decision-making, and (iv) data retention.
10. Changes to this policy	We may revise this Privacy and Cookies Policy to reflect changes in the law, our personal data collection and use practices, the features of the Content, or advancements in technology.
11. Contact us	Should you have any questions, concerns or comments, please contact us as detailed below.

 

 

1. INFORMATION WE COLLECT FROM YOU

We may collect the following categories of personally identifiable information (“Personal Data”) you provide to us when using the Content:

1. Identification Data: Information that allows us to differentiate you from other individuals. This may include: name and surname, and African country of heritage
2. Contact Information: Information that allows us to keep in touch with you. This may include: email address and phone number.
3. Electronic Records: This information includes certain data from you or your device that are obtained when you access our Content.
4. User-Generated Content: We may also collect information that you enter into our Content, such as Submission Materials.
5. Usage Information: We and our third-party partners and service providers, such as Google Analytics and/or Adobe Analytics, may use a variety of technologies that collect and provide information about how the Site is accessed and used. Usage Information may consist of your internet browser type and version, operating system, service provider, the Content, the time you viewed them and for how long, , your location, time zone and/or language.
6. Device Identifiers: We and our third-party partners and service providers may also automatically collect your IP address or other unique identifier for the computer, mobile device, technology or other device you use to access the Content. A unique identifier is a number that is automatically assigned to your device when you access a web site or its servers, and our computers identify your device by this number. Some mobile service providers may also provide us with the physical location of the device used to access the Content.

 

2. INFORMATION WE RECEIVE FROM THIRD PARTIES

The Content may include hyperlinks to, or include on or in connection with, the Content (e.g., apps and plug-ins), websites, locations, platforms, applications or services operated by third parties ("Third-Party Service(s)"). These Third-Party Services may use their own cookies, web beacons, and other tracking technology to independently collect information about you and may solicit Personal Data from you. Their privacy policies apply in such cases, and not this Privacy Policy.

3. HOW WE USE YOUR INFORMATION

We use the categories of Personal Data outlined above for the following purposes:

1. To fulfil a contract, or take steps linked to a contract;
   1. To process your registration and entry into the Initiative
   2. To send you information about changes to our terms or policies and other transactional messages

 

2. Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests are:
   1. To provide you with access to Content
   2. To send you information you have requested
   3. To ensure the security of our site, by trying to prevent unauthorized or malicious activities
   4. To determine your approximate location and adapt our Content (e.g. providing appropriate privacy policies and/or territory restrictions)
   5. To enforce compliance with our Terms of Use, Official Rules and other policies and to help other organizations (such as copyright owners) to enforce their rights

 

3. Where you give us consent:
   1. Where required by applicable law, consent to place cookies and to use similar technologies
   2. On other occasions where we ask you for consent, for a purpose which we explain at that time

 

4. For purposes which are required by law:
   1. In response to requests by government or law enforcement authorities conducting an investigation.
4. COOKIES AND SIMILAR TRACKING TECHNOLOGY

Cookies, web beacons (also known as "tracking pixels") and other tracking technologies may be used to collect information about interactions with the Content, including information about your browsing behavior. These cookies and similar tracking technologies allow us to recognize you when you visit our site – they do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your experience.

We use tracking technologies for two purposes:

1. To provide you with the service you have requested: for example, keeping you logged in during your visit and ensuring security of the Content.
2. To analyze and improve your browsing experience: We also check for bugs and glitches in the Content and remember the choices you have made, such as your language or region, to enhance and personalize your experience. We may use analytics services provided by Adobe and Google to help us do this. If you don’t want us to use information about your visits in this way, click here for Adobe and here for Google, to opt-out of their services.

How to manage tracking technologies

If you are using our Content via a browser and cookies are deployed, you can change your cookie preferences and withdraw your consent at any time. You do not need to have cookies enabled to use our Content but turning them off may affect your experience on our sites and apps. To manage your preferences: (1) the Help menu on the menu bar of most browsers tells you how to prevent your browser from accepting new cookies, how to delete old cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether; and (2) you can opt-out of analytics as described above.

Location-identifying Technologies

Subject to applicable laws, we may use GPS (global positioning systems) software, geo-filtering and other location-aware technologies to locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting content (e.g. territory restrictions) based on your location. You can turn off precise geo-location tracking through the location settings on your device. 

 

 

5. HOW WE SHARE YOUR PERSONAL DATA

We may share your Personal Data in the following circumstances:

1. Third Parties Providing Services on Our Behalf. We share data with our partners, as well as third parties who perform functions on our behalf, such as hosting or operating our site and apps, sending emails, and carrying out data analysis.
2. Affiliate Sharing. We may share your Personal Data with other SPE and/or EbonyLife entities, which are involved when we process data for the purposes listed above. We may also share your Personal Data with other Sony group companies for analytics purposes
3. Business Reorganization. Your Personal Data may be transferred to a purchaser or prospect to the extent permitted by law, either as part of a transaction or during any due diligence process.
4. Mandatory Disclosures and Legal Protections. We share information with government and law enforcement authorities and with other parties involved in, or contemplating, legal proceedings to comply with a legal obligation, when we believe in good faith that the law requires it, to verify or enforce our Terms of Use or where this is necessary for us or for third parties to protect our or their rights, property, safety, or security.
6. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

Our Content is hosted and operated by us or our service providers in the United States. As such, your Personal Data will be transferred to and processed in the United States, Nigeria and other countries that may not provide the same level of data protection as your home country. We provide appropriate protections for international transfers as required by law for international data transfers. With respect to transfers originating from the European Economic Area ("EEA"), we implement standard contractual clauses approved by the European Commission, and other appropriate solutions to address cross-border transfers as required by applicable law. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below. Where your consent is required by applicable law, by using the Content and providing us with your Personal Data, you consent to the international transfer of your Personal Data.

 

7. YOUR RIGHTS  

Where required by applicable law, you may have the right to obtain confirmation that we maintain certain Personal Data relating to you, to verify its content, origin, and accuracy, as well as the right to access, review, port, delete, or to block or withdraw consent to the processing of certain Personal Data (without affecting the lawfulness of processing based on consent before its withdrawal). To submit a request to exercise any of these rights, please contact us at: spe_privacy@spe.sony.com.  We may request certain information for the purpose of verifying the identity of the individual seeking access to his or her Personal Data.

We will make good-faith efforts to make such requested changes in our then-active databases as soon as practicable, but it is not always possible to immediately completely change, remove or delete all your information from our databases and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain your Personal Data (a) as permitted by applicable law; (b) as required by applicable law; and (c) for so long as reasonably necessary to fulfil the purposes for which the data is retained except to the extent prohibited by applicable law. 

8. DATA SECURITY

We maintain technical and organizational measures to protect Personal Data from loss, misuse, alteration, or unintentional destruction. However, no security measure can guarantee against compromise. You also have an important role in protecting your Personal Data. If you have reason to believe that your interaction with us is no longer secure please contact us immediately as detailed in the "Contact Us" section of this Privacy and Cookies Policy.

9. OTHER IMPORTANT ISSUES
10. Some jurisdictions require an explanation of the legal basis for the collection and processing of Personal Data. We have several different legal grounds on which we collect and process Personal Data, including: (a) as necessary to confirm eligibility and/or facilitate the selection process of the Initiative); (b) as necessary to comply with a legal obligation (such as when we use Personal Data for record keeping); (c) consent (where you have provided consent as appropriate under applicable law); and (d) necessary for legitimate interests (such as when we act to maintain our business generally, including maintaining the safety and security of the Content).
11. You are not required to provide all Personal Data identified in this Privacy and Cookies Policy to use our Content or to interact with us offline, but certain functionality will not be available if you do not provide certain Personal Data. If you do not provide certain Personal Data, we may not be able to accept your entry into the Initiative and/or respond to your request.
12. We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.
13. For Personal Data that we collect and process for other purposes described above, we typically retain such Personal Data for no longer than for the period necessary to fulfil the purposes outlined in this Privacy and Cookies Policy and as otherwise needed to address tax, corporate, compliance, litigation, and other legal rights and obligations.
10. CHANGES TO THIS POLICY

We may update this Privacy and Cookies Policy from time to time as our services and privacy practices change, or as required by law. The effective date of our Privacy and Cookies Policy is posted above, and we encourage you to visit our Content periodically to stay informed about our privacy practices. We will post the updated version of the Privacy and Cookies Policy on our Content, and ask for your consent to the changes if legally required.

11. CONTACT US

If you have any questions or comments regarding this Privacy and Cookies Policy or our privacy practices, please contact us at spe_privacy@spe.sony.com.  And/or enquiries@ebonylifemedia.com

 

You may also have a right to submit a complaint to a supervisory authority for data protection in the country where you live, where you work, or where you consider that a breach of data protection has occurred.