PRIVACY POLICY

Effective Date: July 15,2022.
Last update: October 2, 2023.

1. Introduction and Overview.

This Privacy Policy describes how P3 Inc. ("P3," "we," "our," or "us") is intended to inform users (“You”) of our platform and online services (collectively, the "Service"), in a transparent manner, about the data we collect, the purpose of its collection, how we use it and the rights You have regarding the processing of Your personal data. This Privacy Policy does not apply to our information collection activities offline or otherwise outside of the Service (unless otherwise stated below or at the time of collection).

We are committed to respecting the privacy of the individuals whose personal data we process and to treating such data in the strictest confidence and in accordance with applicable law, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data;

Please read this Privacy Policy carefully.

If You have any questions about our privacy practices, please contact us as set forth in the section entitled "Contact Us" below.

2. Data We collect.

A. Information You Provide.

We collect information You provide directly via the Service, such as when You access or make changes to Your account, view digital screeners, or contact customer support. We may use Service Providers (defined below) to collect this information.

The information we collect includes information that identifies You personally (whether alone or in combination) ("Data”). Some examples of information we collect include the following:

• Data relating to Your identity, including Your first and last name,
• Contact Data, including e-mail address, postal address, and phone number.
• Account Credentials, including Your username, password, password hints, and information for authentication and account access.
• Demographic Data, including Your age, gender, and country.
• Profile Data, including what company You work for, the title of Your position, Your Voting Group (defined below) membership, and Your interests and favorites.
• Content, including the content of any messages You send to us, such as feedback and product reviews You write, or questions and information you provide to customer support.

You may choose to voluntarily submit other information to us through the Service that we do not request, and, in such instances, You are solely responsible for such information.

B. Information Collected Automatically.

We automatically collect information about Your device and how Your device interacts with our Service. We may use Service Providers to collect this information. Some examples of information we collect include the following:

• Data relating to navigation on our website: IP address, connection data, type of browser, operating system used. Information on "Cookies" and other similar technologies can be found at Cookie policy.
• Location-Identifying Technologies. GPS, WiFi, Bluetooth, and other location-aware technologies may be used to collect precise location data when You enable location-based services through Your device. Location data may be used for purposes such as verifying Your device's location and delivering or restricting relevant content based on that location.

C. Information from Other Sources.

We also obtain information about You from other third party sources. To the extent we combine such third party sourced information with information we have collected about You through the Service, we will treat the combined information in accordance with the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data. These third party sources vary over time, but have included:

• Membership lists from the guilds, unions, trade associations, or other organizations participating in the voting-based awards program and in which You are a member ("Voting Groups").
• Partners with which we offer co-branded services or engage in joint marketing activities.

3. Why do we collect Your Data.

We use information we collect in accordance with the practices described in this Privacy Policy, including to:

• Manage our Service, including Your registration and account.
• Provide access to view digital screeners including the video, audio, images, music, graphics, software, and text contained therein.
• Use information as directed by Your Voting Group and as Your Voting Group permits us to.
• Respond to Your comments, questions, and requests, and provide customer service.
• Send You technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
• Prevent and address fraud, breach of policies or terms, and threats or harm.
• Enforce the content protection and anti-piracy policies of P3 and the studios, independent film makers, and other individuals or entities that own, license, have intellectual property rights in, or have provided digital screeners to us for use on the Service ("Content Providers").
• Monitor and analyze trends, usage, and activities.
• Conduct research, including focus groups and surveys.
• Improve the Service or other P3 websites, apps, marketing efforts, products and services.
• Develop and send You direct marketing, including communications about our and third party products, offers, promotions, rewards, events, and services.
• Fulfill any other purpose disclosed to You, at Your direction, or with Your consent.

Notwithstanding the above, we may use information that does not identify You (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on Your rights and choices regarding how we use Your information, please see the section entitled "Your Rights and Choices" below.

4. Sharing of Information.

We share information we collect in accordance with the practices described in this Privacy Policy, including as follows:

• Service Providers. We share Your information with our agents, vendors, and other service providers (collectively "Service Providers") in connection with their work on our behalf. Service Providers assist us with services such as data analytics, marketing and promotional services, website and digital screener hosting, and technical support. Service Providers are prohibited from using Your information for any purpose other than to provide this assistance, although we may permit them to use information that does not identify You (including information that has been aggregated or de-identified) for other purposes.
• Affiliates. We may share Your information with our related entities. For example, we may share Your information with our affiliates for customer support, marketing, and technical operations.
• Business Partners. We may share Your information with our business partners in connection with offering You co-branded services or engaging in joint marketing activities.
• Content Providers. We may share Your information with Content Providers.
• Voting Groups. We may share Your information with Your Voting Groups for their own business and marketing purposes.
• Merger or Acquisition. We may share Your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
• Security and Compelled Disclosure. We may share Your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share Your information to protect the rights, property, life, health, security and safety of us, the Service or any third party.
• Direction or Consent. We may share Your information to fulfill any other purpose disclosed to You, at Your direction, or with Your consent.

Notwithstanding the above, we may share information that does not identify You (including information that has been aggregated or de-identified) with third parties except as prohibited by applicable law.

For information on Your rights and choices regarding how we share Your information, please see the section entitled "Your Rights and Choices" below.

5. Viewing Information.

In certain circumstances, we may need to share information about the videos You view on our Service along with other information we have about You, including information You have provided to us (such as Your name or address) and information we have automatically collected (such as an IP address, device identifier, or precise location data). By using the Service, You consent to our doing so, including the collection, use, and sharing as described in our Video Privacy Notice and Consent. For more information, please review that policy.

6. Your Rights and Choices.

A. Account Information.

You may access, update, or remove certain information that You have provided to us through Your account by sending an e-mail to the e-mail address set forth in the section entitled "Contact Us" below or visiting Your account settings. If You send an e-mail, we may require additional information from You to allow us to confirm Your identity.

B. Communications.

You can opt-out of receiving promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link, or e-mailing us at the e-mail address set forth in the section entitled "Contact Us" below with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that You cannot opt-out of non-promotional e-mails, such as those about Your account, transactions, servicing, or P3's ongoing business relations.

C. Your California Privacy Rights.

California's "Shine the Light" law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties' and affiliates' own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing.

P3 may share personal information as defined by California's "Shine the Light" law with third parties and/or affiliates for such third parties' and affiliates' own direct marketing purposes. If You are a California resident and wish to obtain information about our compliance with this law, please contact us as set forth in the section entitled "Contact Us" below. Requests must include "California Privacy Rights Request" in the first line of the description and include Your name, street address, city, state, and ZIP code. Please note that P3 is not required to respond to requests made by means other than through the provided e-mail address or mail address.

D. Your European Privacy Rights.

Data subjects in Europe have additional rights as set forth in the "Additional Disclosures for Data Subjects in Europe" section below.

7. Children.

The Service is not directed toward children and we do not knowingly collect information from children through the Service without verifiable parent consent. Please visit our Children’s Privacy Notice for any information about children. If You believe P3 has collected information from children in violation of applicable law, please contact us as at the e-mail address set forth in the section entitled "Contact Us" below.

8. Data Security.

We make it a priority to ensure the protection of Your Data.

We maintain a strict data protection commitment and have taken appropriate technical and organizational measures to protect Your Data against unauthorized or unlawful processing and against loss, destruction, damage, modification or disclosure. These measures include informing staff of their confidentiality obligations as well as technical security measures (protection of their CRM, etc.).

Please however note that although we take the necessary measures and safeguards to protect Your data, transmission via the internet is not completely secure.

9. Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates Your consent to the Privacy Policy then posted. If the changes are material, we may provide You additional notice, to Your e-mail address.

10. Validity of the Privacy Policy’s provisions

If We do not use/invoke one of the provisions of the present Privacy Policy for a period of time, this cannot be interpreted in any way as a waiver to enforce such rights on a later stage.

The nullity, interpretation and/or execution of some of the provisions implies by no means the invalidity of all provisions. The provision that is wholly or partially invalid, void or unenforceable is to be considered as unwritten. We undertake to replace this provision by another who, as far as possible, pursues the same goal.

11. Contact Us.

If You have any questions or comments about this Privacy Policy, please contact us:

By e-mail:

[email protected]

By post:

P3 Inc.
29003 Avenue Sherman
Valencia, CA 91355

12. Additional Disclosures for Data Subjects in Europe.

A. Data Controller.

Data protection laws in Europe make a distinction between organizations that process personal data for their own purposes (known as "controllers") and organizations that process personal data on behalf of other organizations (known as "processors").

P3 acts as a controller with respect to personal data collected as You interact with the Service. In other instances, P3 acts a processor on behalf of its customers, separate legal entities, which are the controllers. For example, P3 processes personal data provided to it by Your Voting Group in order to allow Your Voting Group to provide You with access to the Service. Please visit the applicable customers' privacy policy for information about their privacy practices. Any questions that You may have relating to the processing of personal data by P3 on behalf of its customers and Your rights under data protection law should be directed to the customers as the controllers, not to P3.

B. Lawful Basis for Processing.

Data protection laws in Europe require a "lawful basis" for processing personal data.

In view of the purposes set out in article 3, the legal basis for processing Your personal data is as follows

• The performance of a contract to which You are a party;
• Compliance with a legal obligation to which we are subject;
• Our legitimate interests, unless these override Your interests or fundamental rights and freedoms; and ;
• In certain cases, Your consent.

C. Data retention

We keep Your Data for as long as necessary to achieve the purposes for which it is collected. The retention periods may vary from one processing operation to another, depending on the purpose and the legal basis for the retention periods. Once the purpose is achieved, we either delete or anonymize Your Data.

D. Data transfers outside the European Union

Your Data may be transferred to entities located in different countries (including countries outside the European Economic Area).

We implement appropriate safeguards to ensure the lawfulness and security of such transfers of Data, in particular by relying on adequacy decisions of the European Commission, standard data protection clauses adopted by the European Commission, Binding Corporate Rules and any other safeguards or conditions considered adequate to the transfer in question.

Our Company is based in the U.S. If You are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions.

In July 2023, the European Commission adopted an adequacy decision with regard to the United States, which means that it considers that the USA provides an adequate level of protection for personal data.

E. Your European Privacy Rights.

We wish to inform You that, in the context of the processing of Your Data, You have the right:

• Right of access: To obtain confirmation that We are processing Your Data and to request a copy of that Data at any time and free of charge. We may ask You for proof of identification before granting Your request.
• Rights to rectification: To request that We update Your Data or correct Data that You consider to be inaccurate or incomplete.
• Right of erasure: To request that We delete Your Data or restrict the way in which We use it if You consider that there is no or no longer any lawful basis for processing it.
• Right to withdraw consent: To withdraw Your consent to the processing of Your Data (to the extent that the processing is based on Your consent).
• Right of limitation of processing: To obtain a limitation of processing when You have objected to the processing, when You dispute the accuracy of the personal data, or when You consider that the processing is illegal.
• Right of objection: To object to the processing of Your Data for which We use legitimate interest as a legal basis. In such cases, We will stop processing unless We have compelling legitimate grounds for doing so.
• Right of portability: To receive a copy of the Data You have provided to us in a structured, commonly used and readable format and to pass that Data on to another party (another data controller, to the extent that the processing is based on consent or contract).

We will take all necessary measures to satisfy such a request as soon as possible and in any case within one month of receipt of the request. If necessary, this period can be extended by up to two months, given the complexity and the number of requests.

If Your personal data has been processed by us on behalf of a customer and You wish to exercise any rights You have with such personal data, please inquire with our customer directly. If You wish to make Your request directly to us, please provide the name of our customer on whose behalf we processed Your personal data. We will refer Your request to that customer, and will support them to the extent required by applicable law in responding to Your request.

F. Complaints.

If You wish to exercise any of the rights set out above, report a problem with our applications, require specific assistance or wish to send a comment, please contact us by the means set out below:

By e-mail:

[email protected]

By post:

P3 Inc.
29003 Avenue Sherman
Valencia, CA 91355

Please do not hesitate to contact Us if You consider that We are not treating Your Data with the care that You expect. You can also contact the Data Protection Authority of Your country directly and/or lodge a complaint.

We would, however, appreciate the opportunity to address Your concerns before You approach a data protection regulator, and would welcome You directing an inquiry first to us.