*Indicates non-mandatory items you can optionally provide in response to survey questions. 

**This data is considered “Sensitive” under the California Privacy Rights Act (CCPA) and the Virginia Consumer Data Protection Act (VCDPA).

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Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You

When you provide such information directly to us.

• When you create an account or use our website or mobile application.
• When you voluntarily provide information in free-form text boxes, such as to reserve a Telly device, or through responses to surveys or questionnaires.
• When you send us an email or otherwise contact us.  

When you use our Services and such information is collected automatically.

• Through Cookies and other similar tracking technologies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
• If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.

Third Parties

Vendors

• We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
• We use fraud-detection providers to detect, prevent and combat harmful or unlawful or fraudulent behavior and to maintain the integrity of our Services.

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Our Commercial or Business Purposes for Collecting or Disclosing Personal Data

Providing, Customizing and Improving the Services

• Creating and managing your account or other user profiles.
• Providing you with the Services or information you request.
• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Services.
• Improving the Services, including testing, research, internal analytics and product development.
• Customizing the Services, website content and communications based on your preferences.
• Doing fraud protection, security and debugging.
• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the CCPA.

Advertising

• Showing you advertisements, including interest-based or online behavioral advertising (including cross-context behavioral advertising or targeted advertising).

Corresponding with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Telly or the Services.
• Sending emails and other communications according to your preferences or that display content that we think will interest you.

Meeting Legal Requirements and Enforcing Legal Terms

• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property or safety of you, Telly or another party.
• Enforcing any agreements with you.
• Responding to claims that any posting or other content violates third-party rights.
• Resolving disputes.

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We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.  If you are a California resident, please note that we only use or disclose your information for the purposes set forth in section 7027(m) of the CCPA regulations and we do not collect or process information with the purpose of inferring any characteristics about California residents.

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How We Disclose Data

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We disclose Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data or sharing for cross-context behavioral advertising. For more information, please refer to the state-specific sections below.

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Service Providers. These parties help us provide the Services or perform business functions
on our behalf. They include:

• Hosting, technology and communication providers.
• Data privacy and security compliance platforms.
• Security and fraud prevention vendors and platforms.
• Support and customer service vendors.
• Product fulfillment and delivery providers.
• Payment processors.

Advertising Partners. These parties help us deliver relevant advertisements to you. They include:

• Advertisers, ad agencies, and our and their advertising technology companies and partners, to show you ads that we think may interest you and measure the effectiveness of those ads. 

Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:

• Companies that track how users found or were referred to the Services.
• Companies that track how users interact with the Services.

Business Partners. These parties partner with us in offering various services. They include:

• Businesses that offer services or apps through the Telly Device that you connect to or interact with.
• Companies that we partner with to offer joint promotional offers or opportunities.

Parties You Authorize, Access or Authenticate

• Third parties you access through the Services.

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Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting or Disclosing Personal Data” section above. 

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Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

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Data that is not Personal Data

We may create aggregated, de-identified or anonymized data from the data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.  

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Tracking Tools, Advertising and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, mobile device identifiers and JavaScript (collectively, “Cookies”) to enable our (and our vendors’) servers to recognize your web browser or mobile device, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because the effect of “Do Not Track” signals remains unclear, and there continues to be no consistent industry understanding of how to respond to such a signal, we do not alter our privacy practices when we detect a “Do Not Track” signal from your browser.

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or Services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and Services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to size our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics Services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout. 
• Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and/or identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”

3^rd PARTY COOKIES

The website contains both 1^st party and 3^rd party cookies. While certain cookies on this site may be both 3^rd party and controlled by us, we do not control either the expiry (how long a cookie will remain on your computer) or the retention (how long the 3^rd party will retain information) relating to the majority of cookies on this site which are both 3^rd party and not controlled by us. We make no representations about these cookies. For more information about these cookies, please access the privacy policies of the parties which set the cookies from the links here.

AVAILABLE COOKIE CHOICES

Choice with respect to cookies comes in 3 forms:

• Browser controls – All modern browsers allow you to set preferences with respect to any particular cookie issuer or more generally by 1^st or 3^rd party.
• Opt-Out Controls – Many advertisers and adtech providers offer an Opt-Out function. If this is selected they still set or read a cookie, but the cookie is generally a placeholder to remember your choice as having opted out or is not used for interest-based advertising. It is generally of the form ID=OPT_OUT and conveys no unique information.

Advertising industry opt outs include:

• US - www.abotuads.info/choices
• US - www.networkadvertising.com/choices

Please note that opt outs operate by placing a cookie on your device that is unique to the browser and device you use to opt out. They may not function properly if you have configured your browser to reject certain cookies. If you change browsers or devices, or delete the cookies on your device, you will need to opt out again. You also can set your browser to notify you when a cookie is being set and to block most cookies. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit allaboutcookies.org.

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Information about Interest-Based Advertisements: 

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or Services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) to you through the Services. These trackers enable advertising technology providers to serve targeted advertisements to you when you visit other websites. These trackers allow advertising technology providers to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site. 

Data Security 

We seek to protect Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational, and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data Retention

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases, we retain Personal Data for longer following the end of you having an open account or using our Services, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

• We retain your profile information and credentials for as long as you have an account with us.
• We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively, and efficiently.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 18 years of age; if you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18  years of age may have provided Personal Data to us, please contact us at support@freetelly.com.

California Resident Rights

If you are a California resident, you may have the rights set forth in this section pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain Services to our customers. If we are processing your data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Telly Website, App and Reservations Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@freetelly.com.

Access

You may have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

• The categories of Personal Data that we have collected about you.
• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting or selling your Personal Data.
• The categories of third parties with whom we have shared your Personal Data.
• The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third-party recipient.

Deletion

You may have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request. 

Correction

You may have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.

Personal Data Sales and Sharing Opt-Out 

In this section, we use the terms ‘sell’ and ‘share’ as defined in the CCPA. We sell or share Personal Data governed by the Telly Website, App and Reservations Privacy Policy, subject to your right to opt-out of selling and sharing.

As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on websites or other digital properties you visit. Under the CCPA, sharing your data through Cookies for online advertising may be considered a “sale” or “sharing” of information. 

We may sell or share Personal Data with the following categories of third parties:

• Analytics Partners
• Advertising Partners
• Business Partners

Over the past 12 months, we may have sold or shared the following categories of your Personal Data with the categories of third parties listed above:

• Device/IP Data 
• Device Analytics

Over the past 12 months, we have sold or shared those categories of your Personal Data with the categories of third parties listed for the following purposes:

• Improving the Services, including testing, research, internal analytics and product development.
• Personalizing the Services, website content and communications based on your preferences.
• Doing fraud protection, security and debugging.
• Showing you advertisements, including cross-context behavioral advertising.

You have the right to opt-out of the sale of your Personal Data or the sharing of it for cross-context behavioral advertising. You can opt-out using the following methods:

• Email us at support@freetelly.com.
• For browsers that support it, you can use a Global Privacy Control or similar control that is legally recognized by a government agency or industry standard and that complies with the CCPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals. Please also note not all browsers support GPC at this time. 

Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.

To our knowledge, we do not sell the Personal Data governed by the Telly Website, App and Reservations Privacy Policyof minors under 16 years of age.

Please note that if you are selected to receive a Telly device, our collection, use and sharing of your Personal Data will be governed by our Telly Device Privacy Policy [www.telly.com/device-privacy-policy]. Please refer to that Policy for more information. 

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. 

Virginia Resident Rights

If you are a Virginia resident, you have the rights set forth under the Virginia Consumer Data Protection Act (“VCDPA”). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain Services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Telly Website, App and Reservations Privacy Policy and you are a Virginia resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@freetelly.com.

Access

You may have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.

Correction

You may have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.

Portability

You may have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.

Deletion

You may have the right to delete your Personal Data.

Opt-Out of Certain Processing Activities

If you are a Virginia resident, you may have the right to opt-out of the processing activities identified below.

• You may have the right to opt-out of the processing of your Personal Data for targeted advertising purposes. We may process Personal Data governed by the Telly Website, App and Reservations Privacy Policy for targeted advertising purposes. To opt-out of our processing of Personal Data for targeted advertising purposes, please click Do Not Sell or Share My Personal Information [www.telly.com/do-not-sell-my-personal-data] or email us at support@freetelly.com.

               -  Please note that if you are selected to receive a Telly Device, our processing of your Personal Data will be governed by our Telly Product Privacy                   Policy [www.telly.com/product-privacy-policy]; we process Personal Data governed by our Telly Product Privacy Policy                   [www.telly.com/product-privacy-policy] for targeted advertising purposes. Please refer to that Policy for more information.

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• You may have the right to opt-out to the sale of your Personal Data. As discussed in the “Personal Data Sales and Sharing Opt-Out and Opt-In” under the “California Resident Rights” section, some of our data sharing relationships may constitute a “sale” as defined by the VCDPA. 

                -  Please note that if you are selected to receive a Telly Device, our processing of your Personal Data will be governed by our Telly Product Privacy                     Policy [www.telly.com/product-privacy-policy]; we sell Personal Data governed by our Telly Product Privacy Policy                    [www.telly.com/product-privacy-policy]. Please refer to that Policy for more information.

• You may have the right to opt-out from the processing of your data for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, if applicable

Appealing a Denial

If we refuse to take action on a request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the VCDPA. We will respond to your appeal within 60 days of receiving your request. If we deny your appeal, you have the right to contact the Virginia Attorney General using the methods described at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.

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You may appeal a decision by us using the following method:

• Email us at: support@freetelly.com (title must include “VCDPA Appeal”)

Exercising Your Rights under CCPA and VCDPA

To exercise the rights described in this Telly Website, App and Reservations Privacy Policy, you or, if you are a California resident, your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

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We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following method:

• Email us at: support@freetelly.com

If you are a California resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

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Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at support@freetelly.com. 

Please note that because the effect of “Do Not Track” signals remains unclear, and there continues to be no consistent industry understanding of how to respond to such a signal, we do not alter our privacy practices when we detect a “Do Not Track” signal from your browser.
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Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain data to third parties who intend to license or sell that data. You can exercise this right by contacting us at support@freetelly.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your data as sales are defined in Nevada Revised Statutes Chapter 603A. 

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Contact Information:

If you have any questions or comments about this Telly Website, App and Reservations Privacy Policy, the ways in which we collect and use your data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

• www.telly.com
• support@freetelly.com
• 14622 VENTURA BLVD #102 PMB 2037 SHERMAN OAKS, CA 91403

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