Last Updated: May 13, 2024

This Privacy Policy applies to C919 Media, Inc. (“C919″,”We”, “Us”, or “Our”) and describes the collection, use, disclosure, and protection of information gathered through the C919 network of Websites, including C919.com, C919.com, email newsletters distributed by us (hereinafter “Web sites” or “Sites”), C919 mobile applications (hereinafter “Apps”), and other products or services owned or operated by C919 (together hereinafter “Services”). C919 is committed to protecting the confidentiality and security of information it collects through its Services. Please read the following carefully. Your use of our Services is governed by this Privacy Policy and C919’s Terms of Use (available here: https://www.C919.com/terms). Our Privacy Policy and Terms of Use do not apply to any third-party websites, services or applications, even if they are accessible through our Services.

By using our Services, you are accepting the practices described in our Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Services.

• Revisions to this Privacy Policy. Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of these changes, for example by posting them on the Services or providing email or other notice, and we’ll update the “Last Updated” date at the top of the Privacy Policy to indicate when those changes will become effective. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services.
• Information We Collect.
• Device Related Information. We collect information about the devices you access to our Services, such as IP address, device ID, cookies, user settings and preferences, operating system, app and file names and types, app version and other information permitted by Android or iOS based on their policies and your settings.
• Location Information. We may collect general location information about your device that you volunteer or enable through the App or your device. When an app user selects precise location, your device transmits to us your general location.
• Usage Information. We collect information about how you use our Services, such as the type of content you view, and the time, frequency and duration of your activities, advertisement interactions and other usage information and performance data related to the Services and usage of them.
• Information You Provide When Sign-In. If you register for an account with us, you provide us your account name, email address, password. You might choose to provide your birth year or gender. You may also be able to register using your user credentials to certain social media sites, such as Facebook, Google or Apple (“Social Networks”), and when you do, Social Networks might share with us your account name, email address, profile image or other information based on their policies and your settings. We may collect your contact list upon obtaining your consent.
• Information You Provide as a One-Time Request. You may provide us with certain information when you submit a request or claim on our Apps or to us.
• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information about you.
• Information You Provide When Posting Content. You may provide us with the content you create, like posts, comments, audio, picture, or video, and the content you provide through our camera feature or your camera roll settings with your permission.
• Information You Provide When You are Our Business Partners. You may provide your business name, legal name, email, phone number, Tax ID and other business contact information.
• Information You Provide When you are Content Provider. You may provide publication name, legal name, email phone number, occupation, publication description, publication profile picture, publication coverage area, blog website, and social media links.
• Cookies. Like most websites, we use cookies and similar technology to collect information about Site usage by all of our visitors and to help us remember you and your preferences when you revisit the Site. These cookies may stay on your browser into the future until they expire or you delete them. Further general information about cookies and how they work is available at www.allaboutcookies.org. We may allow selected third parties to place cookies or tracking pixels through the Site for analytics or advertising purposes on our or other sites, apps, or social media and they may collect information about your online activities or device related information over time and across different websites when you use our Sites. We do not use technology that recognizes a “do-not-track” signal from your web browser.

3. How We Use Your Information. Our primary purposes for the collection and processing of information are to provide our Services (to perform our contract with you), to improve our Services, to administer your use of the Services, to market the Services to you, and to enable you to enjoy and easily navigate our Services. Also, we may process your information where we have a legitimate interest (e.g., fraud prevention, network and information security, research (including marketing research), and direct marketing), and as you otherwise consent.
   
   We will use your information in one or more of the following ways:

Performing Services for You:

3. As necessary for the Web sites or Apps to function or provide you with Services properly;
4. Improve user experience;
5. Perform statistical, demographic, and marketing analyses of users of the App;
6. Communicate with you about your questions, claims or technical support; and
7. Communicate with you about changes to our policies, and send you information about features and enhancements on our Sites and Apps.

Advertising Customization and Measurement; Marketing:

• Personalize content and experiences on our Services, including providing you reports, recommendations, ads and feedback based on your preferences, and measuring and analyzing that advertising (e.g., which advertising is more effective or engaging);
• Marketing to you regarding products and services we believe might interest you; and
• Send invitation to the connections in your contact list.

Internal Research and Development; Quality Control:

• In the aggregate to help us evaluate and modify existing Services and to help us develop additional services that are likely to be of interest to our users;
• Optimize or improve our products, services and operations; and
• To monitor quality control, verify your business and ensure compliance with our legal obligations, codes and ordinances, policies and procedures.

Security Detection, Protection and Enforcement; Functionality Debugging, Error Repair:

• Detect, investigate, and prevent activities that may violate our policies, including our content policies and all applicable terms for our Services, or be illegal;
• Recognize repeat visitors and facilitate ongoing access to the Services; and
• Verify your or your authorized agent’s identity.

Other uses about which we notify you.

4. Information We Share with Third Parties. We will not share any information that we have collected from or regarding you without your consent except for the purposes described in “How We Use Your Information” and as described below:
5. Advertising and Marketing Partners. We may use our advertising partners’ software development kits (“SDKs”). Our Advertising Partners can access your information through the SDKs so that they can decide whether to bid on ad inventory or serve an advertisement and choose the best ad for you on the Services. We may provide your online activities or device related information to our marketing partners to promote our products and services to you.
6. Affiliates and Service Providers. Our affiliates and service providers are necessary to provide our Services. We may share the information we collect with our affiliates or service providers who may process the information in their facilities subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures.
7. Content Providers. When you follow a content provider, the content provider can access your account name, general location, profile picture if you sign-in through a Social Network.
8. Content You Create/General Location. Your username, general location, the content you like, and the content you create, such as your posts, comments, or video, are available to the public. You can exclude your general location from the public comments in your settings.
9. Legal Obligations. We cooperate with government and law enforcement officials or private parties to enforce and comply with applicable laws and regulations.
10. Third-Party Video Player. We provide the capability for content publishers to integrate their video players on our Services, allowing you to access their video content.  Additionally, we may embed third-party video players, such as YouTube, for certain videos. When you activate a video through a third-party video player, they may collect your user information. Their use of your information will be governed by their privacy policy. We do not receive this information.

5. Your Choices. You may have the right to opt out of certain uses of your information:
6. Opt-out of Email Communications. We may periodically send you free newsletters and emails that directly promote our Services. When you receive such promotional communications from us, you will have the opportunity to “opt-out” (either through the App (if applicable) or by following the unsubscribe instructions provided in the email you receive). We do need to send you certain important communications regarding the Services, and you will not be able to opt out of those communications.
7. Opt-out of Ad Tracking. You may opt-out of certain targeted advertising from participating entities by visiting http://optout.aboutads.info/#/ or http://optout.networkadvertising.org/# on each of your devices and browsers. If you change or upgrade your browser or device, or delete your cookies, you may need to use these opt-out tools again. Some Cookie-management solutions also rely on Cookies, so please adjust your browser Cookie settings carefully. We do not maintain or control the opt-out mechanisms and settings below and are not responsible for their operation. Your mobile device may also include settings that allow you to manage the use of cookies, such as Limit Ad Tracking or Tracking settings in iOS and Opt out of Ads Personalization in Android. You may also visit or download and use the AppChoices app at http://www.aboutads.info/appchoices on each of your devices.
   
   Please note that, if you change or upgrade your device you may need to use these opt-out tools again. Please review the instructions and information at the links above carefully for more information about how these tools work. We do not maintain or control the opt-out mechanisms and settings and are not responsible for their operation.
8. More Opt-out on Mobile Apps. You have choices when it comes to how Apps function on your mobile device. Access to or availability of controls may vary depending on your device. You may be able to:
9. Manage push notifications by using your built-in mobile device settings and controls;
10. Manage location information by using your built-in mobile device settings and controls;
11. Manage/restrict in-app purchases by using your built-in mobile device settings and controls; or
12. Block navigation to the web by turning off network access on the device or turning off the browser.
13. Reject Cookies. You may Reject Cookies by selecting that option on the banner that appears when you visit the Site.  This will tell us not to set any cookies on your browser except for cookies that are strictly necessary to operate our Site and a single preference cookie that tells us you do not want cookies to be set.  When you make this selection some Site features may not be available or may not function.

6. Notice to California Residents Regarding “Shine the Light” Rights. California’s “Shine the Light” law (Cal. Civil Code section 1798.83) gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined by applicable California law) with third parties for their direct marketing purposes, or to permit such residents to “opt out” of such sharing. We do not share your personal information with third parties for their own direct marketing purposes.
7. NOTICE TO RESIDENTS OF CALIFORNIA, COLORADO, TEXAS, VIRGINIA AND UTAH
   
   If you are a California, Colorado, Connecticut, Virginia or Utah Consumer, laws in those states require us to provide you with some additional information regarding how we collect, use, and share your “personal information” as defined in the California Consumer Privacy Act of 2018/ Privacy Rights Act, the Colorado Privacy Act, the Connecticut Personal Data Privacy Act, the Utah Consumer Privacy Act, the Texas Data Privacy and Security Act, and the Virginia Consumer Data Protection Act (collectively the Privacy Laws).
   
   California defines a ‘Consumer’ as any resident of the state regardless of the capacity in which they interact with us.
   
   Our California employees (current, former or applicants) can learn about our information collection and disclosure practices and how to exercise their CPRA rights by contacting the Director of Human Resources.  This Privacy Policy does not include disclosures about employee information that we collect, use, retain and disclose.
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   Colorado, Connecticut, Texas, Virginia and Utah define a ‘Consumer’ as a resident of the state who is acting in an individual or household capacity, but this excludes state residents who are acting in an employment capacity (as one of our current, former or prospective employees) or in a commercial capacity (as an employee, owner, director, officer, etc. of an entity communicating with us in that context). As a result, if you reside in one of these states and have interacted with us in an employment or commercial capacity you are not provided the rights described below by the Privacy Laws.
   
   Categories of personal information we collect.
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   ‍Throughout this Privacy Policy, we discuss in detail the specific pieces of personal information we collect from and about users. We collect different information from Site Users, Content Providers (individuals and businesses) and Business Partners and not all information is collected from all individuals. Under the Privacy Laws, we are also required to provide you with the “categories” of personal information we collect. The categories of information that we collect are: identifiers; commercial information; internet or other network or device activity; geolocation information; employment, education and professional related information; sensitive personal information; inferences we make about you or your interests based on analysis of other information we have collected; and other information that identifies or can be reasonably associated with you. Please see below for additional detail about information we have collected about Site Users, Content Providers (individual and businesses) and Business Partners.
   
   During the past 12 months we may have collected the following categories of personal information. This includes information that you provide to us directly, information we collect from you automatically, information that we collect when you interact with us such as through your online postings, and information that we may collect from third parties such as service providers, affiliated companies, marketing or data partners, or other third parties with whom you interact. It also includes information that we collect about business partners and vendors from those individuals directly or from references or referrals. Not all information is collected from everyone who interacts with us.
   
   Site user information: Identifier information (profile name, device identification information) and electronic network activity information (IP Address and interactions with our Site) are collected directly from Site users.
   
   Content Provider Information (Individuals): Identifier information (name, profile name, device identification information, email address), content posted (comments, audio, picture, video), general location information, and electronic network activity information IP address and interactions with our Site) are collected directly from individuals posting content to the Site. We also collect inferences based on content posted.
   
   Content Provider Information (Business): Identifier information, electronic network activity information, commercial information (transactions with us), content posted (audio, picture, video), professional related information, sensitive information (taxpayer identification, anti-discrimination information used for legal compliance) are collected from companies that provide content to us.
   
   Business Partner Information (Service providers): Identifier information, commercial information (transactions with us), business address),  professional related information, sensitive  information (taxpayer identification, anti-discrimination information used for legal compliance) are collected from companies that provide services or products to us.
   
   Business purposes for collection of personal information. We and our service providers may use and disclose the categories of personal information we collect from and about you for the following business and commercial purposes (as those terms are defined in applicable law:
8. Performing services for you;
9. Advertising customization and measurement;
10. Marketing to you regarding products and services we believe might interest you;
11. Research and development;
12. Improving our Services;
13. Detecting, protecting against, and prosecuting violations of our terms and policies, security incidents, and fraudulent or illegal activity;
14. Managing and overseeing our staffing needs (current, former and applicants) and our vendors;
15. Other uses about which we notify you.
    
    Examples of these types of uses are discussed in the “How We Use Your Information” section in our main Privacy Policy above. We may also use the categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.
    
    Processing Sensitive Personal Information. We collect limited information in this category from Business Content Providers and Business Partners/Service Providers.  We process and disclose Sensitive Personal Information only for the purposes permitted by Privacy Laws and as disclosed above or at the time we collect this information unless otherwise required by law. Sensitive Personal Information we collect from Business Content Providers and Business Partners/Service Providers includes Social Security, driver’s license, or passport numbers; account log-in; financial account information without required access codes or passwords; racial, ethnicity, religious or philosophical beliefs; precise location (within 1850 feet); union membership; gender; and health information.
    
    Processing Precise Geolocation. When an app user selects precise location your device transmits to us your general location so that we may provide relevant content and advertisement based on your location. We do not store or monitor your precise geolocation. You can always withdraw your consent.
    
    Disclosure of Information
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    During the past 12 months we have disclosed the following categories of personal information to the following types of third parties for a business purpose as described above.
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    Affiliated companies: We may have disclosed identifiers and commercial information with affiliates for purposes of decision making, reporting, management, analysis and other business purposes.
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    Service providers, publishers and marketing partners: We may have disclosed information such as identifiers, commercial information, geolocation, internet or other electronic network activity, and inferences with service providers, content provider, and marketing partners for purposes of providing the Services to you, processing payments, legal and accounting services, advertising and analytics services.
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    Other third parties: We may have disclosed any or all categories of information with governmental authorities, law enforcement or others to comply with our legal obligations, to enforce our agreements, or to protect or defend the rights and property of our company or others.
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    Selling and Sharing Personal Information
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    We do not sell personal information for monetary consideration but we may transfer your information to a third party that provides us with services such as helping us with advertising, data analysis and analytics, and security, which may fall under the definition of for “other valuable consideration” and which may therefore be considered a “sale” under the Privacy Laws. During the past 12 months leading up to the effective date of this Privacy Policy, we “sold” (as that term is defined under the CPRA), identifiers, commercial information, geolocation, and internet or other electronic network activity (like a record of a browser’s visit to our website) to marketing and advertising services to assist with such activities. We do not “sell” personal information if we have actual knowledge that the consumer is less than 16 years of age.
    
    “Sharing” your personal information means making it available to a third party so that they can use it to display targeted or cross-context behavioral advertisement to you. Cross-context behavioral or targeted advertising means that we display an advertisement to you that is selected based on personal information about you that we obtained or inferred over time from your activities across other companies’ websites, applications or online services that we use to predict your preferences or interests. Targeted advertising and profiling does not include using your interactions with us or information that you provide to us to select advertisements to show you. In the preceding twelve (12) months, We may have shared identifiers, commercial information, geolocation, and internet or other electronic network activity (like a record of a browser’s visit to our website) of non-minors for behavioral or cross context or targeted advertising purposes.
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California, Colorado, Connecticut, Texas, Virginia and Utah Privacy Rights

If you are a California, Colorado, Connecticut, Texas, Virginia or Utah Consumer, you have the following rights:

1. Access Rights. The right to request and receive up to twice in as 12 month period disclosure of:
2. our information collection practices – the categories of personal information we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, the categories of third parties with whom we share such information;
3. our information sharing practices – a list of the categories of personal information sold with the category of third party recipients and a list of the categories of personal information that we disclosed for a business purpose; 
4. the personal information we have collected about them during the prior 12 months, or at their option, since January 1, 2022. 

2. Deletion Rights. The right to request that we delete (and direct our service providers to delete) their personal information subject to certain exceptions.
3. Correction Rights. The right to request that we correct information that we hold which is inaccurate.
4. Opt-Out Rights.
5. Do Not Sell My Personal Information. The right to request that we not sell personal information about them;
6. Do Not Share My Personal Information. The right to request that we not share personal information for cross-context or behavioral marketing purposes; 
7. Limit Processing of Sensitive Personal Information. The right to request that we do not process Sensitive Personal Information for any purpose other than the purpose for which we originally collected it as disclosed in this Privacy Policy or before it is collected. We only process and disclose sensitive personal information for these purposes.

Colorado, Connecticut, Texas, Virginia, and Utah Consumers also have the right to direct us not to engage in profiling using their personal information but only where that information is used to make decisions that result in a legal or similarly significant effect on the consumer, such as the provision or denial of financial or lending services, housing, insurance, education enrollment or opportunity, criminal justice, employment opportunities, health-care services, or access to essential goods or services, While we may use automated processing of personal information to evaluate, analyze or predict personal aspects related to your economic situation, health, personal preferences or interest, etc. to deliver content to you based on your interactions with us, we do not use profiling information to make decision that result in a legal or similarly significant effect on you. As a result, you do not need to tell us not to engage in profiling that results in a legal or similarly significant effect on you.
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We will not discriminate against you as a result of your exercise of any of these rights.
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Exercising your rights

To exercise your Access, Deletion or Correction rights, please send an email to [email protected] with a subject of “Privacy Law Request”. You must include your name, address, email and telephone number so that we may identify you; we only use this information for identification purposes for responding to your requests.

In order to protect your information, we may need to verify your identity (that you are the person about whom we collected personal information) before processing your request. In some cases we may need to collect additional information to verify your identity, such as a government issued ID. We will acknowledge receipt of your request within 10 days and respond within 45 days; if we need additional time (up to 45 additional days) we will notify you.

We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you. Please understand due to very limited personal information we receive from Site Users and Individual Content Providers, we might not be able to verify your identity sufficiently in order to process your request.

Do not Sell or Share Opt Out. To exercise your rights to Opt Out of having your personal information “sold” or shared for cross-context behavioral marketing purposes you can follow the instructions on our Do Not Sell or Share My Personal Information form.

No Opt Out regarding Sensitive Personal Information or Profiling. You do not need to opt out or tell us to limit processing of Sensitive Personal Information or to limit profiling that results in legally or similarly significant effects on consumers because we do not engage in covered activities. We only process and disclose Sensitive Personal Information for the purposes permitted by Privacy Laws and for which we originally collected it as disclosed in this Privacy Policy or at the time we collect it unless otherwise required by law. As noted above, we only collect very limited Sensitive Personal Information and only from Business Content Providers and Business Partners/Service Providers. Further, we do not engage in profiling that results in legally or similarly significant effects on consumers.
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You may also opt out by activating a user-enabled global privacy control, such as a browser plug-in or privacy setting, device setting, or other mechanism, that communicates or signals your choice to opt-out of the sale and sharing of personal information. When we receive such a signal we will stop setting third party, analytics, or advertising partner cookies on your browser. This will prevent the sale or sharing of information relating to that specific device through cookies to our advertising or analytics partners. This option does not stop all sales or sharing of your information because we cannot match your device’s identification or internet protocol address with your personally identifiable information like your name, phone number, email address or ZIP Code. If you delete cookies on your browser, any prior do not sell or do not share signal is also deleted and you should make sure that your user-enabled setting is always activated.

Under the Privacy Laws you can also designate an authorized agent to exercise your rights on your behalf. We may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.

If we have denied your Consumer request you have the ability to file an appeal with us. To file an appeal with us, please send an email to [email protected] with a subject of “Privacy Law Request”.

We will respond to you in writing within 45 days explaining the reasons for our decisions. If we deny your appeal Colorado, Connecticut. Texas, Virginia, and Utah Consumers can contact your state Attorney General at:

Colorado residents:
Office of the Attorney General
Colorado Department of Law
Ralph L. Carr Judicial Building
1300 Broadway, 10th Floor
Denver, CO 80203
(720) 508-6000

Connecticut residents:
Office of the Attorney General
165 Capitol Avenue
Hartford, CT 06106
860-808-5318

Texas residents:
Office of Attorney Genera
lPO Box 12548
Austin, TX 78711-2548
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Virginia residents:
Office of the Attorney General
202 North Ninth Street
Richmond, Virginia 23219
(804)786-2071 

Utah residents:
Utah State Capitol Office Mailing Address
Office of the Attorney General
PO Box 142320
Salt Lake City, UT 84114-2320
General Office Number:
1-801-366-0260

California Residents (Appeal Not Applicable)

8. Nevada Residents Only. We do not transfer personal information for monetary consideration. If you would like to tell us not to sell your information in the future please email us at [email protected] with your name, postal address, telephone number and email address with “Nevada do not sell” in the subject line.
9. The Security of Your Information. We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you from unauthorized access, use or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the security of any information.
10. Data Retention. We retain the information we collect for as long as your use of our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
11. Links to Other Sites. Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-party Services that you access.
12. Data Processing. Our Sites are maintained on AWS servers located in the U.S., and your information submitted is processed and stored in the U.S.. If you are visiting our Sites from outside the U.S., please be advised that your information is transferred to the U.S..
13. Our Policy toward People under 13. Our Services are not directed to people under 13 and we do not knowingly collect information from individuals under the age of 13. If you are between 13 and 18, you must have permission from your legal guardian before you are permitted to use the Services. If you are a parent or legal guardian and think your child under 13 has given us information, you can email us at [email protected]. You can also write to us at the address listed at the end of this Privacy Policy.
14. Questions? Please contact us at [email protected], or 800 W El Camino Real, Suite 300, Mountain View, CA 94040.