PRIVACY POLICY

Toggle Media, LLC (“Toggle”, “us” or “we”) offers you (the “User”) limited access to certain content, data and services through a password-protected, proprietary application accessible through the hellotoggle.com website and Toggle mobile application (or “App”) (collectively referred to herein as the “Services”). Through your use of the Services, Toggle collects information from and about you. You should read this Policy carefully as it contains important information about your privacy rights and choices.

Please note that we may update or change this Policy from time to time. We will always post our most updated policy on Toggle’s website at hellotoggle.com.

DATA WE COLLECT. Toggle collects the following types of data from and about you:

  1. Registration Information. This is the information you provide Toggle to (i) gain access to Services and (ii) enable us to bill your payment accounts for access to the Services.
  2. Account Information. This is the information, including your login and security credentials, that you have furnished to your video streaming service providers (“Subscription(s) providers”), including the login and security credentials that you use to access accounts at your  Subscription(s) providers .
  3. Billing Information. This is the information that you use to pay fees charged by your Subscription providers, including cardholder name and billing address, credit card number, CVV, card expiration date.
  4. Viewing Preferences. This is data about your video viewing preferences, including the streaming services you subscribe to and cancel, the shows you watch, and any lists you create on  the Subscription(s) providers.

DATA SOURCES. We collect this data from the following sources:

  1. Data you provide to us. When you initially register to use Toggle’s Services, we collect “Registration Information” from you including: name, email, phone number, address of your primary residence, and any referral code you used to register for the Toggle Services.. Once registered as a Toggle User, you may provide Toggle “Billing Information” so that we may charge you for our Services and “Account Information” that enables the us to link your Subscription(s) providers to the Toggle Service using the “Add subscription” feature. Also, as a User of our Services, we will periodically collect data on your viewing preferences, including which Subscriptions you activate and cancel, and when, which shows you watch, and other similar viewing behavior and preferences that will enable Toggle to configure its Services for you.
  2. Data from identity providers. If you choose to use an identity provider, such as Apple or Google, to facilitate your login to Toggle we will have access to and collect data that will verify your identity and authenticate your account access, as well as any associated profile information the identity provider may deliver to us.
  3. Data that we access from your Subscription providers. Depending on which Subscription providers you use, we will collect the data necessary to manage the Subscription for you and provide relevant suggestions for new content that may interest you. For example, this may include the following: (i) your Subscription account data, including account name, number, subscription type/tier, and billing information; (ii) Subscription financial information, including billing terms, payment balances; (iii) Subscription viewing history; (iv.) Subscription account usernames and security credentials; (v.) temporary or one-time passcodes (OTP) and other forms of temporary credentials used as an authentication factor by Subscription providers; and (vi.) various data on your usage patterns.
  4. Data from the electronic device you use to access Toggle. The mobile device you use to access Toggle’s Services provides us (i) your internet protocol (IP) address; (ii) timezone setting and device location; (iii) hardware model and operating system; (iv) browser data; and (v) other technical data regarding the device and your usage.
  5. Information we derive from the data we collect. We may derive additional information about you from the data we collect. For example, we may infer your geolocation and socio-economic characteristics from your viewing habits, preferences and selection of Toggle Offers.

HOW WE USE YOUR DATA. Toggle only uses your data for the following business and commercial purposes:

  1. Provide Services. To operate, provide and maintain the Services.
  2. Develop Existing Services To improve, enhance, modify, add to, and further develop the existing Services.
  3. Develop New Services. To develop new products and services.
  4. Develop Insights. To develop insights based on the data we’ve collected from and about you. This includes your selection of Subscription(s) providers, viewing preferences, and data from other sources so that we can provide services and/or a better user experience to you. We may share anonymized data regarding your content choices to third-party services in order to generate appropriate suggestions for you based on your past viewing behavior and preferences.

HOW WE SHARE YOUR DATA. We share your data for reasons that include:

  1. With our internal team and developers, but only as needed to create or maintain the Services.
  2. To enforce our Agreement with you.
  3. With your Subscription providers, but only as necessary to subscribe, cancel or restart your subscription services as you direct us to do.
  4. With your Payment Processor (see our Terms of Service) to bill you through a payment account that you have linked to your Toggle account.
  5. If we believe in good faith that disclosure is appropriate to comply with applicable laws, regulations, or legal processes (like a court order or subpoena).
  6. In connection with a change in ownership, control or reorganization of all or a part of our business (like a merger, acquisition, reorganization, or bankruptcy).
  7. As we believe reasonably appropriate to prevent malicious or fraudulent activities, or otherwise protect the rights, privacy, safety, or property of you, your Subscription providers, our partners in Toggle Offers, Toggle, and others.
  8. For any other notified purpose with your consent or at your direction.
  9. Generating suggested content for you that we may obtain from third-party analytics sources based on an anonymized list of your past viewing choices. 

We do not share your data with non-affiliated third parties except as permitted by law, nor do we sell or rent personal data that we collect under this policy.

We may collect, use, and share data that has been aggregated or anonymized in a manner that does not identify you personally for any purpose permitted under applicable law. This includes creating or using aggregated or anonymized data to develop new services or to facilitate research, to the extent permitted under applicable law.

OUR RETENTION AND DELETION PRACTICES.

We retain your data only as long as it is needed. To determine whether the data is needed, we consider the reason the data was collected and used and any legal requirements to hold onto the data. We review your data periodically to ensure it is still needed to fulfill the purpose for which it was collected or any other legal requirements. If a video streaming service cancels your service and deletes your ability to connect to their service (for example, for non-payment, piracy, misuse or other matter) Toggle’s systems are designed to automatically delete your Account Information (see our Terms of Service), subject to certain exceptions. For example, we will maintain certain Account Information if: (a) you’ve established a connection with another Subscription provider through Toggle that is still active; (b) Toggle needs your data to continue providing you with a Toggle service you requested; (c) Toggle is required by law to keep your data; (d) Toggle needs your data to help prevent fraud or protect privacy, provide support, or investigate misuse and misconduct; or (e) we request - and you specifically agree - to allow us to retain your data longer.

PROTECTION OF DATA.

Toggle’s security policies and practices are designed to protect the confidentiality and integrity of your private and sensitive information (such as personally identifying information (PII), billing information, and security credentials for third-party services), as well as any other data we collect about you. Toggle implements controls designed to limit access to this data to our personnel who have a business reason to know it and prohibits its personnel from unlawfully disclosing this data.

When submitting a subscription or restart service request, you may provide Toggle with Billing Information which we will furnish to the relevant Subscription provider on your behalf. Toggle uses industry-standard security practices, including encryption, to keep your Billing Information safe. We will only hold your Billing Information for the time necessary to fulfill a particular subscription or restart service request, after which it will be permanently deleted. 

For your convenience, the Toggle App will allow you to store certain Billing Information, such as your account name and billing address. Toggle does not have access to this stored information, which is maintained in a secure storage mechanism provided by your device’s operating system.

YOUR DATA PROTECTION RIGHTS. 

Regardless of where you live, we will honor the following rights related to your personal data, subject to some limitations and exceptions provided by law, and you will not be discriminated against for exercising them:

To exercise any rights you have, you can submit a request by contacting Toggle directly at: info@hellotoggle.com. You may be required to provide additional information necessary to confirm your identity before we can respond to your request.