Privacy Policy

1.

Introduction.

La Bocina Latina Ltd. recognizes that its users value their privacy and we take your privacy seriously. This privacy policy (“Privacy Policy”), as hosted at www.labocinalatina.tv/privacypolicy, explains our privacy practices, including what types of information we collect from you and how we may use it, our rights to share and disclose such information to third parties and how you can review and modify information that you provide to us and your preferences regarding our use and disclosure of such information. Please additionally review our Terms of Use (“Terms of Use”), as hosted at www.labocinalatina.tv/termsofservice, which governs your use of the La Bocina Latina Service (as defined below). Any capitalized terms that are not defined in this Privacy Policy shall have the meaning given in the Terms of Use.

This Privacy Policy applies to the information: (i) collected by La Bocina Ltd, and any of their respective affiliates (collectively, “La Bocina Latina”, “we”, “our” or “us”) or third parties acting with our authorization, or (ii) otherwise provided to us by third parties about you, in each instance, in connection with your use of the La Bocina Latina-branded television application (also commonly referred to a “connected television app”, “CTV app” or “living room app”) made available via certain third party television connected, digital streaming devices and television subscription services and/or the La Bocina Latina owned and controlled websites (collectively, the “La Bocina Latina Service”).

This Privacy Policy applies regardless of whether you are accessing the La Bocina Latina Service as an end user, television service subscriber or otherwise.

We will either rely on our legitimate interest or our need to perform under a contract to collect, store, use and process your information or, if required by applicable law, you will be asked to consent to our processing of your information in accordance with the terms and conditions of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please see information on your privacy rights below or stop using the La Bocina Latina Service.

This document is the sole statement of the La Bocina Latina Service’s Privacy Policy and no summary, restatement or other version thereof, or other privacy statement or policy, in any form, including, without limitation, machine-generated, is valid.

This Privacy Policy was last modified on the date indicated above and is effective immediately.

Copyright © 2022 La Bocina Latina Ltd.

2.

Information That We Collect.

The information we may process depends upon your interaction with us.

When you use the La Bocina Latina Service, we collect information that may identify or be linked to your television, set-top box, computer, mobile device or other internet-connected device (each, a “Device”). We generally cannot personally identify you from this Device information, but we and our third-party service providers may combine this data with other information and attempt to identify you in order to serve you more relevant advertisements (as further described below). Information may be collected as described below and through the use of cookies, web beacons, pixels, and other similar technologies by us or by other companies on our behalf. This information we may process includes:
 

• Online Identifiers. The La Bocina Latina Service includes features that automatically pass certain information about some of the unique identifiers assigned to your Device, including the Internet Protocol (IP) address, unique device identifier, or advertising identifier (collectively, “Online Identifiers”), to us and/or our third-party service providers.
   
• Activity Information. To improve functionality and user experience, we also collect information regarding your interactions with the La Bocina Latina Service, including advertisements displayed on the La Bocina Latina Service.
   
• Geolocation Information. Through your IP address, we can determine your general geolocation or region, which we use to support the delivery of content in your language and provide localized advertising.
   
• Inferences or Audience Segmentation. This includes certain information that relates to or may be used to create and remember individual profiles, preferences, characteristics, and behaviors.
   
• Legal Names and/or Email Addresses.
   
• Payment Method Information.

In addition, if you contact us with a customer service, copyright-related, or privacy-related request, we may use the personal information that you provide us (e.g., email address or phone number) to process and respond to your request. If you contact us through our website for sales-related purposes and/or previously provided us with registration information, we may collect, store, and/or use such personal information you provide us (e.g. name, email address and/or other information provided to us) in those instances to communicate with you for marketing and promotional purposes, including direct marketing.

3.

How We Use the Information That We Collect.

We may process the personal information we collect for the below purposes and any other purposes disclosed at the time that you provide us with data:

To fulfill our contractual obligations under an existing agreement with you, including:
 

• To communicate with you about the La Bocina Latina Service and La Bocina Latina; and
• To deliver content on the La Bocina Latina Service.

To meet and/or fulfill our legitimate interests, including:
 

• To manage our business needs, such as monitoring, analyzing, modifying and improving the La Bocina Latina Service’s functionality and performance;
• To prevent fraud and abuse on and unauthorized access to the La Bocina Latina Service;
• To provide localized content on the La Bocina Latina Service based on the country in which you are located (as determined based on your Online Identifiers);
• To provide localized advertising based on your general geographic location (as determined based on your Online Identifiers);
• To provide targeted advertising to you on the La Bocina Latina Service;
• To respond to your questions or other requests;
• To conduct research and analytics for marketing/promotional purposes and to provide anonymous and aggregated reporting (i.e., reporting that does not identify you and cannot be combined with other information to identify you) for internal use and use by external clients, business partners and other third parties; and
• To accumulate and report aggregated, de-identified, statistical information in connection with the La Bocina Latina Service and user activity.

To comply with our regulatory and legal obligations or to enforce our legal rights, including:
 

• To meet reporting requirements (e.g., filing tax forms);
• To retain documents and information related to a legal action;
• To enforce the Terms of Use; and
• To report data breaches or unauthorized access to the La Bocina Latina Service.

With your consent. If you have allowed us to process your personal data based on consent, you can withdraw your consent to such uses of your personal data that rely on consent as a legal basis to processing at any time by following the steps in this Privacy Policy.

4.

Sharing and Disclosure of the Information That We Collect.

We will not share your personal data or information with others except in the following circumstances:
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• Our Group Entities: We may disclose your personal data to other group entities that are affiliates and/or subsidiaries, owners or parents of La Bocina Latina in accordance with our internal policies or administrative or business practices.
   
• Third Party Service Providers: We may share your information with other carefully selected third party operators, advertising networks, data exchanges, traffic measurement service providers and other third parties for the purpose of (1) assisting with facilitating transactions on or through the La Bocina Latina Service, (2) supporting the delivery of content via the La Bocina Latina Service, (3) providing information technology and customer service assistance, (4) providing, delivering, offering, supporting, administering, maintaining and enabling the La Bocina Latina Service (including providing a full range of content, activities, services, features and functions offered on or in connection with the La Bocina Latina Service), (5) providing, and measuring and tracking, the display of and interaction with advertisements served within the La Bocina Latina Service. In certain cases, these service providers and other third parties may use (or facilitate the use of) your Online Identifiers and/or other information provided by us or collected by such third parties in combination with information third parties have independently collected about you, for purposes of serving you advertisements on the La Bocina Latina Service and/or third-party websites, applications and/or services that may be of interest to you. La Bocina Latina does not receive or have access to any personal information that those third parties have independently collected about you. We request that service providers maintain commercially reasonable standards of security and confidentiality and must agree to keep such information secure and confidential in line with this Privacy Policy. Please note that we are not responsible for the actions of service providers, third party distributors or platform or service operators (including those on which the La Bocina Latina Service is made available) or others. The third party distributors of the La Bocina Latina Service and the third-party platform or service operators on which the La Bocina Latina Service is made available may independently process your information. We are not responsible for any additional information you provide to any third parties. Instead, you should review those third parties’ privacy policies and practices to understand your rights.
   
• Corporate Transactions or Events: If La Bocina Latina sells all or part of its business or makes a sale or transfer of all or a material part of its assets or stock or is otherwise involved in a merger, joint venture, transfer, corporate reorganization or other disposition of its business, La Bocina Latina may transfer your information to the party or parties involved in the transaction as part of that transaction, and such party or parties may use the information for the purposes set forth in, and in accordance with the terms of, this Privacy Policy.
   
• Pursuant to Law, Rule or Regulation: We may share or disclose your information with other parties as we deem necessary or appropriate under applicable law, rule or regulation. Examples of these purposes include: to respond to requests from public, governmental and regulatory authorities, to comply with court orders, to obtain legal remedies or limit our damages, to enforce this Privacy Policy or the Terms of Use, and to protect the rights, safety and/or property of you, our employees or others.
   
• With Your Consent: If we do not process your personal data in accordance with our legitimate interest or based on a contractual obligation we have with you, we may share or disclose your personal data if you provide us with your affirmative consent.

5.

User Choice and Access Regarding Personal Data.

A. Privacy Requests. 

You may contact us about privacy preferences and learn more about your choices with respect to advertising on the La Bocina Latina Service by sending an email to us at Sam@BenjaminEsq.com detailing your privacy request. If you ask La Bocina Latina to stop using your personal data, we will honor that request, provided that we may retain a record of such information as necessary to comply with applicable law and we may continue to use your contact information to respond to your requests. If you continue to use the La Bocina Latina Service, we may continue to use your Online Identifiers to determine the country in which you are accessing the La Bocina Latina Service in order for content to be displayed within the La Bocina Latina Service. You always have the right to access, review and correct the personal data you have provided.
 

B. Your EU Privacy Rights.

If you are an EU citizen or reside in the EU, you may have certain rights with respect to the personal data you provided to us. To the extent permitted by applicable data protection laws, you may:
 

• Access or modify your personal data;
• Object, on grounds relating to your particular situation, at any time to the processing of your personal data if the legal ground we are relying on is our legitimate interest or in the public interest;
• Request that your personal data be erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn consent to, or object to, the processing of such personal data and we meet no other legitimate basis for such processing or it has been unlawfully processed;
• Restrict the processing of your personal data if you contest its accuracy or the lawfulness of our processing, we no longer need it but you need it for a legal claim or you have objected to its processing and await verification of our legitimate grounds for processing it;
• Under certain circumstances, have your personal data transferred to another company; or
• Withdraw any consents that you have previously provided to allow us to process your personal data.

If you wish to exercise any of these rights, please contact us at Sam@BenjaminEsq.com. Please note that some requests may require you to verify your identity.

C. Your California Privacy Rights. 

This section provides information regarding the personal information we may collect from California residents and the rights that you may have under applicable law, including The California Consumer Privacy Act (“CCPA”), if you are a California resident.
 

• What Categories of Personal Information Have We Collected From/About California Residents in the Past Year? Section 2 contains the categories of personal information we may have collected from you in the 12 month period before this Privacy Policy was last updated. We may have obtained such information from you directly (e.g., usage information when you use the La Bocina Latina Service) and/or from our affiliates, information suppliers, service providers, vendors, advertising partners and promotional and strategic partners.
   
• What Categories of Personal Information About California Residents Have We Disclosed to a Third Party in the Past Year?  Section 2 contains the categories of personal information we may have disclosed to a third party in the 12-month period before this Privacy Policy was last updated.
   
• What Categories of Third Parties Have We Disclosed California Residents’ Personal Information to in the Past Year? In the 12 month period before this Privacy Policy was last updated, we may have disclosed each of the categories of personal information described above to the categories of third parties described in Section 4, including (a) service providers (i.e., entities that process information on our behalf for business purposes as detailed in Section 3, helping us to provide products or services to you), (b) advertising partners (i.e., entities that help us serve and deliver advertisements via our products or services, and connect us with others who want to place advertisements on the La Bocina Latina Service), and (c) analytics partners (i.e., entities that help us collect data regarding how the La Bocina Latina Service (including advertisements served thereon) is used).
   
• What Categories of California Residents’ Personal Information Have we “Sold” in the Past Year? La Bocina Latina does not sell personal information of its users as the term “sell” is traditionally understood, but the CCPA defines “sale” very broadly. Under the CCPA, a “sale” includes the sharing of California residents’ personal information in exchange for anything of value. For example, sharing an advertising or device identifier to a third party may be considered a “sale” under the CCPA. In light of this broad definition, in the 12 month period before this Privacy Policy was last updated, we may have “sold” the categories of personal information described in Section 2.
   
• What Categories of Third Parties Have We “Sold” California Residents’ Personal Information to in the Past Year? In the 12 month period before this Privacy Policy was last updated, we may have “sold” California residents’ personal information to the categories of third parties described in Section 4, including (a) advertising partners (i.e., entities that help us serve and deliver advertisements via our products or services, and connect us with others who want to place advertisements on the La Bocina Latina Service), and (b) analytics partners (i.e., entities that help us collect data regarding how the La Bocina Latina Service (including advertisements served thereon) is used).

To the extent provided by applicable data protection laws, if you are a California resident, you may have the following rights:
 

• The right to request that we disclose to you the following:
   
• The categories of personal information we have collected about you;
• The specific pieces of personal information we have collected about you;
• The categories of sources from which such personal information has been collected;
• The business or commercial purpose for collecting or selling such personal information;
• The categories of third parties with whom we have shared such personal information;
• The categories of such personal information that we have sold and the categories of third parties to whom such personal information was sold; and
• The categories of such personal information that we have disclosed for a business purpose.
   
• The right to request that we delete your personal information, under certain circumstances.
   
• The right to opt out of the “sale” of your personal information. To the extent La Bocina Latina “sells” your personal information (as the term “sell” is defined under the CCPA), you have the right to opt-out of that “sale” on a prospective basis at any time. If you choose to opt-out of the “sale” of your personal information, then we will no longer “sell” your personal information to third parties. Note that it may take us a few days to process your opt-out, but we will do so within the time period required by law. Also note that we may continue to share or “sell” your information in an aggregated or de-identified manner (meaning it is no longer personal information). We may also continue to share your personal information with our services providers, solely for the purposes of providing us services. Please note that opting out of the “sale” of your personal information does not mean that you will stop seeing ads on the La Bocina Latina Service.
   
• The right to not be discriminated against by us because you have exercised any of the foregoing rights under applicable law.
   

​If you wish to exercise any of these rights, please contact us at Sam@BenjaminEsq.com. You may also opt-out of the “sale” of your data via the opt-out mechanism made available to you via the La Bocina Latina Service (as located in the “Settings” page of the La Bocina Latina Service). Please note some requests may require you to verify your identity. You may designate someone to submit requests and act on your behalf (an “Authorized Agent”). To do so, you must provide us with written permission to allow your Authorized Agent to act on your behalf.
 

We share the Device information we collect with third party service providers. We cannot reasonably identify you based on this Device information; however, these third party service providers may combine the information with their own data to make inferences about what ads may be relevant to you. For example, we share your IP address so that advertisers can determine which region you live in and provide you ads in the language of that region. We receive revenue for ads served on the La Bocina Latina Service. Sometimes we get paid only for the placement of those ads and sometimes we get paid based on how they perform, for example, how many times an advertisement was viewed. We generally use aggregate, statistical data to find out more about how well ad campaigns have performed, and we may provide the results of these studies with third party service providers. To find out more information about ads and your information contact us at Sam@BenjaminEsq.com.
 

Some web browsers have a setting that requests that a web application disable its tracking of an individual user (also known as a “Do Not Track” request). Unfortunately, due to technological limitations, our La Bocina Latina Service does not recognize such “Do Not Track” requests.
 

In the event that La Bocina Latina operates a content management service and permits you access to such content management service, we may (i) collect Online Identifiers, Activity Information, Geolocation Information, and any other personal information you provide to us in connection with your use of such content management service, (ii) use that information in some of the ways ascribed by Section 3, and (iii) share that information with our group entities or our third party service providers, in all instances, subject to the limitations of this Privacy Policy. In connection with the foregoing, you may also exercise your full rights under applicable laws in the manner specified in this Section 5.
 

D. Opting Out of Cookies and Other Tracking Technologies. Please see Section 9 below to learn more about how you may opt out of the use of certain cookies and other tracking technologies.

6.

Data Collection From Children.

La Bocina Latina recognizes the need to adequately protect the privacy of all of its users, especially children. The La Bocina Latina Service is not intended for or directed at children under the age of 16. We do not knowingly collect personal data from children under the age of 16. If we obtain actual knowledge that we have collected personal data from someone under the age of 16, we will promptly delete it, unless we are legally obligated to retain such data. If you believe that we have mistakenly or unintentionally collected information from someone under the age of 16, please contact us at Sam@BenjaminEsq.com. For users in the United States, please also visit https://www.consumer.ftc.gov for information from the Federal Trade Commission about protecting children's privacy online.

7.

Security.

While no data transmission over the Internet is 100% secure from intrusion, we maintain commercially reasonable physical, electronic and procedural safeguards to protect the personal data that we collect, use and/or store, which are consistent with applicable privacy and security laws. These policies and measures are designed to prevent against loss, misuse, unauthorized access, modification and disclosure and unlawful destruction of your personal data.

We also limit access to the La Bocina Latina Service to our own employees, contractors, operators, service providers and those individuals who are authorized for the proper handling of and have a business need to access such information. We request that our third-party contractors and service providers follow similar standards of security and confidentiality as those followed by La Bocina Latina. However, it is possible that third parties may unlawfully intercept or access transmissions or private communications despite our efforts to prevent same and we therefore make no guarantees regarding the security of user information. While we are dedicated to securing your personal data and our systems and the La Bocina Latina Service, you are responsible for securing and maintaining the privacy of your credentials (e.g., user name and password) and verifying that personal data we maintain about you is accurate and current.

8.

Integration of Third Party Platforms and Services.

The La Bocina Latina Service may be linked to, rely on and/or be integrated with Third Party Platforms and other websites, applications, interfaces, services and/or platforms operated by other companies. The La Bocina Latina Service will also feature advertisements from third parties. La Bocina Latina is not responsible for the privacy practices of such websites, applications, interfaces, services and platforms operated by third parties that are linked to, rely on and/or integrated with the La Bocina Latina Service or for the privacy practices of third party advertising companies. Additionally, we are not responsible for protecting any personal data shared with a third party (e.g. OTT software platforms) through your use of the La Bocina Latina Service.

9.

Cookies and Other Tracking Technologies.

This section provides you with information about how La Bocina Latina uses cookies or similar technologies on the La Bocina Latina Services, and information about how third parties may use such technologies in connection with the operation of the La Bocina Latina Services. We may use cookies and similar technologies to enable us to understand how you interact with our products, to improve your experience, and to allow you to use certain features. Cookies are small text files that are placed in your browser or on your device. Cookies can either be persistent (i.e., they remain on your device until you delete them) or temporary (i.e., they last only until you close your browser or application). The La Bocina Latina Service may also use web beacons, pixels and other “tracking technologies”, which are small strings of code placed on a web page or in an email or advertisement. These technologies allow your browser or device to recognize and store certain types of information (such as cookies previously set, the time and date that you viewed the page with the beacon and a description of that page).

​

The categories of cookies that may be used on the La Bocina Latina Services are as follows:

​

• Functionality cookies: These cookies allow the La Bocina Latina Service to remember the choices you make and your account preferences and to provide enhanced, more personal features. These cookies are set by us or by our third party service providers.
   
• Analytics / Performance cookies: These cookies allow us to measure and analyze how La Bocina Latina end users use the La Bocina Latina Services, so that we may improve the La Bocina Latina Service’s functionality and enhance your experience.
   
• User preference cookies: These cookies will remember your preferences (like your language or location), so we can make your experience as seamless as possible, and more personal to you.
   
• Targeting or advertising cookies: These cookies are set by us and our advertising partners to record your visit to the La Bocina Latina Service, the sections of the La Bocina Latina Service or pages you have visited and the advertisements you have viewed. These are used to deliver ads relevant to you, to limit the number of times that you see an ad and to help us measure the effectiveness of our marketing campaigns.

​

You may opt-out or delete cookies as follows:​

​

• Opt-In/Opt-Out on the La Bocina Latina Connected Television App: You may opt-in or opt-out of the use of your data to personalize your ad experience on the La Bocina Latina Service delivered through the La Bocina Latina-branded connected television application by making the applicable selection in the “Settings” page of such application.
   
• Opt-Out on Your Browser: Most browsers allow you to manage cookies saved on your device. Please note that denying all or certain cookies may result in a less personalized experience on the La Bocina Latina Service.
   
• Opt-Out on a Mobile or Connected Television Device: Depending on your device and operating system, you may be able to reset your device's advertising identifier to limit this data collection or prevent the collection of usage data across unaffiliated applications for interest-based advertising purposes by accessing the privacy settings on your device. Each operating system and/or device may provide its own instructions on how to manage these settings – please see the privacy settings for your device for more information.
   
• Google Analytics: Some aspects of the La Bocina Latina Services may use Google Analytics to analyze traffic. You can find out more information about Google Analytics cookies by visiting https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage. To opt out of Google Analytics relating to your use of the La Bocina Latina Services, you can download and install the Browser Plugin available by visiting the following location provided: https://tools.google.com/dlpage/gaoptout.
   
• Nielsen: We and/or our advertising partners may use Nielsen’s measurement services, which contribute to market research. Nielsen’s pixel may be in some of the ads on the La Bocina Latina Service to track whether or not you viewed the ad and gather related information. Nielsen uses the data it collects to create ratings reports for advertisers and publishers. To learn more about the data Nielsen collects via such pixels and your choices, please see the Nielsen Digital Measurement Privacy Policy: https://www.nielsen.com/us/en/legal/privacy-statement/digital-measurement/.
   
• DAA / NAI Opt-Out: You may also be able to opt-out of the use of your data by certain third parties to serve interest-based advertising on certain websites or devices, by using the opt-out tools made available on the Digital Advertising Alliance’s DAA’s Consumer Choice Page: https://optout.aboutads.info and the Network Advertising Initiative’s ("NAI") website: https://optout.networkadvertising.org/.

10.

Retention of Your Personal Data.

We access, retain, store and use personal data for the least amount of time necessary pursuant to our relationship with you (e.g., to provide you with or access to our products and services), in accordance with our data retention policies and applicable law. We do not collect more personal data than is necessary to fulfill our obligations to you or at law or for purposes stated in this Privacy Policy.

11.

Privacy Policy Changes.

From time to time, we may modify this Privacy Policy to reflect industry initiatives, third party requirements or changes in the law, technology, our information collection and use practices or the features and functionality of the La Bocina Latina Service, and such modifications shall be effective upon posting. When we change this Privacy Policy in a material way, we will, subject to technological restrictions, post a notice within the La Bocina Latina Service along with the updated Privacy Policy. Your continued use of the La Bocina Latina Service after we post a revised Privacy Policy (and, where appropriate, notify you of same) signifies your acceptance of the revised Privacy Policy. It is therefore important that you review this Privacy Policy regularly to ensure you are updated as to any changes. We may continue to process your information based on our legitimate interests or in order to fulfill our obligations under a contract and/or may also seek your affirmative consent to the terms of the updated Privacy Policy. For example, we may ask for your consent before implementing new uses of the personal data that we’ve already collected from you based on such consent, if such new use was not addressed by the privacy policy under which such information was collected or if our legal basis for processing such information changes.

12.

Accuracy of Information Provided.

It is your responsibility to give us current, complete, truthful and accurate information and to keep such information up to date. We cannot and will not be responsible for any problems or liability that may arise if you do not give us accurate, truthful or complete information or you fail to update such information. We will reject and delete any entry that we believe in good faith to be false, fraudulent or inconsistent with this Privacy Policy.

13.

Contact Us.

If you have any questions about our privacy practices, how we handle your personal data or any of the terms or conditions of this Privacy Policy, please feel free to contact us at:

Email: Sam@BenjaminEsq.com

OR

Mail:

La Bocina Latina Ltd.

Attn: Privacy Matters

c/o The Law Office of Samuel A. Benjamin, Esq. LLC

20 Pine Street, Suite 2201

New York, NY 10005

Although we urge you to contact us to find a solution for every concern you may have, you always have the right to lodge a complaint with your competent data protection authority.

14.

Data Storage, Transfer, Processing.

Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and some of our subsidiaries and affiliates, servers, vendors and service providers may not be located in your jurisdiction and may be located outside of the European Economic Area and Switzerland. If you are an EU citizen or resident in the EU, we will transfer your personal data to the United States in accordance with EU data protection law requirements by using model contractual clauses that have been approved by the European Commission or other appropriate means.

Please note that such transfers may also be necessary in order to perform our obligations under a contract with you, to fulfill a request made by you, to meet a legal or regulatory obligation and/or through obtaining your express consent. If you make transactions with parties outside the EEA or Switzerland or connect the La Bocina Latina Service with platforms outside the EEA or Switzerland, we are required to transfer your personal data with those parties in order to provide the La Bocina Latina Service to you. If you wish to gain more information about such transfers, please contact us at Sam@BenjaminEsq.com.