SKYDANCE PRIVACY POLICY

Effective (last updated) Date: July 1, 2024

We, Skydance Productions, LLC and its parent, subsidiaries, and other affiliates under the control of our corporate parent (collectively “Skydance”, “we,” “us”, “our”) provide the following notice regarding our data practices:

Section A of this Privacy Policy describes our collection, use, and disclosure of Consumers’ (other than our Personnel (defined below)) Personal Information or Personal Data (and also referred to herein as “PD”), as those terms are defined under State Privacy Laws (defined below) (the “Enterprise Privacy Notice”). The same practices apply to residents of other U.S. states, but not our Personnel.  Personnel may contact their local human resources (“HR”), or contact us as set forth in Section E, for the applicable HR privacy notice(s).

Section B of this Privacy Policy applies to all users of, and visitors to, our online services (including websites, and emails) that post a link to this notice (“Online Services”) (the “Online Services Privacy Notice”), which includes supplements for persons outside of the U.S. Do not use our Online Services if you do not accept our data practices as described in the Online Services Privacy Notice and agree to our Terms of Use (which also provides supplements for persons outside of the U.S.). This Online Services Privacy Notice does not apply to our interactive games distributed by third-party platforms. See the privacy notices made available in-game, with respect to our and the distributors’ in-game data practices.

Section C of this Privacy Policy describes U.S. Consumers’ (including our California Personnel’s). privacy rights and how to exercise them (“State Privacy Rights”). Persons outside of the U.S. should consult the Online Services Privacy Notice.

Section D includes information regarding changes to these policies and Section E lists our contact information.

Collectively, Sections A-E are our “Privacy Policy.”  Additional notices may be made at the point of collection, in which case those will supplement this Privacy Policy and govern that collection in the event of a conflict with this main Privacy Policy. Capitalized terms used but not defined herein will have the meanings given to them in the applicable laws to which we are subject to, which may differ from one applicable jurisdiction to another. 

To see and print our full Privacy Policy, click here. You can request disability access assistance by contacting us as set forth in Section E.

A.             Enterprise Privacy Notice

This Enterprise Privacy Notice is designed to provide Consumers, as defined under State Privacy Laws, other than our Personnel, with notice of our PD practices over the prior 12 months (from the Effective Date), including through Skydance online and offline business activities (the “Business Activities”), and to meet the notice requirements of the California Consumer Privacy Act, including as amended by the California Privacy Rights Act (together, the “CCPA”), the Texas Data Privacy and Security Act, Chapter 603A of the Nevada Revised Statutes, Nebraska Data Privacy Act (effective January 1, 2025), substantially similar state consumer privacy laws that may hereafter be applicable to us, and all laws implementing, supplementing, or amending the foregoing, including regulations promulgated thereunder (each a “State Privacy Law,” and collectively, “State Privacy Laws”). In California, the term “Consumer” is not limited to data subjects acting as individuals in a household goods and services context and includes individuals acting in a business-to-business context.

If Skydance’s processing materially changes between updates to this Enterprise Privacy Notice, Skydance will provide a supplemental notice when or before the changes apply. Otherwise, this Enterprise Privacy Notice serves as our notice at collection (i.e., pre-collection notice).

1.     Notice of Collection and Privacy Practices

This Enterprise Privacy Notice does not apply to data that is collected in a HR context. If you are a current or former employee, independent contractor, intern, job applicant, or if we have collected data from you or about you otherwise in the HR context (e.g., emergency contact or beneficiary information) (“Personnel”), and are currently residing in California, or another jurisdiction that requires HR privacy notices, you may request notice of our HR privacy practices by contacting your local HR representative, or contact us as set forth in Section E.

Notably, this Enterprise Privacy Notice does not apply to data that is not treated as PD, or to the extent the data is subject to an exemption, under applicable State Privacy Laws.

Generally, the processing purposes for which we collect, retain, use, disclose and otherwise process your PD in connection with our Business Activities, including to provide you with or promote our products or services and as otherwise related to the operation of our business, which includes both the Business Purposes set forth below, and Commercial Purposes, specifically  Sharing with Third-Party Digital Businesses (defined below), as more fully explained in Section A.2, below.  Further, as more fully explained in Section A.3., below, this may include disclosing or otherwise making available PD to our vendors that perform services for us in their role as “Service Providers” or “Processors,” as the terms are defined under State Privacy Laws (collectively, “Processors”), as well as to third parties in the context that is subject to your right to opt-out (as more fully explained below).  

The categories of sources from which we collect your PD include:  you, your employer (in the business-to-business context), our Processors, other of our vendors and third parties, including with third-party digital businesses that may associate cookies and other tracking technologies that collect PD about you on our Online Services, or otherwise collect and process PD that we make available about you, including digital activity information and identifiers (“Third-Party Digital Businesses”).

To learn about your State Privacy Rights and how to exercise them (including a notice of how to exercise Do Not Sell/Share/Target rights), see Section C.

2.     PD Processing to Which This Enterprise Privacy Notice Applies

The Business Purposes and Commercial Purposes for processing described below may apply to all categories of your PD, but we detail our disclosures (including Selling and Sharing) by PD type in Section A.3 for additional transparency.

Business Purposes:

Generally, we collect, retain, use, and disclose your PD to provide you our products and services, or information about them, and as otherwise related to our Business Activities, including for one or more of the following “Business Purposes”:

• Providing Products or Services: Operating or distributing products and services, providing customer service, and verifying customer information.

• Managing Interactions and Transactions: Performing services on behalf of the business, including maintaining or servicing B-to-B accounts, verifying customer information, processing B-to-B payments, providing analytics services, and customizing your experience, offers and content.

• Security and Debugging: Helping to ensure the security and integrity of our systems and data to the extent the use of the Consumer’s PD is reasonably necessary and proportionate for these purposes. Debugging to identify and repair errors that impair existing functionality.

• Advertising and Marketing: Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with State Privacy Laws. Short-term transient use including, but not limited to, non-personalized advertising shown as part of the Consumer’s current interaction with the Service. Providing advertising and marketing services, except for cross-context behavioral advertising (i.e., Targeted Advertising, which is a separate Commercial Purpose described below for which there is a right to opt-out under State Privacy Laws). Customizing your experience, offers, and content.

• Quality Assurance: Undertaking activities to verify or maintain the quality or safety of our products and services, and to improve, upgrade, or enhance our products or services.

• Research and Development: Undertaking internal research for technological development and demonstration.

• Operation of our Business: For our additional legitimate Business Purposes that are compatible with the purposes of collecting your PD and that are not prohibited by law in the context that is not a “Sale,” “Share” or “Targeted Advertising” under State Privacy Laws, such as disclosing it to a person that processes PD on our behalf, such as our Processors, to the Consumer, or to other parties at the Consumer’s direction or through the Consumer’s action, including:
  • for additional purposes explained at the time of collection (such as in the applicable privacy policy or notice); as required or permitted by applicable law;to the government or private parties, including litigants, to comply with law or legal process or to protect or enforce legal rights or obligations or prevent harm;to comply with legal obligations, as part of our general business operations, and for other business administration purposes and in response to legal obligations or process;to investigate, prevent or take action if someone may be using info for illegal activities, fraud, or in ways that may threaten someone’s safety or violate of our terms;
  • in connection with our Online Services as more fully detailed in Section B, below;

(“Additional Business Purposes”). Subject to restrictions and obligations under State Privacy Laws, our Processors may also use your PD for Business Purposes and other purposes permitted by law and may engage their own vendors to enable them to perform services for us.

Commercial Purposes:

We may also use and disclose your PD in connection with digital advertising, which may be considered a “Sale” or “Share” or “Targeted Advertising” under applicable State Privacy Laws, when Third-Party Digital Businesses collect your PD via third-party cookies or we otherwise make it available to them. Under State Privacy Laws, some of these processing disclosure activities do not qualify as Business Purposes disclosures and are therefore subject to a right to opt-out.  The specific purpose for this Selling or Sharing is to help us and others provide you with more relevant content and marketing messages (e.g., Targeted Advertising) and related activities, and when we and third parties process your PD for certain advertising purposes (e.g., creating profiles and inferences, measurement, some types of analytics, conversion tracking, audience extension, etc.). The parties we disclose it to are detailed, by type of PD, in Section A.3 below. For more information on the meaning of Selling, Sharing, and Targeted Advertising and how to adjust your preferences with respect to such processing, please refer to the Do Not Sell/Share/Target Opt-out subsection of the State Privacy Rights Section.

3.     Collection, Disclosure and Retention of PD – By Category of PD

The table below describes the categories of PD we collect and examples of data types that fit within each category and corresponding categories of recipients of PD to which we disclose.

Category of PD	Examples of PD Collected and Retained	Categories of Recipients
Identifiers	First and last name, postal address, unique personal or online identifier, IP address, and email address.	Disclosures for Business Purposes: * Operational Service Providers (e.g., cloud storage vendors, IT vendors, email/messaging, customer support providers, and data analytics); * Marketing Service Providers; Other members of our corporate group, and/or other parties in connection with a Corporate Transaction (“Corporate Recipients”); * Governmental entities (e.g., making requests pursuant to legal or regulatory process)(“Government”); and/or * Other parties (e.g., professional advisors (accountants and lawyers),  litigants and where you have directed or caused the disclosure) within the limits of Additional Business Purposes (“Other Business Recipients”). Sale/Share: Third-Party Digital Businesses.
Personal Records	Name, signature, address, telephone number, and B-to-B financial information. Some PD included in this category may overlap with other categories.	Disclosures for Business Purposes: *Operational Service Providers; *Marketing Service Providers; *Corporate Recipients; *Government; and/or *Other Business Recipients.   Sale/Share: N/A
Personal Characteristics or Traits	Our online Services may collect approximate age for restricting access.	Disclosures for Business Purposes: *Operational Service Providers; *Marketing Service Providers; *Corporate Recipients; and/or *Other Business Recipients.   Sale/Share: N/A
Commercial Information	Records of products or services considered.	Disclosures for Business Purposes: *Operational Service Providers; *Marketing Service Providers; *Corporate Recipients; and/or *Other Business Recipients.   Sale/Share: Third-Party Digital Businesses
Internet or Other Electronic Network Activity Information	Information regarding the consumer’s interaction with online services  or advertisements.	Disclosures for Business Purposes: *Operational Service Providers; *Marketing Service Providers; *Corporate Recipients; and/or *Other Business Recipients.   Sale/Share: Third-Party Digital Businesses
Geolocation Data	If you interact with us online, we may gain access to the approximate  location of the device you are using (e.g., city).	Disclosures for Business Purposes: *Operational Service Providers; *Marketing Service Providers; *Corporate Recipients; and/or *Other Business Recipients.   Sale/Share: Third-Party Digital Businesses
Audio, Electronic, Visual, or Sensory Information	Such as CCTV recordings in our offices and customer service call recordings.	Disclosures for Business Purposes: *Operational Service Providers; *Corporate Recipients; and/or *Other Business Recipients.   Sale/Share: N/A
Inferences from PD Collected	Inferences drawn from PD for marketing and to provide more relevant content.	Disclosures for Business Purposes: *Operational Service Providers; *Marketing Service Providers; *Corporate Recipients; and/or *Other Business Recipients.   Sale/Share: Third-Party Digital Businesses

There may be additional information we collect that meets the definition of PD under applicable State Privacy Laws but is not reflected by a category above, in which case we will treat it as PD as required, but will not include it when we describe our practices by PD category. As permitted by applicable law, we do not treat deidentified data or aggregate Consumer data as PD and we reserve the right to convert, or permit others to convert, your PD into deidentified data or aggregate consumer data, and may elect not to treat publicly available information as PD. We will not attempt to reidentify data that we maintain as deidentified.

Because there are numerous types of PD in each category, and various uses for each PD type, actual retention periods vary by purpose not by data type and, accordingly, the retention periods cannot be meaningfully provided by category of PD. We retain specific PD pieces based on how long we have a legitimate purpose for the retention, which includes the period of time we need to process the PD to meet the processing purposes, plus limited retention thereafter to maintain business and legal records and defend or bring potential legal claims.

B.              Online Services Privacy Notice

This Online Services Privacy Notice applies to all users of our Online Services. Section B.6 applies only to users from outside of the U.S. This Online Services Privacy Notice is a supplement to our other privacy policies and notices, and is part of our main Privacy Policy. In the event of a conflict between any other Skydance policy, statement, or notice and this Online Services Privacy Notice, this notice will prevail as to data collected by our Online Services, except where additional notices are posted at collection that are said to modify or supplement this notice.

This Online Services Privacy Notice applies to “Online Services PD,” which is PD that is collected through the Online Services. To the extent we combine your Online Services PD with data we receive outside of the Online Services, we will treat the combined data as Online Services PD and apply this Online Services Privacy Notice to such combined data, unless we have disclosed otherwise.  As permitted by applicable law, we do not treat Online Services PD that has been deidentified or aggregated as PD and we reserve the right to convert, permit others to convert, your Online Services PD into deidentified or aggregate consumer data. We will not attempt to reidentify data that we maintain as deidentified.

1.     Data We Collect

Skydance and the third parties we have retained to perform or provide certain services or functions to us (“Vendors”) collect Online Services PD in a number of ways:

a.     Data That You Provide

The Online Services are publicly available. We collect Online Services PD from you when you interact with, or submit your data through, the Online Services, such as when you fill out forms ; correspond with us by phone, e-mail or otherwise; subscribe to notifications (e.g., email alerts); search for content; interact with our social media functions on the Online Services; participate in promotions; and when you report a problem with our Online Services. The Online Services PD you give us may include, but is not limited to, your name, address, email address, phone number, the content  of your communication, and any other data you choose to provide to us. You are responsible for ensuring the accuracy of the data you submit to Skydance. Inaccurate data may affect your ability to use the Online Services, the data you receive when using the Online Services, and our ability to contact you. For example, your email address should be kept current.

b.     Other Data Collected About You

When you access or use the Online Service, Skydance, our Vendors, and/or third-party websites,  locations, platforms, code (e.g., plug-ins) or other services (each a “Third-Party Services”), may automatically collect the following data (note, however, that the privacy policy of that Vendor and/or Third-Party Service also apply to your interaction):

• Usage data, including the URL from which you linked to the Online Service, how you use and interact with the Online Service, what pages you visit, and which hyperlinks you click. We may collect usage data to analyze usage trends so that we may understand how individuals use the Online Service to help us improve the user experience, and to provide customer assistance and technical support.

• Technical data, including data regarding your Internet Protocol (“IP”) address, device type, device operating system, browser type you use to access the Services, the unique device identifier (“UDID”) or mobile equipment identifier (“MEID”) for your mobile device, and other data (“Device Identifiers”). We may use such Device Identifiers to associate data you have provided on different devices, or during separate interactions with us on the Online Services on the same device.

• Data about you from cookies and other similar tracking technologies (as more fully described below), which may be considered PD under applicable laws.

Skydance, and our Vendors and Third-Party Services, may use cookies and other tracking technologies to help us collect data about interactions with the Online Service, other online services, and/or our emails, including data about your browsing and information or service request behaviors. These methods enable Skydance to serve you better and more efficiently, to personalize your experience, to improve and/or promote the Online Services and other products and services, and for other functions and purposes. These methods may include:

• Cookies. A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Online Services and expire when you close your browser. Tracking and other persistent cookies remain longer and help in understanding how you use the Online Services, enhance your user experience, and perform other functions such as facilitating analytics and advertising and remembering you and your preferences when you return. Persistent cookies may remain on your hard drive for an extended time. The Online Services may associate some or all types of these cookies with your devices.  If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked, which may cause some Online Services features and functionalities to not work.

• Web Beacons/Tracking Pixels (“Pixels”). Pixels are small graphic images, also known as “Internet tags” or “clear gifs”, embedded in webpages and e-mail messages. Pixels may be used, without limitation, to count the number of visitors to the Online Services, to monitor how users navigate the Online Service, to determine if our emails are opened, and to count content views.

• Location-Identifying Technologies. Our Online Services may provide you the ability to enable location-identifying technologies, for example, to help identify your city-level location when visiting our Online Services, but we do not collect precise geolocation.

• Device Recognition Technologies. Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).

• Device and Activity Monitoring. Technologies that monitor, and may record, certain of your interactions with the Online Services, and/or collect and analyze information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes such as identification, security, fraud prevention, troubleshooting, tracking and/or improving the Online Services and customizing or optimizing your experience on the Online Services.

We are giving you detailed notice of the tracking technologies and your choices regarding them so that your consent is meaningfully informed.  For information on how to exercise preferences as to our features, functionality, and communications, see the Choices: Tracking and Communications Options section below.  For more information on Third-Party Services’ data collection and practices, and the choices they may offer you, please refer to the Third-Party Services section.

c.     Data We Receive From Other Than Via the Online Services

Skydance may receive Online Services PD about you from third parties, including your contacts and others who use the Online Services, when they submit data to us or otherwise interact with the Online Services. We may also collect Online Services PD and other PD about you from other sources, including from companies that can help us correct or supplement our records, improve the quality or personalization of our Online Services to you, and help prevent or detect fraud. To the extent we combine your Online Services PD with other data, we will treat it as Online Services PD and apply this Online Services Privacy Notice to such combined data, unless we have disclosed otherwise. 

2.     How We Use Your Online Services PD

Skydance may use data about you, including Online Services PD, for any purposes not inconsistent with Skydance’s statements under this Online Services Privacy Notice, or otherwise made by us in writing at the point of collection, to the extent permitted by applicable law including, without limitation, the following:

• To operate and improve our Online Services;
• To display content (e.g., reviews) you post or otherwise submit;
• To provide you with information, products and services you request, view, or engage with;
• To communicate with you when you send us a request or subscribe to our newsletter;
• To facilitate, manage, personalize and improve your online experience;
• To market our products and services, including by providing you with advertising based on your activity on the Online Services and on third-party websites and applications and to operate promotions;
• To send you notices;
• To operate, optimize, analyze the use of, improve and enhance the Online Services, including by using survey, research and analytics tools;
• For auditing, compliance and legal purposes, to protect the rights and property of Skydance, its partners, customers and other users of the Online Services and to investigate potential violations of and to enforce our Terms of Use;
• To detect, investigate and prevent activities that may violate our policies, pose safety issues or be fraudulent and illegal;
• To respond to requests from legal and regulatory enforcement authorities, as appropriate and to the extent required by law; and/or
• For all other purposes related to our business that are reasonably proportional to the forgoing purposes, or otherwise subject to your consent.

3.     How We Disclose Your Online Services PD

We may disclose your Online Services PD as described in Section A (Enterprise Privacy Notice) of our Privacy Policy, and for any purpose not inconsistent with our statements under this Online Services Privacy Notice, or statements otherwise made by us in writing at the point of collection, and not prohibited by applicable law. We disclose Online Services PD to Vendors. Other instances when we may disclose any Online Services PD to outside parties include:

• When we reasonably believe that such disclosure is permitted or required by law or pursuant to legal process or is necessary in connection with actual or threatened litigation or to protect Skydance or third parties.  We may disclose your Online Services PD to third parties in connection with a Corporate Transaction, such as to assignees as part of an acquisition, merger, asset sale, or other transaction where another party assumes control over all or part of our business.  
• In connection with  the purposes set forth in the How We Use Your Online Services PD section, above.

4.     Choices: Tracking and Communications Options

a.     Tracking Technologies Generally

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Please be aware that if you disable or remove these technologies, some parts of the Online Services may not work and that when you revisit the Online Services your ability to limit browser-based tracking technologies is subject to your browser settings and limitations.  Accordingly, you may want to consider the more limited opt-out choices noted in the next section.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, Skydance currently does not alter Skydance’s practices when Skydance receives a “Do Not Track” signal from a visitor’s browser. However, we do honor browser signals known as “Global Privacy Controls” and provide cookie preference tools on our Online Services as more fully explained in the Do Not Sell/Share/Target Opt-out subsection of the State Privacy Rights Section.

Some third parties, however, may offer you choices regarding their tracking technologies. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section. We do not represent that these third-party tools, programs or statements are complete or accurate.

You will need to set preferences on each browser that you use to access our Online Services and clearing cookies on your browser(s) may disable some preference settings.

b.     Analytics and Advertising Tracking Technologies

Skydance may engage and work with Vendors and other third parties to serve advertisements on the Online Services and/or on other online services. Some of these ads may be tailored to your interest based on your browsing of the Online Service and elsewhere on the Internet, which may include Cross-device Data, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on another online service after you have left the Service (i.e., “retargeting”).  Note that State Privacy Laws regulate some Interest-based Advertising practices that meet the definitions of “Sharing” for “Cross-context Behavioral Advertising” or processing for “Targeted Advertising.”  This Section B.4.b does not address the opt-outs of those activities under State Privacy Laws.  Consult Sections A and C for information on those opt-out programs.    

You may choose whether to receive some Interest-based Advertising by submitting opt-outs to some or all of the participants in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more, visit http://www.aboutads.info/choices/. Please be aware that, even if you opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected DAA members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your DAA browser-based opt-out may not, or may no longer, be effective. Skydance supports the ad industry’s Self-regulatory Principles for Online Behavioral Advertising and expects that ad networks Skydance directly engages to serve you Interest-based Advertising will do so as well, though Skydance cannot guaranty their compliance. Also note that the DAA program is national and is not the same as Do Not Sell/Share/Target Opt-out rights under State Privacy Laws.

We may also use Google Ad Services. To learn more about the data Google collects and how your data is used by it and to optout of certain Google browser Interest-Based Advertising, please visit: http://www.google.com/settings/ads.

In addition, we may serve ads on other online services that are targeted to reach people on those services that are also identified on one of more of our data bases (“Matched List Ads”). This is done by using tracking technologies or by matching common factors between our data bases and the data bases of the other online services. For instance, we may use such ad services offered by Meta (Facebook and Instagram) or X (f/k/a Twitter) and other Third-Party Services, which may offer user controls that you can use to limit Matched List Ads. We are not responsible for these Third-Party Services, including without limitation their security of the data or their failure to comply with your or our opt-out instructions, and they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.

Skydance may use Google Analytics or other Vendors for analytics services. These analytics services may use cookies and other tracking technologies to help Skydance analyze users and how they use the Online Services. Data generated by these analytics services (e.g., your IP address and other usage data) may be transmitted to and stored by these Vendors on servers in the U.S. (or elsewhere) and these Vendors may use the data for purposes such as evaluating your use of the Online Services, compiling statistic reports on the Online Services’ activity, and providing other services relating to Online Services activity and other Internet usage. Skydance is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics Vendors and Third-Party Services associated with the Online Services, and encourages you to familiarize yourself with and consult their privacy policies and terms of use.

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. You may exercise choices regarding the use of cookies from Adobe Analytics by going to http://www.adobe.com/privacy/opt-out.html under the section labeled “Tell our customers not to measure your use of their web sites or tailor their online ads for you.”

Skydance is not responsible for effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

Residents of certain U.S. states have additional and more comprehensive rights which are more fully explained in the Do Not Sell/Share/Target Opt-out subsection of the State Privacy Rights Section.  Users from Europe or Canada should review Section B.6, below for additional rights that may apply to them.

c.     Communications

You can opt-out of receiving certain promotional communications from us at any time by following the instructions provided in emails or by clicking on the “Unsubscribe” link. Please note that your opt-out is limited to the email address used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt-out of receiving promotional communications, we may, subject to applicable law, continue to send you non-promotional communications, such as those about your requests or our ongoing business relations.

5.     Third-Party Services

This Online Services Privacy Notice only applies to the processing activities of Skydance through the Online Services. The Online Services may include or link to third-party websites, apps, locations, platforms, code (e.g., plug-ins, application programming interfaces (“API”),) or other services (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other tracking technologies to independently collect data about you and may solicit PD from you.

Certain functionalities on the Online Services permit interactions that you initiate between the Online Services and certain Third-Party Services, such as third-party social networks (“Social Features”). Examples of Social Features include: “liking” or “sharing” Skydance’s content; and to otherwise connect the Online Services to a Third-Party Service (e.g., to pull or push information to or from the Online Services). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Online Services or by the Third-Party Service that you use. Similarly, if you post information on a Third-Party Service that references the Online Services (e.g., by using a hashtag associated with Skydance in a tweet or status update), your post may be used on or in connection with the Online Services or otherwise by Skydance. Also, both Skydance and the third party may have access to certain data about you and your use of the Online Services and any Third-Party Service.

If you follow a link to any Third-Party Services (including postings on the “Job Listings” website that is linked on the Online Services, which are hosted by a third party), please note that those websites have their own privacy statements and that we do not accept any responsibility or liability for those practices. Please check the privacy statements, terms of use and other notices posted by those other third parties before visiting the third party’s website or submitting any personal data via Third-Party Services.

6.     Additional Notices for Users Outside of the U.S.

Europe: 

Most of our Online Services are not directed United Kingdom (“UK”) or European Economic Area (“EEA”) data subjects and are not subject to those jurisdictions’ privacy laws.  However, that is not always the case for Skydance Interactive, LLC and Skydance Silicon Valley LLC (collectively “Skydance Games”).  With respect to Skydance Games’ UK/EEA personal data practices and corresponding data subject rights see our UK/EEA Supplemental Notice, that supplements this Privacy Policy.  Skydance Games websites that are directed to UK or EEA users will also post a cookie statement where the use of cookies requires that notice.    Where the UK/EEA supplemental notice or cookie statement apply, they will govern in the event of a conflict with the main Privacy Policy for applicable data subjects. This UK/EEA supplemental notice is not intended to, and does not, apply to any human resources-related PD that may be processed by UK/EEA Skydance entities, information on which you may obtain from your local UK/EEA human resources department.

Canada:

If you are a resident of Canada, you have the right to access your PD and request the correction of inaccurate information (subject to limited exceptions set out in applicable laws), and have other rights in relation to your PD. Depending on which province you reside in, you may also be entitled to request the rectification of their PD if our collection, disclosure or retention of such information is not authorized by law, to have your PD forgotten, anonymized or de-indexed.

We make reasonable efforts to ensure that your PD is accurate and complete when it is under our control, but also depend on you to provide us with accurate information. To access and correct your PD, please contact us at the email address noted at the end of this Privacy Policy. You can also edit certain information collected about you through our Online Services by editing your information and preferences in your account. Following receipt of a valid request from you, we will take reasonable steps to update or correct their information.

If you are a resident of Canada, you may withdraw your consent to the collection, use and disclosure of your PD in accordance with this Privacy Policy at any time by contacting us, in writing, at the address specified at the end of this notice, subject to legal or contractual restrictions.  Keep in mind that by withdrawing your consent (in whole or in part) to our collection, use or disclosure of your PD, we may no longer be able to provide you with the products or services you requested.

This Canadian supplemental notice is not intended to, and does not, apply to any human resources-related PD that may be processed by Canadian Skydance entities, information on which you may obtain from your local Canadian human resources department.

All non-U.S. Users:  We are based in the U.S. and the information we and our Vendors collect via the Online Services is governed by U.S. law.  If you are accessing our Online Services from outside of the U.S., please be aware that information collected through the Online Services may be transferred to, processed, stored, and used in the U.S.  Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Online Services, or provision of any information therefore, constitutes your acknowledgement of the transfer to and from, processing, usage, sharing, and storage of your information, including PD, in the U.S. (and potentially other territories worldwide) as set forth in this Privacy Policy.   

7.     Data Retention, Security and Monitoring

Skydance will retain the Online Services PD that is subject to this Online Services Privacy Notice for as long as reasonably necessary to achieve the purpose for which it was collected, or to the extent necessary for Skydance to protect its rights, or as otherwise permitted or required by applicable laws.

Skydance maintains reasonable administrative, technical and physical safeguards to protect your Online Services PD against loss, misuse, unauthorized access, disclosure, alteration or destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and Skydance does not guarantee the security of your Online Services PD or of the Online Services.

To help protect you and others, Skydance and its Vendors may (but make no commitment to) monitor use of the Online Service, and may collect and use related information for all purposes not prohibited by applicable law or inconsistent with this Privacy Policy, including, without limitation, to identify fraudulent activities and transactions; prevent abuse of, and investigate and/or seek prosecution for, any potential threats to or misuse of the Online Service; ensure compliance with the Terms of Use; investigate violations of or enforce these policies; improve the Online Services and your user experiences, and to protect the rights and property of Skydance, third parties, and other users. Monitoring may result in the collection, recording, and analysis of online activity or communications through our Online Services. If you do not accept these conditions, you must discontinue your use of the Online Services.

8.     Children and Teens

Our Online Services are intended for individuals who are of the age of majority in the jurisdiction in which they reside, and are not directed at, marketed to, nor intended for children or other minors.  Skydance does not knowingly collect any data, including Online Services PD, from children or other minors. If you believe that we have inadvertently collected data from a child under 13 years of age, please contact us, and we will take steps to delete or otherwise treat the data as required by applicable law. Some State Privacy Laws provide additional consideration for children and teens. More information on the privacy of the PD of / from children and, where regulated by State Privacy Laws, teens (collectively “Child-Aged”) Consumers is included in the Child-Aged Consumers of Certain States subsection of Section C (State Privacy Rights) below.

C.              State Privacy Rights

Subject to meeting the requirements for a Verifiable Consumer Request (defined below) and limitations permitted by applicable laws, Skydance provides Consumers residing in states with State Privacy Laws to which we are subject the privacy rights described in this section. The State Privacy Laws applicable to us are: the California Privacy Rights Act (together, the “CCPA”), the Texas Data Privacy and Security Act, and Chapter 603A of the Nevada Revised Statutes. On January 1, 2025, the Nebraska Data Privacy Act is effective and will be applicable to Skydance.

For residents of states without applicable State Privacy Laws, or where we are not subject to a state’s jurisdiction (e.g., we do not meet applicability thresholds), we will consider requests but will apply our discretion with respect to and if and how we process such requests. We will consider applying state law rights prior to the effective date of such laws but will do so in our discretion.

To submit a request to exercise your Consumer privacy rights, or to submit a request as an authorized agent, complete our Consumer Rights Request Form and return it to us via email to Privacy@skydance.com or contact us via phone by calling 888-862-1186. We do not accept or process requests through other means (e.g., via fax, chats, or social media, etc.). Please respond to any follow-up inquiries we make to help us complete your request.

1.     Your Consumer Privacy Rights

The Consumer privacy rights we accommodate for residents of California, Texas and Nebraska (as of the effective date) are as follows (Nevada residents are entitled only to opt-out of sale of non-cookie PD):

a.     Right to Limit Sensitive PD Processing

We do not process Consumer Sensitive PD.

b.     Right to Know/Access

Residents of California, Texas, and Nebraska are entitled to access PD up to twice in a 12-month period.

(i)   Categories / Confirm Processing

California residents have a right to submit a request for any of the following for the period that is 12-months prior to the request date:

• The categories of PD we have collected about you.
• The categories of sources from which we collected your PD.
• The Business Purposes or commercial purposes for our collecting, Selling, or Sharing your PD.
• The categories of third parties to whom we have disclosed your PD.
• A list of the categories of PD disclosed for a Business Purpose and, for each, the categories of recipients, or that no disclosure occurred.
• A list of the categories of PD sold or shared about you and, for each, the categories of recipients, or that no sale or share occurred.

Residents of Texas and Nebraska are entitled to confirm our processing of their PD, but are not entitled to categories summaries.

(ii)  Specific Pieces

Residents of California, Texas and Nebraska  have a right to obtain a transportable copy, subject to applicable request limits, of their  PD that we have collected and are maintaining. For your specific pieces of PD, as required by applicable State Privacy Laws, we will apply the heightened verification standards. We have no obligation to re-identify data or to keep PD longer than we need it or are required to by applicable law to comply with access requests.

c.     Do Not Sell/Share/Target Opt-out

We permit residents of California, Texas, Nebraska and Nevada to opt-out of PD “sales”; provided, however, that Nevada residents are only entitled to the non-cookie opt-out explained below. California also has an opt-out for “sharing” for cross-context behavioral advertising (i.e., the use of PD derived from different businesses or services to target advertisements). Texas and Nebraska have an opt-out of Targeted Advertising (defined differently but also addressing tracking, profiling and targeting of advertisements).

Third-party digital businesses may associate cookies and other tracking technologies that collect PD about you on our Online Services, or otherwise collect and process PD that we make available about you, including digital activity information and identifiers (“Third-Party Digital Businesses”). We understand that giving access to PD on the Online Service or otherwise, to Third-Party Digital Businesses could be deemed a sale/sharing under the State Privacy Laws and as such, we will treat such PD (e.g., cookie ID, IP address, and other online IDs and Internet or other electronic activity data) collected by Third-Party Digital Businesses, where not limited to acting as our Processor, as a sale/sharing that is subject to a Do Not Sell/Share/Target opt-out request.

Opt-out for Non-Cookie PD: We do not sell or share non-cookie PD, or use non-cookie PD for Targeted Advertising and will not do so until such time as we provide notice and offer an opt-out as to this type of activity.  However, Nevada residents are entitled to register an opt-out in advance, which they may do by complete our Consumer Rights Request Form and return it to us via email to privacy@skydance.com (which under Nevada law only applies to Online Services PD and sales for cash consideration).

Opt-out for Cookie PD: If you would like to limit our processing of your cookie-related PD for Targeted Advertising or opt-out of the Sale/Sharing of such data, you must exercise an  opt-out request via our consent management tool, which is accessible via the “Your Privacy Rights” link on the footer of our websites that employ cookies that may Sell / Share or process for Targeted Advertising. Our consent management tool enables you to exercise such an opt-out request and enable certain cookie preferences on your device. You must exercise your preferences on each of our websites you visit, from each browser you use, and on each device you use. Since your browser opt-out is designated by a cookie, if you clear or block cookies, your preferences will no longer be effective, and you will need to enable them again via our consent management tool. Note that if you use ad blocking software, our cookie banner and/or the “Your Privacy Rights” link may not appear when you visit our website(s). Also note that if you visit our Online Services from outside of the U.S., or if you visit certain Skydance Games websites from any location, non-essential cookies will be on an opt-in rather than opt-out basis, thereby not constituting a Sale or Share and even if you opt-in to Targeted Advertising (or other) cookies you can always change that to reject them. If one of our Online Services does not use cookies that would constitute a Sale, Share, or Targeted Advertising, we may not provide a consent management tool on that Online Service.

Opt-out Preference Signals (also known as global privacy control or “GPC”): Some State Privacy Laws require businesses to process certain types of  signals, referred to as opt-out preference signals in California or universal opt-out mechanism in other states, which are signals sent by a platform, technology, or mechanism, enabled by individuals on their devices or browsers, that communicate the individual’s choice to opt-out of the Sale or Sharing of PD, and of processing of PD for Targeted Advertising, which we understand to include GPC signals.  We currently look for and recognize GPC signals.  To use a GPC, you can download an internet browser or a plugin to use on your current internet browser and follow the settings to enable the GPC. We process GPC with respect to Sales and Sharing, and processing for Targeted Advertising, that may occur in the context of collection of cookie PD via that website and apply it to the specific browser on which you enable GPC. We do not: (1) charge a fee for use of the Service if you have enabled GPC; (2) change your experience with any product or service if you use GPC; or (3) display a notification, pop-up, text, graphic, animation, sound, video, or any interstitial in response to the GPC.

We may disclose your PD for the following purposes, which are not a sale or sharing: (i) if you direct us to disclose PD; (ii) to comply with a Consumer rights request you submit to us; (iii) disclosures amongst the entities that constitute Skydance as defined above, or as part of a Corporate Transaction; and (iv) as otherwise required or permitted by applicable law.

d.     Child-Aged Consumers of Certain States

We do not knowingly Sell or Share, or use for Targeted Advertising, the PD of / from Child-Aged or other similar term (as defined by the applicable State Privacy Law) Consumers who are residents of certain states, unless we receive affirmative opt-in authorization from (i) the applicable Child-Aged Consumer if the Consumer is at least 13 years of age and Consumer consent is required under the applicable U.S. State Privacy Law; or (ii) the parent or guardian of the Child-Aged Consumer if the Consumer is less than 13 years of age. If you think we may have unknowingly Sold or Shared PD, or used PD for Targeted Advertising, of / from a Consumer under the threshold age (as set by the applicable State Privacy Law) without the appropriate affirmative opt-in authorization, please report that to us as described in Section E.

e.     Right to Delete

Residents of California, Texas and Nebraska have the right to request that we delete any of your PD that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your Verifiable Consumer Request, we will delete (and direct our Processors / Service Providers to delete) your PD, unless an exception applies.  If an exception applies, we will limit processing to such permitted purposes and to the duration of those purposes.

We may deny your request to delete your PD if retaining the data is necessary for us or our Processor(s) / Service Provider(s):

• to complete transactions and services, you have requested;
• for security purposes;
• for legitimate internal business purposes (e.g., maintaining business records);
• to comply with law and to cooperate with law enforcement; and
• to exercise or defend legal claims.

Please be aware that making a deletion request does not ensure complete or comprehensive removal or deletion of PD or content that you may have posted. Note also that depending on where you reside (e.g., California), we may not be required to delete your PD that we did not collect directly from you.

f.      Right to Correct Your PD

Residents of California, Texas and Nebraska may bring inaccuracies they find in their PD that we maintain to our attention, and we will act upon such complaint as required by applicable law.

g.     Automated Decision Making / Profiling

We do not engage in automated decision making or profiling that is currently subject to Consumer rights under applicable State Privacy Laws.

2.     How to Exercise Your Consumer Privacy Rights

To submit a request to exercise your Consumer privacy rights, or to submit a request as an authorized agent, complete our Consumer Rights Request Form and return it to us via email to Privacy@skydance.com or contact us via phone by calling 888-862-1186. Please respond to any follow-up inquiries we make to help us complete your request. We do not accept or process requests through other means (e.g., via fax, chats, or social media, etc.), except that notices of Child-aged PD issues and general privacy inquiries may be directed to us as explained in Section E.

a.     Verification of Your Request

We do not verify Sale/Share/Target opt-outs unless we suspect fraud.  As permitted or required by State Privacy Laws, any other request you submit to us must be a “Verifiable Consumer Request,” meaning when you make a request, we may ask you to provide verifying information, such as your name, email, phone number, account and/or transaction information. We will review the information you provided and may request additional information (e.g., customer history) via email or other means to ensure we are interacting with the correct individual. We will not fulfill your Right to Know (Categories), Right to Know (Specific Pieces), Right to Delete, or Right to Correct request(s) unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PD.  Only you, or someone legally authorized to act on your behalf (your authorized agent), may make a Verifiable Consumer Request related to your PD or the PD of your child.

We verify each request as follows:

• Right to Know/Access (Categories / Confirm Processing): We verify your request to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, which we have determined to be reliable for the purpose of verifying you. If we cannot do so, we will refer you to this Privacy Policy for a general description of our data practices.
• Right to Know/Access (Specific Pieces): We verify your request to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, which we have determined to be reliable for the purpose of verifying you together with a signed declaration under penalty of perjury that you are the Consumer whose PD is the subject of the request. If you fail to provide requested information, we may ask for other verification evidence or we will be unable to verify you sufficiently to honor your request, but we will then treat your request as a Right to Know (Categories / Confirm Processing) request.
• Do Not Sell/Share: No specific verification required unless we suspect fraud.
• Right to Delete: We verify your request to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, depending on the sensitivity of the PD and the risk of harm posed by unauthorized deletion. If we cannot verify you sufficiently to honor a deletion request, you can still make a Do Not Sell/Share/Target opt-out request.
• Right to Correct: We verify your request to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, depending on the sensitivity of the PD and the risk of harm posed by unauthorized correction.

To protect Consumers, if we are unable to verify you sufficiently, we will be unable to honor your request. We will use PD provided in a Verifiable Consumer Request only to verify your identity and authority to make the request and to track and document request responses unless you also gave it to us for another purpose.

b.     Authorized Agent Requests

Only you, or someone legally authorized to act on your behalf, subject to our verification of the agent, the agent’s authority to submit requests on your behalf, and of you, in accordance with the Verification of Your  Request section above, may make a Verifiable Consumer Request related to your PD. We cannot respond to your request or provide you with PD if we cannot verify your identity, or authority to make the request, and confirm the PD relates to the applicable Consumer. Once your agent’s authority is confirmed, they may exercise rights on your behalf subject to the agency requirements of applicable laws.

c.     Appeals

You may appeal Skydance’s decision regarding a Consumer privacy rights request you submitted (or that was submitted on your behalf by your authorized agent) by following the instructions provided in our response to your request.

3.     Response Timing and Formats

We endeavor to respond to Verifiable Consumer Requests within forty-five (45) days of receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing.

The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your PD that is readily usable and that allows you to transmit the information from one entity to another without hindrance.

We do not charge a fee to process or respond to your Verifiable Consumer Request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Consistent with applicable State Privacy Laws and our interest in the security of your PD, we will not deliver you information regarding your Social Security number, driver’s license number, or other government-issued ID number, financial account number, an account password, or answers to security questions in response to a Consumer rights request; however, you may be able to access some of this information yourself through your account if you have an active account with us.

4.     Non-Discrimination / Non-Retaliation

We will not discriminate or retaliate against you for exercising any of your Consumer privacy rights. Unless permitted by applicable State Privacy Laws, we will not do the following if you exercise your Consumer privacy rights:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

5.     Notice of Financial Incentives

We may offer discounts or other rewards (“Incentive(s)”) from time-to-time to Consumes who provide us with PD, such as name, phone number, email address, IP address, or location. You may opt-in to Incentives by entering a competition, promotion, or survey or other loyalty Incentive programs we may offer from time-to-time (“Program(s)”). Each Program may have additional terms, available on the Program page or at Program sign-up. The Incentives will be described in the Program page or at Program sign-up.

We measure the value of your PD collected from Programs by the cost of operating the applicable Program (excluding Incentive costs) and/or the cost of providing the Incentive. We deem the value of the PD to be reasonably related to the value of the Incentive, and by subscribing to these Programs, you indicate you agree. If you do not agree, please do not subscribe to the Programs. If you subsequently wish to withdraw from the Programs, the method for doing so will be explained in the applicable Program terms. We do not limit participation in our financial incentive programs to Consumers who do not exercise their Consumer privacy rights. However, a deletion request will not delete Program PD because the information is necessary to maintain your participation in the Program. If you desire to delete Program PD, terminate your participation in the Program before making a deletion request pursuant to State Privacy Laws.

6.     Our Rights and the Rights of Others

Notwithstanding anything to the contrary, we may collect. use, and disclose your PD as required or permitted by applicable law and this may override your rights under State Privacy Laws. In addition, we are not required to honor your requests to the extent that doing so would infringe upon our or another person’s or party’s rights or conflict with applicable law.

7.     Additional Notice for California Residents

This Online Services Privacy Notice provides information about our online practices and your California rights specific to our Online Services. Without limitation, Californians who visit our Online Services and seek to acquire goods, services, money, or credit for personal, family, or household purposes are entitled to the following notices of their rights:

California’s “Shine the Light” law (Civil Code section 1798.83) permits users of our Website who are California residents to request certain information regarding our disclosure of PD to third parties (including our affiliates) for those third parties’ own direct marketing purposes. We do not currently disclose PD to third parties other than our affiliates for those third parties’ direct marketing purposes. To make such a request, please send an email to privacy@skydance.com or write us at 2900 Olympic Blvd., Santa Monica, CA 90404, ATTN: PRIVACY. You must put the statement “Shine the Light Request” in the body of your correspondence. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. This right is different than, and in addition to, Consumer privacy rights, and must be requested separately. We will not accept Shine the Light requests by telephone or by fax and are not responsible for requests not labeled or submitted properly, or that are incomplete.

D.             Changes to These Policies

We reserve the right to change this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy. Any modifications will apply only to PD we collect after posting the updated Privacy Policy unless we obtain your consent. Please check frequently to see any updates or changes to this Privacy Policy. To the extent any provision of this Privacy Policy is found by a court of competent jurisdiction, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

E.              Contact Us

If you have any questions or comments about this Privacy Policy or the Online Services, please contact us at privacy@skydance.com. For general questions about our business, contact us at info@skydance.com.