Trusted Partner Network Privacy Policy
Last Updated: April 3, 2024
We at the Trusted Partner Network (“TPN”) respect your concerns about privacy. This Privacy Policy describes the types of personal information we obtain about you, including when you visit our website and other online services we own and control (collectively the “Sites”), how we use the information, with whom we may share it and the choices available to you regarding our use of the information. We also describe the measures we take to safeguard the personal information and how you can contact us about our privacy practices. Finally, if you are a user or recipient of our products, services or programming, we describe your obligations with respect to certain personal information transferred to you.
If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Policy called “California Consumer Privacy Statement” by clicking here https://www.ttpn.org/privacy-policy/#ccpa.
- Information We Obtain
- How We Use The Information We Obtain
- Third-Party Analytics
- Information We Share
- Your Choices
- Data Transfers
- How We Protect Personal Information
- Children’s Privacy
- Other Online Services And Third-Party Features
- Updates To Our Privacy Policy
- How To Contact Us
INFORMATION WE OBTAIN
We may obtain certain personal information about individual assessors and personnel of vendors and motion picture and television studios that participate in TPN’s programming (collectively, “Participants”). We also may obtain personal information about you if visit or otherwise interact with our Sites, or if you have administered or participated in a content security audit performed by a motion picture and television studio or vendor that participates in TPN’s programming. The personal information we may obtain includes:
- contact information, such as name, email and postal address, and phone number(s);
- internet protocol address, online identifier, or other personal identifier;
- photographs;
- signature, physical characteristics or description, bank account number, credit card number, debit card number, and other financial information;
- Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements;
- geolocation data;
- login credentials;
- employer, job title and other professional information;
- information contained in security audits results and accreditation applications; and
- other personal information you submit to us, such as through emails or sign-up forms.
Additionally, TPN may take steps to verify information applicants provide to TPN as part of their application to receive (or renew) accreditation from TPN – specifically,
- corporate and/or individual addresses, email address, and contact information;
- educational and/or employment history; and
- professional accreditations (if any).
TPN may take these steps itself, or may retain a third-party company to perform this verification on its behalf, subject to and in compliance with all applicable laws.
In addition, when you visit our Sites, we may obtain certain information by automated means, such as cookies, web server logs, web beacons, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.
We may use these automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include your device IP address, identifiers associated with your devices, types of devices connected to our Sites, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Sites. These technologies help us (1) remember your information so you will not have to re-enter it; (2) track and understand how you use and interact with our Sites; (3) tailor the Sites around your preferences; (4) measure the usability of our Sites and the effectiveness of our communications; and (5) otherwise manage and enhance our services, and help ensure they are working properly.
Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Sites. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.
HOW WE USE THE INFORMATION WE OBTAIN
We may use the information described above to:
- provide services (such as administering security auditor accreditation and training programs, facilitating security audits, and making the results of security audits available to significant stakeholders within the entertainment industry);
- send you promotional materials, newsletters and other communications;
- create and manage your account;
- respond to your inquiries;
- perform data analyses (including market and consumer research, economic impact analyses, demographic analyses and anonymization and aggregation of personal information);
- operate, evaluate and improve our business (including developing new services; enhancing, improving and analyzing our services; managing our communications; and performing accounting, auditing and other internal functions);
- maintain and enhance the safety and security of the TPN, including the Sites, and prevent misuse;
- protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other criminal activity; and
- comply with and enforce applicable legal requirements, relevant industry standards and TPN policies.
We also may use the information in other ways for which we provide specific notice at the time of collection, and obtain consent to the extent required by law.
Third-Party Analytics
We may use third-party web analytics services on our Sites, such as those of Google Analytics. These service providers help us analyze how visitors use the Sites. The information obtained for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. To learn more about Google Analytics, please click here.
INFORMATION WE SHARE
If you are a Participant, we may make some of your personal information available to other Participants and third-party security auditing firms to facilitate communication regarding content security services and issues, manage participation in the TPN, and otherwise operate and provide our services (including the distribution of security audits to stakeholders within the entertainment industry). If you are an individual assessor who participates in the TPN, we also may make certain of your profile information publicly available to help enable communication with our other Participants and industry stakeholders.
In addition, we may disclose personal information we obtain to our affiliates. We also may share personal information with service providers who perform services on our behalf based on our instructions. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. In addition, we may share personal information with our relevant business partners, such as the licensors of key products and services we use, in order to assist them in improving or providing the licensed products or services.
We also may disclose personal information (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent.
We reserve the right to transfer any personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).
YOUR CHOICES
We offer you certain choices in connection with the personal information we collect from you. To update your preferences, limit the communications you receive from us, or submit a request, please contact us as indicated in the “How To Contact Us” section of this Privacy Policy.
DATA TRANSFERS
We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries (such as the United States), we will protect that information as described in this Privacy Policy and will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries other than the one in which you provided the information.
We follow applicable data protection laws when transferring personal data. If you are a participant in TPN and located in the European Economic Area (“EEA”), United Kingdom or Switzerland, we will protect your Personal Information when it is transferred outside of such locations by implementing appropriate safeguards to protect your Personal Information through the use of Standard Contractual Clauses (“SCCs”) as approved by the European Commission, which may be viewed here. These SCCs describe the practices and obligations of (a) TPN, if and when it receives such Personal Information from participants located in the EEA, and (b) users of TPN’s products, services or programs, to the extent they subsequently receive such Personal Information from the EEA further to their use of TPN’s products, services or programs.
HOW WE PROTECT PERSONAL INFORMATION
We maintain administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
CHILDREN’S PRIVACY
Our Sites are intended for a general audience and are not directed to children. We do not knowingly collect personal information online from children under the age of 13.
OTHER ONLINE SERVICES AND THIRD-PARTY FEATURES
For your convenience and information, our Sites may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, is subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by TPN, we are not responsible for these third parties’ information practices.
The providers of third-party apps, tools, widgets and plug-ins on our sites also may use automated means to collect information regarding your interactions with these features. For example, when we present videos on our Website, we may use Vimeo as a third-party platform provider, which uses cookies independent of our own. These third parties may collect information about your online activities over time and across third-party websites. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. To the extent permitted by applicable law, we are not responsible for these providers’ information practices.
UPDATES TO OUR PRIVACY POLICY
This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post the updated version on our Sites and indicate at the top of the Policy when it was most recently updated.
HOW TO CONTACT US
If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please email us at privacy@motionpictures.org or write to:
Trusted Partner Network, LLC
c/o Motion Picture Association, Inc.
15301 Ventura Blvd., Bldg. E
Sherman Oaks, CA 91403
Attn: Privacy
California Consumer Privacy Statement
Effective: January 1, 2023
This California Consumer Privacy Statement supplements the Privacy Policy and applies solely to California consumers. This Statement does not apply to MPA personnel or job applicants.
This California Consumer Privacy Statement uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018, the California Privacy Rights Act of 2020, and/or its implementing regulations (together, the “CCPA”).
- Notice of Collection and Use of Personal Information
We may collect the following categories of personal information about you:
- Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, telephone number, photograph, and other similar identifiers
- Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, bank account number, credit card number, debit card number, and other financial information
- Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
- Geolocation Data
- Employment Information: professional or employment-related information
We may use the categories of personal information listed above for the purposes described in our Privacy Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:
| Purposes | Categories of Personal Information |
| Performing services (such as administering security auditor accreditation and training programs, facilitating security audits, and making the results of security audits available to significant stakeholders within the entertainment industry), processing payments, providing analytics services, or providing similar services |
|
| Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity |
|
| Debugging to identify and repair errors that impair existing intended functionality |
|
| Undertaking internal research for technological development and demonstration |
|
| Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us |
|
- Our Prior Collection, Use and Disclosure of Personal Information
We may have collected and used your personal information, as described in Section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold, and (d) the categories of personal information we may have disclosed for a business purpose.
- Sources of Personal Information
We may have obtained personal information about you from various sources, as described below.
| Categories of Sources of Data Collection | Categories of Personal Information |
| Directly from you, such as information that you submit to us, or that you may provide to us, including via direct submission by email or webform, or via our websites
|
§ Identifiers
§ Additional Data Subject to Cal. Civ. Code § 1798.80 § Sensory Information § Employment Information |
| From your devices, such as your desktop computer, laptop computer(s), or mobile device(s) when you visit our websites | § Identifiers
§ Online Activity § Geolocation Data § Inferences |
| Vendors who provide services on our behalf | § Identifiers
§ Additional Data Subject to Cal. Civ. Code § 1798.80 § Online Activity § Geolocation Data § Sensory Information § Employment Information |
| Social networks and other online sources | § Identifiers
§ Additional Data Subject to Cal. Civ. Code § 1798.80 § Protected Classifications § Commercial Information § Online Activity § Geolocation Data § Employment Information |
- Sharing of Personal Information
We may have shared your personal information with certain categories of third parties, as described below.
| Categories of Third Parties | Categories of Personal Information |
| Our affiliates | § Identifiers
§ Additional Data Subject to Cal. Civ. Code § 1798.80 § Protected Classifications § Commercial Information § Online Activity § Geolocation Data § Sensory Information § Employment Information |
| Vendors who provide services on our behalf | § Identifiers
§ Additional Data Subject to Cal. Civ. Code § 1798.80 § Protected Classifications § Commercial Information § Online Activity § Geolocation Data § Sensory Information § Employment Information |
| Professional services organizations, such as auditors and law firms | § Identifiers
§ Additional Data Subject to Cal. Civ. Code § 1798.80 § Protected Classifications § Commercial Information § Online Activity § Geolocation Data § Sensory Information § Employment Information |
| Government entities | § Identifiers
§ Additional Data Subject to Cal. Civ. Code § 1798.80 § Protected Classifications § Commercial Information § Online Activity § Geolocation Data § Sensory Information § Employment Information |
| Data analytics providers | § Identifiers
§ Online Activity § Geolocation Data |
- Sale of Personal Information
We do not sell your personal information in exchange for monetary compensation.
During the 12-month period prior to the effective date of this California Consumer Privacy Statement, we have not sold personal information.
- Disclosure of Personal Information for a Business Purpose
We may have disclosed to third parties for a business purpose the following categories of personal information:
- Identifiers
- Additional Data Subject to Cal. Civ. Code § 1798.80
- Online Activity
- Geolocation Data
- Sensory Information
- Commercial Information
- Employment Information
- California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
How to Submit a Request. To submit a request for access or deletion, click here for our webform or call us toll-free at 877-968-3334.
Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide your name, email address, and two or more of the following: mailing address, telephone number, online identifier, internet protocol address, or other similar identifiers. In addition, since we do not have consumer accounts, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access or deletion request on your behalf (a) we may require you to provide the authorized agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).
Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact privacy@motionpictures.org or call us toll-free at 877-968-3334 during regular business hours (9:00am – 5:00pm Pacific Time) to request this Statement in an alternative form.