TOUCHTUNES INFORMATION PRIVACY AND SECURITY POLICY
TouchTunes is committed to respecting the legitimate information privacy and security concerns of our operator -partners- ("Operators") and their customers ("Users") who enjoy or play our jukeboxes and/or other coin-operated devices ("Devices"). This statement describes our policies and procedures as currently in effect with respect to the management of information collected from Operators and Users.
TouchTunes reserves the right to change such policies and procedures in any respect and at any time by posting on TouchTunes' web site at www.touchtunes.com an amended, restated, or otherwise modified statement of policies and procedures relating to the treatment of Operator or User information collected by TouchTunes.
As part of the routine operation of Devices and its business practice, TouchTunes may obtain certain information of or relating to Operators and Users including personally identifying information such as names, physical addresses, email addresses, credit card numbers, bank account numbers, and telephone numbers ("Personal Information"); transaction- or event-specific information with respect to any single transaction or event such as identity and cost of purchased products or services, and participation in an event ("Transactional Information"); and business-specific information with respect to an Operator such as information identifying its locations or Devices in particular of its locations, or its earnings and revenues for its locations or Devices ("Business Information").
For purposes of this policy, "Confidential Information" means, with respect to any particular Operator or User, all Personal Information and Transactional Information (and, in the case of any Operator, Business Information) of such Operator or User that is, on its face or in combination with any publicly available and readily accessible information, identifiable as information of such Operator or User. Confidential Information, therefore, does not include information that, because it is aggregated with other information or for any other reason, is not personally identifiable to any particular Operator or User.
TOUCHTUNES TREATS ALL CONFIDENTIAL INFORMATION GATHERED ON THE TOUCHTUNES DIGITAL JUKEBOX NETWORK AS PROPRIETARY AND CONFIDENTIAL. WE MAINTAIN STRICT INTERNAL SECURITY PROCEDURES DESIGNED TO PROTECT CONFIDENTIAL INFORMATION FROM UNAUTHORIZED USE, ACCESS AND DISCLOSURE, INCLUDING:
Placing security and confidentiality notices on any physical materials normally sent to any Operator containing Confidential Information of such Operator, including a facsimile cover page for bills and invoices;
Storing Confidential Information in a secure physical environment and marking that environment as containing Confidential Information; Maintaining a secure electronic environment for any Confidential Information stored electronically;
Maintaining confidentiality agreements with employees or agents that may have access to any Confidential Information; While TouchTunes information security procedures are designed to maintain to the extent reasonably practicable the security of all Confidential Information, we cannot and do not guarantee that such precautions will prevent every unauthorized attempt to access, use, or disclose Confidential Information.
TOUCHTUNES LIMITS THE USE OF THE CONFIDENTIAL INFORMATION TO WHAT IS NECESSARY TO IMPROVE ITS SERVICE LEVELS AND TO DELIVER THE HIGHEST QUALITY SERVICE TO OPERATORS.
All Confidential Information collected by TouchTunes is and shall remain the property of TouchTunes. TouchTunes may use Confidential Information for any legitimate business purpose related to the maintenance, improvement of and marketing of the businesses, products and services of TouchTunes and Operators. These purposes include, but are not limited to, using collected data to recognize Player preferences and provide recommendations based on data collected from other Players, analyzing the use and popularity of Devices; research and development of new Devices; administering and monitoring contracts including payments and/or revenue sharing agreements; customer service, technical support and maintenance, including, from time to time, installation and servicing of Devices; advertising and marketing of Devices.
Users may elect not to receive any marketing and sales material from TouchTunes by contacting TouchTunes at the address set forth below.
TouchTunes may also disclose Confidential Information to third parties including outside professional advisors and service providers, and potential business transaction partners. Any such disclosures will be made subject to an obligation of non-disclosure and all Confidential Information will be marked as "Confidential."
Information of or relating to Operators and Users that does not constitute Confidential Information-namely, any information that is not personally identifiable to any particular Operator or User-is not subject to this statement of policies and procedures and, thus, may be used by TouchTunes in any manner its sole discretion without any obligation to maintain its confidentiality.
Notwithstanding the foregoing, TouchTunes will disclose Confidential Information when required by law in order to comply with a valid legal process such as a subpoena, court order, or search warrant, for example. We may also use or disclose Confidential Information to protect our customers, employees, or property, in emergencies, to enforce our rights in court or elsewhere, or directly with the Operator, and for violations of the agreement between TouchTunes and the Operator.
QUESTIONS OR COMMENTS
If you have any questions or concerns about this policy, please contact TouchTunes' customer service department at
3455 Salt Creek Lane, Suite 100
Arlington Heights, IL 60047 USA