Microsoft Privacy Statement

For Addressable and Interactive Television Advertising and Audience Measurement

INTRODUCTION

Microsoft is committed to protecting your privacy and the privacy of other pay TV subscribers. This privacy statement applies to the data used and collected by Microsoft’s Addressable and Interactive Television Advertising , Audience Measurement and Media Placement services and technologies (the “Services”). It does not apply to any other Microsoft products, services or technologies or any Microsoft website. It also does not apply to the use of Microsoft’s technologies and services by Microsoft’s cable, satellite, telecommunications and multiple systems operator partners (collectively all the “TV Partners”) where Microsoft does not use any of the data that is collected.

COLLECTION AND USE OF VIEWERSHIP DATA

For audience measurement, the Services collect viewership data from set-top boxes through tuner events. A tuner event is defined as a channel change followed by a dwell of a specific period of time on the new channel. Tuner events are collected as a series of discrete viewing periods where each tuner event represents the consumption of a particular service (i.e. channel position) for a period of time. Currently, the Services only collect viewership data from cable and broadcast network viewership. Future plans for the Services may include the collection of video on demand and digital video recorder data as well.

As part of the data collection process, Microsoft will remove from the viewership data all information (e.g. set-top box MAC address) that could be used to associate the viewership data with an individual subscriber or household. Microsoft will then associate the viewership data with a unique identifier that is relevant only to the Services. Microsoft will never associate this unique identifier with any personally identifiable information (such as your name, address or account number) and will create this unique identifier using industry standard technologies that make it computationally infeasible for the unique identifier to be associated back to a specific individual or household. In addition, Microsoft will not store the viewership data until after all information that could be used to associate the viewership data with an individual subscriber or household has been removed from the viewership data.

Prior to or after removing all information that could be used to associate the viewership data with an individual subscriber or household, Microsoft may (either directly or through a third-party) associate the viewership data with third-party provided demographic and other categorization data. However, Microsoft will only associate this third-party provided demographic and categorization data with the viewership data at an aggregate level that does not allow the direct or indirect determination of the viewing behavior of an individual or household.

The Services use the collected viewership data to identify television advertising placement opportunities that meet advertiser target-audience objectives and then broadcast advertising to the applicable target audiences. Microsoft optimizes television ad placement by matching audience concentrations with particular shows and ads. Once optimized placements are identified based upon audience concentrations, ads are broadcast to all viewers either within an ad zone or on a nationwide basis. Microsoft does not currently use the viewership data to target television advertising at the individual or household level.

PARTICIPATION IN VIEWERSHIP DATA COLLECTION

In Microsoft’s collection of viewership data from set-top boxes, it will also comply with the data collection policies, terms and conditions that pay TV subscribers agree to as part of their subscription for pay TV services. The TV Partners are subject to the provisions of the Cable Communications Privacy Act of 1984 (“CCPA”). The CCPA specifies what disclosures our TV Partners must make regarding the collection and use of data related to their subscription services. Microsoft provides the TV Partners with technology that allows their subscribers to opt-out of viewership data collection. However, it is up to each TV Partner to provide this opt-out option to its subscribers and a subscriber must contact them directly with any opt-out request or opt-out related questions.

COLLECTION AND USE OF INTERACTIVE DATA

In the case of interactive applications, your interactions with an enhanced TV advertisement or overlay application may be recorded. In addition, some interactive applications may allow you to enter personal information (e.g. your name, email address, phone number, etc.) through the use of your TV remote. Microsoft will only collect this information when you actively and knowingly enter it, and will only pass this information to the third party that is clearly identified as the party that will receive such information. However, Microsoft is not responsible for such third party’s use of your personal information or any aspects of your interactions with such third party.

Except as otherwise described in this privacy statement, Microsoft will not provide your personal information to any third parties for whom you have not affirmatively requested it to do so or use your personal information for any purpose other than the fulfillment of your request. In addition, Microsoft will not store your personal information except to the extent necessary for the provision of your information to the third-party as requested by you.

Microsoft occasionally hires other companies to provide limited services on its behalf, such as providing customer support or performing statistical analysis of our services. Those service providers will be permitted to obtain only the personal information they need to deliver the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose. Microsoft may also access or disclose the information that is collected by the Services in order to: (a) comply with applicable laws or respond to lawful requests or legal process or (b) act on a good faith belief that such access or disclosure is necessary to protect the personal safety of Microsoft employees, customers, or the public. Information that is collected by the Services may be stored and processed in the United States or any other country in which Microsoft or its affiliates, subsidiaries, or service providers maintain facilities. Microsoft abides by the safe harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union.

SECURITY OF YOUR INFORMATION

Microsoft is committed to helping protect the security of your information. Microsoft uses a variety of security technologies and procedures to help protect your information from unauthorized access, use, or disclosure. For example, Microsoft stores the information you provide on computer systems with limited access and that are located in controlled facilities.

CHANGES TO THIS PRIVACY STATEMENT

Microsoft will occasionally update this privacy statement to reflect changes in its products, services, and customer feedback. When Microsoft posts changes, it will revise the "last updated" date at the top of this statement. If there are material changes to this statement or in how Microsoft will use the data that it collects, Microsoft will notify you by posting a notice of such changes prior to implementing the change. Microsoft encourages you to periodically review this statement to be informed of how Microsoft is protecting and using the information that it collects from set-top boxes.

FOR MORE INFORMATION

Microsoft welcomes your comments regarding this privacy statement. If you have questions about this statement or believe that we have not adhered to it, please contact us by e-mail to tvmpriv@microsoft.com or at:

Microsoft Privacy
Microsoft Corporation
One Microsoft Way
Redmond, Washington 98052 USA