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PRIVACY POLICY

Type of website: Ecommerce

Effective date: 1st day of January, 2024


https://cultureentertainmentnetwork.com (the "Site") is owned and operated by Covington

Entertainment Group, LLC. Covington Entertainment Group, LLC is the data controller and can

be contacted at:


support@cultureentertainmentnetwork.com

________________________________________

One Atlantic Center 1201 N. Peachtree Street, S.W. Suite 2126 Atlanta, Georgia 30309

Purpose

The purpose of this privacy policy (this "Privacy Policy") is to inform users of our Site of the

following:

1. The personal data we will collect;

2. Use of collected data;

3. Who has access to the data collected;

4. The rights of Site users; and

5. The Site's cookie policy.

This Privacy Policy applies in addition to the terms and conditions of our Site.

GDPR

For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European

Parliament and of the Council of 27 April 2016, known as the General Data Protection

Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as

enshrined in the Data Protection Act 2018.


We have not appointed a Data Protection Officer as we do not fall within the categories of

controllers and processors required to appoint a Data Protection Officer under Article 37 of the

GDPR.

Consent

By using our Site users agree that they consent to:


Website Privacy Policy Page 2 of 7

1. The conditions set out in this Privacy Policy.

When the legal basis for us processing your personal data is that you have provided your

consent to that processing, you may withdraw your consent at any time. If you withdraw your

consent, it will not make processing which we completed before you withdrew your consent

unlawful.

You can withdraw your consent by: To withdraw consent, please send an email to

withdrawconsent@cultureentertainmentnetwork.com.

Legal Basis for Processing

We collect and process personal data about users in the EU only when we have a legal basis for

doing so under Article 6 of the GDPR.

We rely on the following legal bases to collect and process the personal data of users in the EU:

1. Users have provided their consent to the processing of their data for one or more specific

purposes; and

2. Processing of user personal data is necessary for us or a third party to pursue a legitimate

interest. Our legitimate interest is not overridden by the interests or fundamental rights and

freedoms of users. Our legitimate interest(s) are: We provide our affiliates and third-party

advertising clients with the opportunity to present all Culture Entertainment Network

subscribers with special offers, promotional announcements and advertisements. By

providing our affiliates and third-party advertising clients, we can keep subscription cost

to our subscribers free-of-charge to our Silver-Package Subscribers.

Personal Data We Collect

We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will

not collect any additional data beyond the data listed below without notifying you first.

Data Collected Automatically

When you visit and use our Site, we may automatically collect and store the following

information:

1. IP address;

2. Location;

3. Hardware and software details;


Website Privacy Policy Page 3 of 7

4. Clicked links; and

5. Content viewed.

Data Collected in a Non-Automatic Way

We may also collect the following data when you perform certain functions on our Site:

1. First and last name;

2. Age;

3. Sex;

4. Email address;

5. Phone number;

6. Address;

7. Payment information; and

8. Auto fill data.

This data may be collected using the following methods:

1. All from the creation of a new subscription account on the Culture Entertainment Network..

How We Use Personal Data

Data collected on our Site will only be used for the purposes specified in this Privacy Policy or

indicated on the relevant pages of our Site. We will not use your data beyond what we disclose

in this Privacy Policy.

The data we collect automatically is used for the following purposes:

1. We capture marketing tracking data, advertising conversion data, traffic engagement length

of time and any and all statistics..

The data we collect when the user performs certain functions may be used for the following

purposes:

1. Communications and end user identity verification.


Website Privacy Policy Page 4 of 7

Who We Share Personal Data With

Employees

We may disclose user data to any member of our organization who reasonably needs access to

user data to achieve the purposes set out in this Privacy Policy.

Third Parties

We may share user data with the following third parties:

1. Covington Retail Media Network, LLC and/or any authorized third parties we authorize to

view our user data.

We may share the following user data with third parties:

1. Links clicked while consumers engage with the site..

We may share user data with third parties for the following purposes:

1. For the purpose of targeted advertising.

Third parties will not be able to access user data beyond what is reasonably necessary to

achieve the given purpose.

Other Disclosures

We will not sell or share your data with other third parties, except in the following cases:

1. If the law requires it;

2. If it is required for any legal proceeding;

3. To prove or protect our legal rights; and

4. To buyers or potential buyers of this company in the event that we seek to sell the company.

If you follow hyperlinks from our Site to another Site, please note that we are not responsible

for and have no control over their privacy policies and practices.

How Long We Store Personal Data

User data will be stored for 2 Years.

You will be notified if your data is kept for longer than this period.

How We Protect Your Personal Data

In order to protect your security, we use the strongest available browser encryption and store all


Website Privacy Policy Page 5 of 7

of our data on servers in secure facilities. All data is only accessible to our employees. Our

employees are bound by strict confidentiality agreements and a breach of this agreement would

result in the employee's termination.

While we take all reasonable precautions to ensure that user data is secure and that users are

protected, there always remains the risk of harm. The Internet as a whole can be insecure at

times and therefore we are unable to guarantee the security of user data beyond what is

reasonably practical.

Your Rights as a User

Under the GDPR, you have the following rights:

1. Right to be informed;

2. Right of access;

3. Right to rectification;

4. Right to erasure;

5. Right to restrict processing;

6. Right to data portability; and

7. Right to object.

Children

The minimum age to use our website is 18 years of age. We do not knowingly collect or use

personal data from children under 16 years of age. If we learn that we have collected personal

data from a child under 16 years of age, the personal data will be deleted as soon as possible. If

a child under 16 years of age has provided us with personal data their parent or guardian may

contact our privacy officer.

How to Access, Modify, Delete, or Challenge the Data Collected

If you would like to know if we have collected your personal data, how we have used your

personal data, if we have disclosed your personal data and to who we disclosed your personal

data, if you would like your data to be deleted or modified in any way, or if you would like to

exercise any of your other rights under the GDPR, please contact our privacy officer here:

Michael J. Covington

support@cultureentertainmentnetwork.com


Website Privacy Policy Page 6 of 7


________________________________________

One Atlantic Center N. Peachtree Street, S.W., Suite 2625, Atlanta, Georgia 30309

Do Not Track Notice

Do Not Track ("DNT") is a privacy preference that you can set in certain web browsers. We do

not track the users of our Site over time and across third party websites and therefore do not

respond to browser-initiated DNT signals. We are not responsible for and cannot guarantee how

any third parties who interact with our Site and your data will respond to DNT signals.

How to Opt-Out of Data Collection, Use or Disclosure

In addition to the method(s) described in the How to Access, Modify, Delete, or Challenge the

Data Collected section, we provide the following specific opt-out methods for the forms of

collection, use, or disclosure of your personal data specified below:


1. Subscribers can opt out of the use of personal data for direct marketing emails. You can opt-

out by by clicking the "unsubscribe" on the bottom of any marketing email or updating your email preference under your account.

Cookie Policy

A cookie is a small file, stored on a user's hard drive by a website. Its purpose is to collect data

relating to the user's browsing habits. You can choose to be notified each time a cookie is

transmitted. You can also choose to disable cookies entirely in your internet browser, but this

may decrease the quality of your user experience.

We use the following types of cookies on our Site:

1. Analytical cookies

Analytical cookies allow us to improve the design and functionality of our Site by

collecting data on how you access our Site, for example data on the content you access,

how long you stay on our Site, etc., and

2. Targeting cookies

Targeting cookies collect data on how you use the Site and your preferences. This allows

us to personalize the information you see on our Site for you.

Modifications

This Privacy Policy may be amended from time to time in order to maintain compliance with

the law and to reflect any changes to our data collection process. When we amend this Privacy

Policy we will update the "Effective Date" at the top of this Privacy Policy. We recommend


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©2022-2024 Culture Entertainment Network® All Rights Reserved

that our users periodically review our Privacy Policy to ensure that they are notified of any

updates. If necessary, we may notify users by email of changes to this Privacy Policy.

Complaints

If you have any complaints about how we process your personal data, please contact us through

the contact methods listed in the Contact Information section so that we can, where possible,

resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you

may contact a supervisory authority. You also have the right to directly make a complaint to a

supervisory authority. You can lodge a complaint with a supervisory authority by contacting the

One Trust.

Contact Information

If you have any questions, concerns or complaints, you can contact our privacy officer, Michael

J. Covington, at:

support@cultureentertainmentnetwork.com

________________________________________

One Atlantic Center N. Peachtree Street, S.W., Suite 2625, Atlanta, Georgia 30309

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Culture Entertainment Network

One Atlantic Center 1201 N. Peachtree Street, S.W. Suite 2625 Atlanta, Georgia 30309

The Culture Entertainment Network, LLC is a wholly owned subsidiary of Covington Entertainment Group, LLC. All Information, promotional content and music are the intellectual properties of the Culture entertainment Network,LLC© COPYRIGHT 2022 -2025. All Rights Reserved.

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