PRIVACY NOTICE

Ole Distribution, LLC, operating the website under the Ole Distribution brand (“Ole Distribution,” “OLE,” “we,” “us,” or “our”), recognizes the importance of privacy and the protection of personal data.

This Privacy Notice describes how we collect, use, share, store, and protect personal data related to access to and use of the Ole Distribution website, currently available at https://www.oledistribution.com/ (the “Site”).

The Site is primarily corporate, informational, promotional, and commercial in nature. It is used to present Ole Distribution’s activities, its channel portfolio, programming and content information, industry news, and commercial opportunities, as well as to allow operators, platforms, prospective customers, partners, and other interested persons to contact our team.

This Notice primarily governs personal data processing activities related to the Site.

Processing activities carried out in the context of specific contractual relationships with customers, licensors, operators, platforms, vendors, or other partners may be subject to separate contracts, data processing agreements, privacy notices, and other independent terms.

1- Controller

With respect to personal data processing activities related to the Site for which it determines the purposes and means of processing, the controller is:

Ole Distribution, LLC
2525 Ponce de Leon Boulevard, Suite 250
Coral Gables, Florida 33134
United States of America

Email for privacy matters: contacto@oledistribution.com

2- Scope

This Notice applies to personal data collected through the Site, including data obtained through:

• browsing the Site;
• contact forms;
• requests for information;
• commercial contacts;
• communications sent through the Site;
• interaction with news and other Site pages; and
• cookies, pixels, and similar technologies.

This Notice does not necessarily govern all processing activities carried out in the context of separate contractual or commercial relationships with Ole Distribution.

3- Personal Data We May Collect

3.1. Information Provided Directly

When a person uses the contact form or otherwise communicates with us through the Site, we may collect information such as:

• first name;
• last name;
• company or organization;
• email address;
• information included in the field describing the project, interest, or inquiry; and
• any other information the person voluntarily chooses to provide.

The information provided may relate, among other matters, to:

• channel distribution;
• signal availability;
• relationships with operators or platforms;
• commercial opportunities;
• channel onboarding;
• programming;
• distribution projects; or
• other inquiries related to Ole Distribution’s activities.

We ask users not to provide through the general form:

• passwords;
• credentials;
• financial information;
• sensitive personal data;
• third-party trade secrets;
• confidential audiovisual content; or
• information that is not reasonably necessary to address the request.

3.2. Information Collected Automatically

When a person uses the Site, we may automatically collect certain technical or browsing information, including, as applicable:

• IP address;
• browser type;
• device type;
• operating system;
• cookie identifiers and similar technologies;
• pages visited;
• channels or sections viewed;
• date and time of access;
• approximate duration of the visit;
• traffic source or channel;
• interactions performed on the Site;
• information related to campaigns or conversions; and
• other technical, statistical, or operational information.

4- Cookies and Similar Technologies

The Site uses or may use cookies, pixels, tags, and similar technologies for:

• technical purposes;
• security;
• analytics;
• statistical purposes;
• measurement; and
•  

Depending on the final implementation of the Site, these tools may include:

• Google Analytics;
• Google Ads;
• Meta Pixel;
• LinkedIn Insight Tag;
• tools associated with Site hosting and security; and
• other analytics, measurement, or advertising technologies.

Where applicable law requires consent to use cookies or technologies that are not strictly necessary, such technologies will be used in accordance with the preferences selected by the user.

The user may manage preferences through the cookie settings tool available on the Site.

For additional information, please see our Cookie Policy.

5- Purposes of Processing

We may use personal data collected through the Site for the following purposes:

Responding to Requests

• respond to requests for information;
• respond to inquiries regarding our portfolio;
• provide general information about channels and services;
• identify the interested party’s needs;
• route an inquiry to the appropriate team; and
• maintain communications related to a request received.

Commercial Management

• evaluate commercial opportunities;
• manage contacts with operators, platforms, customers, prospective customers, and partners;
• follow up on requests;
• manage pre-contractual relationships;
• prepare meetings or proposals;
• evaluate distribution opportunities;
• maintain records related to commercial opportunities; and
• develop and manage business relationships.

Operation and Improvement of the Site

• operate and maintain the Site;
• analyze Site use and performance;
• detect technical issues;
• improve content, navigation, and user experience;
• understand which sections generate greater interest; and
• perform statistical analyses.

Advertising and Measurement

Where applicable and subject to applicable consent requirements:

• measure advertising campaigns;
• analyze conversions;
• generate audience statistics;
• evaluate traffic sources;
• evaluate the performance of digital campaigns; and
• conduct digital marketing activities through tools implemented on the Site.

Security and Compliance

• protect the Site and our systems;
• detect and prevent fraud, abuse, or unlawful activities;
• investigate security incidents;
• exercise or defend legal rights;
• retain records where necessary; and
• comply with legal, regulatory, or contractual obligations.

6- Commercial Communications

The form available on the Site is primarily intended to allow a person to contact Ole Distribution regarding its activities, portfolio, services, or commercial opportunities.

When a person has requested information or initiated a commercial contact, we may communicate with them to:

• respond to the request;
• request additional information;
• conduct reasonably related follow-up;
• coordinate a meeting; or
• continue discussions regarding the proposed opportunity.

Submitting the form does not automatically result in enrollment in newsletters or general marketing campaigns.

If newsletters or other periodic promotional communications are enabled in the future, we will implement the consent, objection, or opt-out mechanisms required by applicable law.

7- Legal Bases for Processing

Depending on the applicable jurisdiction and the specific activity, we may process personal data on the basis of:

• the data subject’s consent;
• steps requested by the data subject prior to a potential contractual relationship;
• our legitimate interests in operating our business, responding to requests, developing business relationships, managing opportunities, improving the Site, and protecting our systems, where permitted by applicable law;
• compliance with legal or regulatory obligations;
• the establishment, exercise, or defense of legal claims; or
• any other lawful basis recognized under applicable law.

Where processing depends on consent, consent may be withdrawn in accordance with the available mechanisms and subject to applicable law.

Withdrawal of consent will not affect the lawfulness of processing carried out before such withdrawal.

8- Service Providers and Third Parties

We may use external service providers to support the operation of the Site, our communications, and other corporate activities.

Such providers may provide services related to:

• hosting;
• technology infrastructure;
• security;
• DNS and networks;
• Site maintenance and development;
• content management;
• corporate email;
• analytics;
• advertising and measurement;
• communication tools;
• consent management; and
• other technology services.

Depending on the technical configuration, these may include:

• the hosting provider;
• cloud service providers;
• corporate email providers;
• Google;
• Meta;
• LinkedIn; and
• other technology or analytics providers.

These third parties may process information only to the extent necessary to provide the relevant services, subject to their respective roles, contracts, and legal obligations.

9- Affiliated Companies and Corporate Structure

Ole Distribution carries out its activities in collaboration with related companies and other participants in the media and entertainment industry.

We may share certain information with affiliated or related companies where reasonably necessary to:

• respond to a request;
• evaluate a commercial opportunity;
• route the request to the appropriate team or entity;
• manage internal operations;
• provide administrative, commercial, or technological support;
• comply with legal obligations; or
• conduct other legitimate business activities compatible with the purposes described in this Notice.

10- Business Partners, Channels, and Content Owners

Depending on the nature of an inquiry, it may be necessary to share certain contact information with a channel owner, media company, vendor, business partner, or other entity involved in a potential opportunity.

For example, this may occur where:

• the inquiry requires participation by the channel owner;
• it is necessary to evaluate the availability or terms of an opportunity;
• there is a joint commercial opportunity; or
• it is necessary to involve another entity in order to respond appropriately.

Such sharing will occur only where there is a legitimate purpose and an appropriate legal basis.

We do not sell personal data obtained through the Site form as a standalone activity involving the commercial sale of databases.

11- Disclosure of Information

We may also share personal information:

• with providers that support the operation of the Site and our systems;
• with affiliated or related companies;
• with business partners where necessary to address a request or develop a legitimate opportunity;
• with professional advisors, attorneys, auditors, or consultants;
• where required by a competent authority;
• where necessary to comply with a legal obligation;
• to prevent fraud or protect the security of our systems;
• to establish, exercise, or defend legal claims;
• to protect our rights, property, or legitimate interests; or
• in connection with a merger, acquisition, reorganization, financing, sale of assets, or other corporate transaction.

We will not use or share personal data for purposes materially incompatible with those described in this Notice without an appropriate legal basis.

12- International Transfers

Ole Distribution conducts international activities and maintains relationships with companies and service providers located in different countries.

In addition, some technology providers used to operate the Site may store or process information in multiple jurisdictions.

As a result, personal data may be processed, stored, or transferred to countries other than the country in which the data subject is located, including the United States.

Where applicable, we will implement the measures, contractual mechanisms, and other safeguards required by applicable law for international transfers of personal data.

13- Data Retention

Information provided through contact forms or other commercial communications may be retained for up to twenty-four (24) months after the last relevant interaction.

This period may be extended where:

• there is an ongoing commercial or contractual relationship;
• the information is necessary to continue a negotiation;
• there is an active commercial opportunity;
• there is a legal retention obligation;
• retention is necessary to establish, exercise, or defend legal claims; or
• another valid legal basis permits a longer retention period.

Once the data is no longer reasonably necessary, it may be deleted, anonymized, or retained only where permitted or required by applicable law.

Data collected through cookies and similar technologies may be subject to different retention periods.

14- Information Security

We implement reasonable technical and organizational measures designed to protect personal data against:

• unauthorized access;
• loss;
• alteration;
• destruction;
• misuse; and
• unauthorized disclosure.

The measures implemented may include access controls, authentication mechanisms, infrastructure security measures, monitoring, and other appropriate safeguards.

However, no method of electronic transmission or storage can guarantee absolute security.

15- Data Subject Rights

Depending on applicable law and the relevant jurisdiction, the data subject may have the right to:

• know whether we process their personal data;
• access their data;
• request information about the processing;
• request correction, rectification, or updating;
• request deletion, cancellation, or suppression;
• object to certain processing activities;
• request limitation or restriction of processing;
• request portability, where applicable;
• withdraw consent;
• lodge a complaint with a competent data protection authority; and
• exercise other rights recognized under applicable law.

To exercise these rights, you may contact us at: contacto@oledistribution.com

We may request information reasonably necessary to verify the identity of the requester before responding to a request.

We will respond in accordance with the timeframes and requirements established by applicable law.

16- Information for Residents of Brazil

Where the Lei Geral de Proteção de Dados Pessoais – Law No. 13.709/2018 (“LGPD”) applies, data subjects may exercise, as applicable, the rights provided under such law, including:

• confirmation of the existence of processing;
• access to data;
• correction of incomplete, inaccurate, or outdated data;
• anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;
• portability, in accordance with applicable regulations;
• deletion of data processed on the basis of consent, subject to legal exceptions;
• information regarding public and private entities with which data has been shared;
• information about the possibility of withholding consent and the consequences thereof;
• withdrawal of consent; and
• objection in the circumstances provided by law.

The data subject may also submit a petition to the Autoridade Nacional de Proteção de Dados – ANPD in the circumstances provided under applicable law.

17- Other Local Privacy Rights

Because Ole Distribution conducts activities in different Latin American countries, certain local data protection laws may apply depending on the location of the data subject or the circumstances of the processing.

Where applicable, we will address privacy rights requests in accordance with the requirements of the applicable local law.

18- Data Relating to Minors

The Site is primarily intended for companies, operators, platforms, professionals, and other participants in the media and entertainment industry.

It is not specifically designed for use by children or to collect personal information from minors.

Although the Site may display information about channels or content intended for family or children’s audiences, this does not mean that the Site is directed to children or that Ole Distribution seeks to collect their personal data.

If we become aware that personal information of a minor has been collected through the form without the required authorization, we will take reasonable measures in accordance with applicable law.

19- Information Relating to Third Parties

If a person provides through the Site personal data belonging to another person, that person represents that they have authorization or another appropriate legal basis to provide such data where required by applicable law.

We ask that users not provide personal data of third parties that is not necessary to address the relevant inquiry.

20- Third-Party Sites and Services

The Site may contain links to:

• channel websites;
• media companies;
• social media platforms;
• digital platforms;
• partner websites; and
• other resources operated by third parties.

This Privacy Notice does not govern the privacy practices of such third parties.

We recommend reviewing their own privacy policies before providing information or using such services.

21- Changes to This Privacy Notice

We may update this Notice to reflect changes in:

• our practices;
• the structure of the Site;
• functionalities offered;
• technologies used;
• service providers engaged;
• our commercial activities; or
• legal or regulatory requirements.

The current version will be available on the Site and will identify the date of its last update.

Where a change is material and applicable law requires it, we will provide any additional notice required.

22- Independent Commercial and Contractual Relationships

This Notice primarily governs personal data processing activities related to the Site.

Relationships between Ole Distribution and:

• operators;
• platforms;
• channel owners;
• media companies;
• vendors;
• distributors;
• customers;
• partners; or
• other third parties,

may involve processing of personal data different from that described in this Notice.

Such processing may be subject to:

• specific contracts;
• data processing agreements;
• separate privacy notices;
• instructions from the relevant parties; and
• other applicable terms.

23- Contact

For questions or requests related to this Privacy Notice or the processing of personal data related to the Site:

Ole Distribution, LLC
2525 Ponce de Leon Boulevard, Suite 250
Coral Gables, Florida 33134
United States of America

Privacy email: contacto@oledistribution.com