FreeWheel Media, Inc. and Subsidiaries Privacy Statement
Effective Date: January 1, 2017
This privacy statement (this “Statement”) describes the privacy practices of FreeWheel Media, Inc. (“FreeWheel”) and its wholly owned subsidiary, FreeWheel SAS (“FreeWheel SAS”), together “we” or “us.” This Statement also describes the services that we provide to our customers, including our hosted solutions that enable our customers to manage and monetize video and display advertising (the “Services”). Our customers are publishers, content re-sellers, and content aggregators. We also partner with third parties to enhance our Services. This Statement also contains our end user opt-out mechanisms. Unless otherwise provided in this Statement, this Statement does not cover our offline data practices.
Information Collection, Use, and Sharing Policies for the Corporate Web Sites
Information you provide to us: You may wish to request information about our Services or our companies, including without limitation to request delivery of FreeWheel’s Video Monetization Reports. In order to facilitate the distribution of this content, you will be asked to provide information that could identify you personally, such as your name, company, title, phone number, e-mail address, site name, URL, and address. Based on the nature of your request, we may also ask for additional information, such as number of page views your site receives, how you anticipate you will make use of our products and services, and how you heard about us. Again, all of this information is provided by you on a voluntary basis only and is not required in order for you to use and enjoy our corporate Web sites. You may choose to stop receiving FreeWheel’s Video Monetization Reports or marketing emails by following the unsubscribe instructions included in these emails or by contacting us as provided below.
When applying for a career with us, you will be asked to provide information that could identify you personally, such as your name, company, title, phone number, e-mail address, mailing address, employment information, and academic information. Our Careers Page also allows you to login using single sign-on services such as Facebook Connect, Google+, LinkedIn, or an Open ID provider. These services will authenticate your identity, provide you the option to share certain personal information (such as your name and email address) with us, and enable you to pre-populate the sign-up form. Services like Facebook Connect give you the option to post information about your activities on our Web sites to your profile page to share with others within your network.
If you use our Services, you will be required to enter certain information that can identify you personally (such as username and password) in order to access our user interface (https://mrm.freewheel.tv; https://mrm.freewheel.tv/system/account/login; https://sfx.freewheel.tv).
We may use the information that you provide us to contact you to further discuss your interest in our companies and our Services, and to send information regarding our companies or partners (such as marketing promotions and events). This information may also be used to improve our Web sites and the Services we provide. The information is collected and stored in a manner that is appropriate for the nature of the data that we collect and the need to fulfill your request. This information is not shared with third parties for their own use, unless you specifically authorize such sharing.
When we are contacted via email, we answer by sending an email response to the sender. Subject to our Data Retention policy described below, we also store the email we receive for archival purposes and for our own marketing purposes if we feel that it is consistent with the nature of the inquiry. We will not use return email addresses for any other purpose unless you give us permission to do so.
Information we share with third parties: We may in connection with our Web sites use the services of third parties (i.e., technology consultants, CRM vendors, etc.) who may, in the course of providing services to us, be given access to the information you have provided to us. Each of these service providers is contractually obligated to provide services to us in a manner consistent with this Statement. These services may include:
- Fulfilling and tracking requests
- Recruitment management for employment applications
- Providing customer service
Third party privacy practices: Our Web sites may contain links to other Web sites, such as those of our customers and partners. We are not responsible for the privacy practices or the content of such Web sites.
FreeWheel may at times offer you the option to post content to a blog, message board, or chat room. In the course of doing so, you may provide information that can identify you personally. You should be aware that any visitor may view your postings on a blog, on a message board, or in a chat room. Furthermore, any information that you post, including your profile information, is available to all users of that blog, message board, or chat room, and thus is neither private nor confidential. FreeWheel cannot guarantee the security of such information that is disclosed or communicated online in these public areas, and you do so at your own risk. FreeWheel reserves the right at any time, in its sole discretion, to remove any content that you may post on any blog, message board, or chat room and/or restrict your access to any blog, message board, or chat room. FreeWheel further reserves the right to republish any user postings from blogs, message boards, or chat rooms elsewhere on the Internet in any format. To request removal of your personal information from the blog or community forum, contact FreeWheel as provided below. In some cases FreeWheel may not be able to remove your personal information, in which case FreeWheel will let you know if it is unable to do so and why.
Your interactions with the user community programs FreeWheel has with third party social networking sites such as Facebook, LinkedIn, and Twitter may be displayed on this Web site and used by FreeWheel in a manner consistent with this Statement. Your interactions may also be displayed in your social networking profile. These interactions may be viewable by anyone that has access to that profile, depending on your privacy settings with the social networking site. You should review the privacy policies of these social networking sites to understand who may have access to your interactions and how the site may use them.
Our Provision of Services to Customers
We are an application services provider, meaning that we host a software application that our customers access via the worldwide Web. Although we acknowledge that end users have a right to access their personal information collected by our customers, we have no direct business relationship with the end users of our customers. Please direct your requests to our customers. We also have no control over the content of the advertisement, including any cookies and web beacons set by advertisers on our customers’ sites. Each customer understands that in the course of providing Services to it, we collect or receive information from the Web browsers of individuals that are either visiting such customer’s Web property or viewing content that is owned or displayed by such customer. This information includes frequency of ads delivered and other delivery statistics, time, browser type and version, visitor’s operating system, device type, referral URL, visitors’ IP addresses, visitors’ countries inferred from their IP addresses, and cookie data, including User IDs. We require our customers to obtain consent for our use of such information and we use it for our provision of Services and enforcement of our rights as described in the applicable customer contract, to improve our Services, and to compile aggregated statistics for internal or marketing purposes.
The visitor information that we collect, store, and use on our customers’ behalf is not intended to identify individual persons and we do not possess or have access to information that could match IP addresses or User IDs to the identity of individuals. We do not allow visitor information collected and stored for one customer to be accessed by any other customer. Further, we may use and retain such information only as provided in its agreement with its customer.
Tracking and End User Opt-Out
Tracking Policy: FreeWheel adheres to the Digital Advertising Alliance’s Self-regulatory Principles of Online Behavioral Advertising <http://www.aboutads.info/principles>. Companies that engage in Online Behavioral Advertising (“OBA,” also called Interest-based Advertising) use information gathered about your visits over time and across different Web sites or applications in order to predict your preferences and show you ads that are more likely to be of interest to you. While FreeWheel itself does not engage in Online Behavioral Advertising, certain of FreeWheel’s Services enable its customers to use audience data to enhance their targeting of ads. For these reasons, FreeWheel has elected to participate in the DAA’s Consumer Choice Page <http://www.aboutads.info/choices/> in order to offer you the ability to elect not to receive such targeted advertising from FreeWheel customers.
FreeWheel SAS does not collect data, nor set cookies, to build profiles for OBA. Some of FreeWheel SAS’ buying partners may do this from their systems. You should check http://www.youronlinechoices.com/ and http://www.networkadvertising.org/choices/ to understand which companies use this data and optout if you wish to.
User Tracking – Desktop: Cookies are files that Web servers place on an Internet user’s computer that are designed to store basic information. We use a cookie in connection with our provision of Services. This cookie does not store any personally-identifiable information and is not otherwise used to provide your identity; it merely is used to recognize your browser. Our cookie is not specific to any of our individual customers. Accordingly, if you choose to opt-out of our cookie for any of our customers, you will be opted out for all of the Web sites and customers that use our Services. If you do not want a unique cookie from us, there is a simple procedure to follow. To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
Click here to replace your unique FreeWheel cookie with an opt-out FreeWheel cookie.
Click here to replace your unique FreeWheel SAS cookie with an opt-out FreeWheel SAS cookie.
If you select an opt-out cookie, ads delivered to your browser on behalf of customers using our ad-serving technology will be targeted based only on the non-personally-identifiable information that is automatically transmitted in the Internet environment when an ad request is received by our ad servers. In such case, your cookie will not be uniquely identified. The non-personally identifiable information that is automatically transmitted includes your browser type, Internet service provider, information about the general content of the site or page displayed on your browser, and other non-personally identifiable information provided by the Web site or customer. When you receive this cookie, our systems will know that you have opted out and will not attempt to assign other of our companies’ cookies in the future. Since the opt-out cookie does not contain a unique user number, it does not allow your browser to be identified uniquely.
PLEASE NOTE: If you erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), or use a new or different computer, you may need to opt out again.
User Tracking – Mobile Devices: In order to provide the Services in connection with mobile applications, we may use technologies that perform similar functions to cookies. To opt out of certain targeted advertising on your mobile device via your device’s identification number, follow the instructions below:
For Android: (1) Open the Google Settings app on your device; and (2) Select Ads.
For iOS: devices with iOS 6 and above use Apple’s Advertising Identifier. To learn more about limiting ad tracking that uses this identifier, visit the Settings menu on your device.
Location Tracking: Standard functionality of FreeWheel’s Monetization Rights Management® Service (“MRM”) enables MRM customers to associate a zip code from the IP address FreeWheel collects from you when you view an ad FreeWheel has served. FreeWheel may, on behalf of a customer, use this location information to improve the relevance of ads you see. FreeWheel SAS does not collect or utilize such location information.
The Services also enable FreeWheel to obtain precise information about your location from ads FreeWheel serves to your mobile device. In order to opt out of advertising that is targeted to your mobile device based on your location, follow the instructions below:
For Android, there are 2 methods:
Method 1: (1) Open the Google Settings app on your device; (2) Go to Location (before Android 5.0); and (3) Turn off the “Location” setting.
Method 2: (1) Open Notification Center (swipe down from top of device); and (2) Turn off the “Location” setting.
(1) Go to Settings; (2) Go to Privacy; (3) Go to Location Services; and (4) Turn off the “Location Services” functionality and/or review information about specific Applications and System Services.
Additional tracking technologies such as beacons, tags, and scripts may be used by us on our Web sites and our analytics service provider. These technologies are used in analyzing trends, administering the Web sites, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
Our Web sites include social media features, such as the Facebook “Like” button, and widgets, such as the “Share This” button or interactive mini-programs that run on our Web sites. These features may collect your internet protocol address or which page you are visiting on our Web sites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Web sites. Your interactions with each these features are governed by the privacy statement of the company providing it.
Security & Data Retention
We maintain security measures with the view to protecting against the loss, misuse, and alteration of any information that is under our control. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we are committed to use commercially acceptable means to protect your information, please be advised that we assume no responsibility or liability for disclosure of your information (personal or otherwise) due to errors in transmission, unauthorized third-party access, or other causes beyond our control.
We will retain any personally identifiable information you have provided to us for as long as we believe is necessary to provide you the information you requested or as reasonably useful for commercial purposes. We retain IP addresses that we have collected on behalf of our customers for a period of 4 weeks in the case of FreeWheel and 1 year in the case of FreeWheel SAS from the date of our receipt.
International Data Transfers
FreeWheel Media, Inc. and its subsidiary FreeWheel SAS participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
We are responsible for the processing of personal data we receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We further commit to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
U.S. – Swiss Safe Harbor Framework
FreeWheel Media Inc. complies with the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. FreeWheel has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view FreeWheel’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.
Changes in our business
As we continue to develop our business, we may sell certain of our assets. In such transactions, visitor information may be one of the transferred assets. Also, in the event that all or substantially all of our assets are acquired in a transaction, our visitor information may be an asset that is reviewed and transferred. Such a transaction will be disclosed per the guidelines in this Statement. Also, we reserve the right to disclose any data we collect at our sites if required by law or valid order of a court or other governmental authority or to protect the health and safety of our employees or the general public.
This Web site is not intended to nor does it seek to receive information from children under the age of 13.
Access or Update Your Information
Upon request, we will provide you with information about whether we hold any of your personal information. We provide all visitors to our Web sites with the opportunity to review, modify, and (where technically feasible) delete any personally identifiable information that has previously been provided. You can send us an email or write to us as set forth below. We will respond to your access request within a reasonable timeframe. If we are unable to grant you access, you will be afforded a reason why.
If you have any questions about this Statement or the practices of our Web sites, you can contact us at:
FreeWheel Media, Inc.
231 Second Avenue, 2nd Floor
San Mateo, CA 94401
Attn: Chief Legal Officer
This Statement is effective as of the date set forth above. We encourage you to check this Statement from time to time. We will post changes to this Statement here. If, however, we intend to use personal data in a manner different from that stated at the time of collection we will notify visitors by posting a notice on our Web sites for thirty (30) days in advance of such use and we will give you the opportunity to opt out. Your continued use of our Web sites and the Services constitutes your acceptance of the current posted Statement.
None of the principles in this Statement changed following FreeWheel’s acquisition by Comcast Cable Communications, LLC (“Comcast”). All of FreeWheel’s contractual obligations with respect to each customer’s information have remained and will remain intact. Also, post-acquisition, FreeWheel will continue to operate as a wholly-owned subsidiary of Comcast, meaning the two companies will be separate legal entities. As such, FreeWheel cannot per the terms of its agreement with each customer allow Comcast (or any of Comcast’s other affiliates) to access FreeWheel customer data for any purpose. Maintaining FreeWheel’s status as a trusted partner is critical to the continued success of our business. Comcast and FreeWheel have been careful to structure the acquisition so as not to disrupt that trust.