Privacy Policy

FreeWheel Media, Inc. Privacy Statement

Effective Date: August 4, 2015

This privacy statement (this “Statement”) describes the types of information that FreeWheel Media, Inc. (“FreeWheel,” “we,” or “us”) collects from users of its corporate Web site (www.freewheel.tv) and the Web site that its customers use to access the services FreeWheel provides to them (https://mrm.freewheel.tv/system/account/login). 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”). 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.

This Statement is effective as of the date set forth above. We encourage you to check this Statement from time to time. If we make material changes that will affect any personal information that we have already collected from you, we will make reasonable efforts to notify you of the changes and to give you the opportunity to opt out. Your continued use of this Web site constitutes your acceptance of the current posted Statement. If you have questions about our Statement, please contact us as provided below.

TRUSTe Privacy Certification

FreeWheel has received TRUSTe’s Privacy Seal signifying that this Statement and our practices have been reviewed for compliance with the TRUSTe program. In order to view our relationship with TRUSTe, please visit the validation page visible by clicking on the TRUSTe Seal.
If you have questions or concerns regarding this Statement, you should first contact privacy@freewheel.tv. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe here.

The TRUSTe certification covers our collection, use, and disclosure of information we collect through our Web site (www.freewheel.tv) and the Web site that its customers use to access the services FreeWheel provides to them (https://mrm.freewheel.tv/system/account/login).

U.S. – E.U. Safe Harbor
FreeWheel complies with the U.S. – E.U. Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the European Union member countries. 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 http://www.export.gov/safeharbor/.

Information Collection, Use, and Sharing Policies for the FreeWheel Web Sites
Information we collect automatically: You can visit and navigate FreeWheel’s corporate Web site (www.freewheel.tv) to find information about our company and Services without telling us who you are and without revealing any personal information. We use “Cookies” (described below) in connection with a Web site analytics service that helps us better understand how our visitors use this Web site. We review the information provided by this use of cookies to better understand how our visitors navigate through this Web site, to learn what content is being reviewed, and to administer this Web site. We do not collect any information that personally identifies you through our use of these cookies and we do not link data collected from these cookies to personally identifiable information we collect from you. You can set your browser to notify you before you receive a cookie so you have the chance to accept it and/or can set your browser to turn off cookies.

Information you provide to us: You may wish to request information about our Services or our company, including without limitation to request delivery of our 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, FreeWheel 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 site. You may choose to stop receiving our 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 FreeWheel, 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. FreeWheel’s 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 our sign-up form. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network.

If you are a customer user, 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 and https://mrm.freewheel.tv/system/account/login).

FreeWheel may use the information that you provide us to contact you to further discuss your interest in our company and our Services, and to send information regarding our company or partners (such as marketing promotions and events). This information may also be used to improve our Web site 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.

Third party privacy practices: Our Web sites may contain links to other Web sites, such as those of our customers and partners. FreeWheel is not responsible for the privacy practices or the content of such Web sites.

Public Fora
We 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. We 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. We reserve the right at any time, in our 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. We further reserve 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 our blog or community forum, contact us as provided below. In some cases we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Your interactions with the user community programs we have with third party social networking sites such as Facebook, LinkedIn, and Twitter may be displayed on this Web site and used by us 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.

FreeWheel’s Provision of Services to Customers
FreeWheel is an application services provider, meaning that we host a software application that our customers access via the worldwide Web. We have no direct business relationship with the end users of our customers. 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, time, browser type and version, and visitor’s operating system. FreeWheel uses this information for its provision of Services and enforcement of its rights as described in the applicable customer contract, to improve its Services, and to compile aggregated statistics for internal or marketing purposes.

The information that FreeWheel collects, stores, and uses on its customers’ behalf is not intended to identify individual persons. FreeWheel does not allow individual information collected and stored for one customer to be accessed by any other FreeWheel customer. Further, FreeWheel may use and retain such information only as provided in its agreement with its customer. We do, however, reserve a limited right to disclose any data we collect if required by law or valid order of a court or other governmental authority.

None of the above principles 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.

We require each of our customers to abide by all applicable laws, rules and regulations that are applicable to their use of our Services, and we promise each customer that we will do the same with respect to our provision of Services. We ask each customer to post a privacy policy that covers our Services and to maintain all necessary rights to allow us to provide the Services, including without limitation to receive the information that we collect and store on such customer’s behalf. We also require each customer to permit no personally identifiable information to be sent to us. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the customer of FreeWheel (the data controller) which has transferred such data to FreeWheel for processing.

Tracking Technologies and End User Opt-Out
Cookies are files that Web servers place on an Internet user’s computer that are designed to store basic information. FreeWheel uses a cookie in connection with its 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. FreeWheel’s cookie is not specific to any of FreeWheel’s individual customers. Accordingly, if you choose to opt-out of FreeWheel’s cookie for any FreeWheel customer, you will be opted out for all of the Web sites and customers that use FreeWheel’s Services. If you do not want a unique cookie from FreeWheel, there is a simple procedure to follow. Click here to replace your unique FreeWheel cookie with an opt-out FreeWheel cookie.

If you select a FreeWheel opt-out cookie, ads delivered to your browser on behalf of customers using FreeWheel’s 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 FreeWheel’s ad servers. In such case, your FreeWheel 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, FreeWheel’s systems will know that you have opted out and will not attempt to assign other FreeWheel cookies in the future. Since the FreeWheel 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.

In order to provide our 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.

Standard functionality of FreeWheel’s Monetization Rights Management® Service enables our customers to associate a zip code from the IP address we collect from you when you view an ad we have served. We may on behalf of such a customer use this location information to improve the relevance of ads you see.

Our Services also enable us to obtain precise information about your location from ads we serve 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.

For iOS:

(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.

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 (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 our customers to use audience data to enhance their targeting of ads. For these reasons, we have 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 our customers.

Additional tracking technologies such as beacons, tags, and scripts may be used on FreeWheel’s Web sites by FreeWheel and our analytics service provider. These technologies are used in analyzing trends, administering the Web site, 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 site includes 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 site. These features may collect your internet protocol address or which page you are visiting on our Web site, 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 site. 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 FreeWheel assumes 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 FreeWheel’s 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.

Changes in our business or privacy policies
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 below. 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.

If we decide to change our privacy policies, we will post those changes to this Statement and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If, however, we are going to use visitors’ personally identifiable information in a manner different from that stated at the time of collection we will notify visitors by posting a notice on our Web site for thirty (30) days in advance of such use.

Children
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
We provide all visitors to our Web site with the opportunity to review, modify, and 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.

Contacting the Web Site

If you have any questions about this Statement, the practices of this site, or your dealings with this Web site, you can contact:

FreeWheel Media, Inc.
231 Second Avenue, 2nd Floor
San Mateo, CA 94401
Attn: Chief Legal Officer

or:
privacy@freewheel.tv