FREEWHEEL PRIVACY AND COOKIES POLICY
Last Updated: 16 May 2019
FreeWheel Media, Inc. and its wholly-owned subsidiary, Comcast International France SAS (together, “FreeWheel”, “we”, “us” or “our”) is committed to protecting your privacy and ensuring that your personal data is protected.
This Privacy Policy explains:
- the type of personal data we collect about you, how we use that data and how we protect it;
- what to do if you do not want your personal data to be collected by us when you visit our corporate website (freewheel.tv) (“our Site/Sites”), and how you can change data that you have already given to us; and
- the services that we provide to our customers (publishers, content re-sellers, and content aggregators), including our hosted solutions that enable our customers to manage and monetize video and display advertising (the “Services”).
This Privacy Policy applies to personal data collected about you by us via the Sites and our Services. Unless otherwise provided in this Policy, this Policy does not cover our offline data practices.
For the purposes of European data protection law, the data controller of the Sites is FreeWheel Media Inc. A data controller is responsible for determining why your data is collected and how it is processed. Our address is 12th Floor, 1407 Broadway, New York, NY 10018. FreeWheel is part of a larger group of companies so by “group” we mean FreeWheel Media, Inc., its affiliates and their own subsidiary undertakings, unless those companies have published a separate privacy policy.
Summary of Privacy and Cookies Policy
- What Personal Data Do We Collect?
- Information we collect from you directly
- Types of Information We Collect when You Visit our Sites
- Types of Information We Collect from Other Sources
- How We Use Your Information Collecting your personal data helps us to better understand what you need from us. When you provide your personal data and related information about your interests, we can learn more about what types of products and services you might be most interested in so that we can present the right information to you and improve your experience of our Sites.
When you express interest in purchasing our services, we also use personal data that we collect about you to take necessary steps at your request prior to enter into and perform a contract with you for our Services. - Cookies We use “cookies” which are files or pieces of information that may be stored on your computer (or other internet enabled devices, such as a smartphone or tablet) when you visit our Sites. We use cookies to make our Sites easier to use and to better tailor the Sites and our products to your interests and needs.
You may choose not to accept cookies or may disable them on your browser but parts of our site may not work properly without them. - How We May Contact You We use an opt-in standard for sending you marketing communications.
- Third Party Sites If you access the Sites via a third party website, we encourage you to read their individual privacy policies and any terms and conditions to understand how they apply to any data you might permit them to share with us.
- Retention of Your Data We will keep the data we hold about you for as long as we believe is necessary to provide you the information you requested or as reasonably useful for commercial purposes, unless you tell us you would like us to stop holding your data. We retain IP addresses that we have collected on behalf of our customers for a maximum of 18 months from the date of our receipt.
- Sharing Information In connection with our Sites, we use the services of third parties (i.e., technology consultants, CRM vendors, etc.) who will sometimes, in the course of providing services to us, be given access to the information you have provided to us. Any such third parties are not authorised by us to use your personal data in any other way and will be required by us to implement measures to protect your personal data. Please note that we may need to disclose your personal data if we are required to do so by law including to meet national security or law enforcement requirements.
- Public Fora We sometimes offer you the option to post content to a blog, message board, or chat room. In the course of doing so, you may provide personal data. You should be aware that any visitor may view your postings on a blog, on a message board, or in a chat room.
- International Transfer of Information Our primary data centres are located in Europe, Singapore, China and the USA. These data centres are used to store data that we receive from end-users. We comply with all applicable laws to protect the security of data during international transfer. FreeWheel Media, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework.
- Security We take reasonable precautions to keep your personal data secure and where we share your data with third parties we require them to do the same.
- Updates This Policy is effective as of the date set out above. We encourage you to check this Policy from time to time. If we change this Privacy Policy, we will notify you by posting the updated version of the privacy policy 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 Sites for thirty (30) days in advance of such use and we will give you the opportunity to opt out.
- Your Rights and our Contact Information We process data based on your consent, where necessary, our legitimate interest in operating our sites and offering our services, or on the basis that your personal data is required for us to provide the Services to you under the relevant contract between us. This involves several specific purposes as outlined in Section 2, “How We Use Your Information.”
Please note that you always have the right to request that we:- provide you information about how we use your data;
- give you access to, and a copy of your personal data we hold in our systems;
- stop contacting you;
- correct, update or delete your personal data in our records;
- stop using, and ensure that all third parties stop using, some or all of your personal data; or
- note any violations of the Privacy Policy.
If you would like us to change how we deal with your personal data, you can send us an email at legalnotices@freewheel.tv.
- Important Information for United States Residents in California In the United States, California residents have the right to request and obtain a list of the third parties, if any, to which personal information (as defined by California law) has been disclosed for their direct marketing purposes during the immediately prior calendar year (e.g. requests made in 2018 will receive information about 2017 sharing activities, if any). California residents also have the right to opt out of having their personal information shared for direct marketing purposes. You may do so by sending an email to legalnotices@freewheel.tv, using this Policy as the subject line
- Do Not Track When we collect tracking information on our web sites, we do not respond to Users’ Do Not Track settings in browsers. You may choose to decline cookies in your browser settings on a desktop computer, or by declining tracking on a mobile device.
- Children This Site is not intended for, nor does it seek to receive information from, children under the age of 13.
- Our Services to Customers We are an application services provider, and host a software application that our customers access online. Although end users have a right to access their personal data collected by our customers, we have no direct business relationship with the end users of our customers. Please direct your requests to our customers.
Full Privacy and Cookies Policy
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WHAT PERSONAL DATA DO WE COLLECT?
In this Privacy Policy your “personal data” means information or pieces of information that could allow you to be personally identified. Throughout the Sites you may wish to request information about our Services or our companies, including without limitation to request delivery of FreeWheel’s Video Monetization Reports. You may also use our Sites to access our Services such as our user interface (https://mrm.freewheel.tv; https://mrm.freewheel.tv/system/account/login; https://sfx.freewheel.tv). You may also apply for a career with us. You will therefore be asked to provide personal data to identify you personally so that we can provide further information and/or Services to you or process your employment application. We may also ask for additional non-identifiable information, such as how you anticipate you will make use of our products and services.
Our 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 Sites. These features may collect your IP address or which page you are visiting on our 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 Sites. Your interactions with each these features are governed by the privacy statement of the company providing it. 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 data (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 Sites to your profile page to share with others within your network.
When you provide us with personal data and provide your consent, where necessary, or enter into a contract with us, you are authorising us to use that data in accordance with the terms of this Privacy Policy, which includes your right to limit or withdraw your consent for our use of the personal data (see “Your rights and who to contact”). We will process your personal data on the basis that your personal data is required for us to provide the Services to you under the relevant contract between us.
Types of information we collect from you directly:
The types of information you may give us directly include:
- your name;
- your username and password to access our Services;
- employer;
- job title;
- telephone number;
- e-mail address;
- employment information;
- site name and URL;
- address;
- academic information;
- 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.
Types of information we collect when you visit our Sites:
You can visit and navigate our Site to find information about our companies and Services without stating who you are. We use “cookies” in connection with a Site analytics service that helps us better understand how you use the Site and how you navigate through the Site, helps us learn what content is being reviewed, and helps us administer the Site. We do not link data collected from these cookies to personally identifiable information (direct identifiers) we collect from you.
Here are examples of the types of information we may collect from you when you visit the Sites:
- information about the type of browser and operating system you use;
- your internet service provider;
- details of the web pages and advertisements you have viewed;
- your IP address;
- log on time;
- the hyperlinks you have clicked; and
- the websites you visited before arriving at our Site.
Types of information we collect from other sources (such as Facebook Connect, Google+, LinkedIn, or an Open ID provider):
- name;
- email address;
- IP address; and
- details of the webpages you have viewed.
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HOW WE USE YOUR INFORMATION
Collecting your personal data helps us to better understand what you need from us so that we can provide it. When you provide your personal data and related information about your interests, we can learn more about what types of products and services you might be most interested in so that we can present the right information to you and improve your experience of our Sites. We will hold your personal data for as long as we need it to provide information, products and services to you, or until you withdraw your consent for us to process your personal data, whichever is earlier (see “Your rights and whom to contact”).
We use personal data that we collect about you for the following purposes:
- to contact you to further discuss your interest in our companies and our Services;
- to better understand what products or services may be of interest to you;
- to improve our Sites and the Services we provide by presenting the information that is most interesting to users of the sites;
- to perform any automated decision making such as allocating you to a specific user group with common characteristics in order to understand what products or services may be of interest to you and provide you with advertisements on social channels like Facebook, LinkedIn and Twitter that may be most relevant to you;
- to send you information regarding our companies or partners (such as marketing promotions and events).
- to evaluate our Sites, your experience as a visitor, and our offerings to our clients; and
- to track where our visitors may be coming from and what type of software they are using so we can continuously improve our visitors’ online experience and improve the Sites.
We use personal data that we collect about you with your consent to send you information regarding our companies or partners (such as marketing promotions and events).
When you express interest in purchasing our services, we also use personal data that we collect about you for the following additional purposes:
- to take necessary steps at your request prior to entering into a contract with you for our Services; and
- to provide you with Services in accordance with a contract we agree with you.
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COOKIES
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HOW WE MAY CONTACT YOU
We use an opt-in standard for sending you marketing communications, which means we will only do so with your express consent. If you wish to opt out of receiving emails from us (such as FreeWheel’s Video Monetization Reports), please follow the unsubscribe instructions in any emails you receive from us or contact us as provided below.
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THIRD PARTY SITES
If you access the Sites via a third party website, we encourage you to read their individual privacy policies and any terms and conditions to understand how they apply to any data you might permit them to share with us. Where our Sites contain hyperlinks to third party websites you leave our Site when you click through the hyperlinks. We do not control these third party websites or any of the content they contain and we encourage you to read their privacy policies. We do not accept responsibility or liability in relation to your use of any third party Site that you access from our Sites, or which you use to access ours. You use such Sites at your own risk.
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RETENTION OF YOUR DATA
We will keep the data we hold about you for as long as we believe is necessary to provide you the information you requested or as reasonably useful for commercial purposes unless you tell us you would like us to stop holding your data. We retain IP addresses that we have collected on behalf of our customers for a maximum period of 18 months from the date of our receipt. For cookie data, please see above.
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SHARING INFORMATION
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PUBLIC FORA
We sometimes offer you the option to post content to a blog, message board, or chat room. In the course of doing so, you may provide personal data. 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, to the extent that they do not constitute personal data, and you do so at your own risk. We reserve the right at any time 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, as well as to republish any user postings, to the extent that they do not constitute personal data, from blogs, message boards, or chat rooms elsewhere on the Internet in any format. To request removal of your personal data from the blog or community forum, contact us as provided below. You understand and acknowledge that even after removal, copies of submitted content may remain viewable if other users have copies or stored your submitted content. In some cases we will not be able to remove your personal data, in which case we will let you know if 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 Site and used by us in a manner consistent with this Policy. 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.
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INTERNATIONAL TRANSFER OF INFORMATION
Our primary data centres are located in Europe, Singapore, China and the USA. These data centres are used to store data that we receive from end-users. We comply with all applicable laws to protect the security of data during international transfer. FreeWheel Media, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.
We are responsible for the processing of personal data we receive, under each 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 and Switzerland. We may be liable for onward transfers of such personal data where our agent processes personal data inconsistent with the Privacy Shield Principles.
With respect to personal data received or transferred pursuant to each Privacy Shield Framework, we are subject to the investigatory and 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 the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland 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. In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal data. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us legalnotices@freewheel.tv. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration to resolve disputes when other dispute resolution procedures have been exhausted.
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SECURITY
We take reasonable precautions to keep your personal data secure and where we share your data with third parties we require them to do the same. 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 fulfil your request. Access to your personal data is restricted to prevent unauthorised access, loss, modification or misuse and is only permitted among our staff on a need-to-know basis. If you have any questions about the security of your personal information, you can contact us at legalnotices@freewheel.tv.
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UPDATES
This Policy is effective as of the date set out above. We encourage you to check this Policy from time to time. If we change this Privacy Policy, we will notify you by posting the updated version of the privacy policy 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 Sites for thirty (30) days in advance of such use and we will give you the opportunity to opt out.
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YOUR RIGHTS AND OUR CONTACT INFORMATION
We collect and process your personal data on the basis that your personal data is required for us to provide our Services to you under our contract with you or for the legitimate purposes set out in this Privacy Policy. See here for a list of the personal data we will collect about you.
Please note that you always have the right to request that we:
- provide you information about how we use your data;
- give you access to, and a copy of your personal data we hold in our systems;
- stop contacting you;
- correct, update or delete your personal data in our records;
- stop using, and ensure that all third parties stop using, some or all of your personal data; or
- note any violations of the Privacy Policy.
If you would like us to change how we deal with your personal data, you can send us an email at legalnotices@freewheel.tv or write to us at: FreeWheel Media, Inc., 12th Floor, 1407 Broadway, New York, NY 10018, Attn: Legal Counsel. We will respond to your request within a reasonable timeframe. Please note that we will require that you validate your identity prior to processing your request. If we are unable to accept your request, we will provide you with our reasons.
Please do not hesitate to contact us if you have any questions, comments or concerns about this Privacy Policy. To assist us in dealing with your request, please provide your full name and details of your query.
In addition, if you are located in the EU, you have the right to lodge a complaint with your local data protection authority about our use of your personal data.
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IMPORTANT INFORMATION FOR U.S. RESIDENTS OF CALIFORNIA
In the United States, California residents have the right to request and obtain a list of the third parties, if any, to which personal information (as defined by California law) has been disclosed for their direct marketing purposes during the immediately prior calendar year (e.g. requests made in 2018 will receive information about 2017 sharing activities, if any). California residents also have the right to opt out of having their personal information shared for direct marketing purposes. You may do so by sending an email to legalnotices@freewheel.tv, using this Policy as the subject line, and include your full name, e-mail address, phone number and postal address in your message, or you may contact us at the postal address below, including the same information.
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DO NOT TRACK
When we collect tracking information on our web sites, we do not respond to Users’ Do Not Track settings in browsers. You may choose to decline cookies in your browser settings on a desktop computer, or by declining tracking on a mobile device
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CHILDREN
This Site is not intended for, nor does it seek to receive information from, children under the age of 13.
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OUR SERVICES TO CUSTOMERS
We are an application services provider, and host a software application that our customers access online. Although end users have a right to access their personal data collected by our customers, we have no direct business relationship with the end users of our customers. If you are a customer of one of our customer and would no longer like to be contacted by one of our customers that use our Service, please direct your requests to our customer that you interact with directly. We will transfer personal data to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.
An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the FreeWheel’s customer (the data controller). If requested to remove data we will respond within a reasonable timeframe.
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.
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 our customer. 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 prevent personal data to be sent to us (other than IP addresses, device IDs and user IDs). An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to our applicable customer (the data controller) which has transferred such data to us for processing. If requested to remove data we will respond to such request within a reasonable timeframe..