Privacy Policy

Last Updated: January 31, 2023

This is the Privacy and Cookie Policy (Privacy Policy) for FreeWheel Media, Inc. and (except where they have published their own separate privacy policy) its affiliates and their own subsidiaries (together, FreeWheel, we, us or our). We are committed to your privacy and ensuring that your personal information is protected.

This Privacy Policy applies to personal information, which is information that is linked or reasonably linkable to you or your household, such as your name, address, telephone number, device identifiers, and IP addresses. It explains the type of personal information we collect about you, and how we collect, use, maintain, protect and share this information. This Privacy Policy also describes your rights regarding your personal information, and how you can contact us.

There are two situations when we may process your personal information:

To explain the processing involved for the situation applicable to you, we have organized this Privacy Policy in Sections, and some sections apply to how we process your personal information dependent upon how you interact with us:

Site Visitors: Do you interact with us on our Sites? Please read the Site Visitors tab below, which combines Sections 1 and 3, to learn how we process your personal information when you visit our Site(s). Note Section 3 applies regardless of whether you visit our Site(s) or are an end user of customers to whom we provide Services – this Section applies in both situations.

Services: Do you interact with us through our Services? Please read the Services tab below, which combines Sections 2 and 3, to learn how we process your personal information when you are an end user or authorized account user of customers to whom we provide Services. Note Section 3 applies regardless of whether you visit our Site(s) or are an end user of customers to whom we provide Services – this Section applies in both situations.

1. Site Visitors: Your Personal Information When You Visit Our Sites

1.1 The Personal Information We Collect and How We Collect It

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 MRM or SFX user interfaces. For more detail about personal information we collect if you are one of our customer’s authorized account users, see Section 2 Services below. You may also apply for a job with us. We may ask you to provide personal information so that we can provide further information and/or Services to you or process your employment application.

Information We Collect When You Visit Our Sites:

You can visit and navigate our Sites to find information about our companies and Services without stating who you are. We do not link data collected from Cookies on our Sites to personally identifiable information (direct identifiers) we collect from you. See 1.9 How We Use Cookies On Our Sites below for more information about Cookies. Information we may collect when you visit our Sites includes:

Information We May Collect Directly From You When You Apply For A Career With Us Includes:

Information We May Collect From Other Sources Includes:

1.2 How We Use And Share Your Information

When we collect your personal information, we learn more about what types of products and services you might be most interested in so we can present the right information to you and improve your experience on our Sites.

We use personal information and related information we collect about you for the following purposes:

When you express interest in purchasing our Services, we also use personal information we collect about you for the following additional purposes:

We may share your personal information within the FreeWheel companies to understand which products and services are more likely to be of interest to you, or with third party vendors as described below:

Each third party vendor is contractually obligated or otherwise subject to confidentiality obligations to provide services to us in a manner consistent with this Privacy Policy. Any such third parties are not authorised by us to use your personal information in any other way and will be required by us to implement adequate measures to protect your personal information.

We may also share your personal information to meet FreeWheel’s legal or other obligations as described below:

1.3 Third Party Social Networking Features

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 of these features are governed by the privacy policy of the company providing that feature.

User community programs we have with third party social networking sites such as Facebook, LinkedIn, and Twitter may be displayed on our Sites and used by us in a manner consistent with this Policy. Your interactions may also be displayed in your social networking profile if you choose to do so. 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 our Sites may use them.

1.4 How Long We Keep Your Information

We keep the information we have about you for as long asnecessary to fulfill your requests, or as reasonably necessary for commercial purposes. See 1.9 How We Use Cookies On Our Sites below for information on Cookie duration.

1.5 FreeWheel’s Role Under EU and UK Data Protection Law

FreeWheel is a controller responsible for processing personal information in relation to the Sites. We collect and process your personal information for the legitimate purposes set out in Section 1 of the Privacy Policy, and on the basis of your consent, where applicable, for sending you marketing communications.

1.6 Your Rights and Our Contact Information

You may request that we:

If you wish to opt out of receiving promotional emails from us (such as where you are a customer of FreeWheel’s services, or FreeWheel’s Video Monetization Reports), please follow the unsubscribe instructions in any emails you receive from us or contact us as provided below.

If you would like to request any of the above or report any suspected violations of the Privacy Policy, 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. For EU and UK purposes, our data protection officer (DPO) can be contacted at dpo@freewheel.com. We will respond to your request within a reasonable timeframe. Please note that in some circumstances we may require that you validate your identity prior to processing your request. If we are unable to process your request, we will provide you with our reasons. If you are located in the EU or the UK, you have the right to lodge a complaint with your local data protection authority about our use of your personal information.

1.7 United States Residents of California

The California Consumer Protection Act (CCPA) provides California residents with specific rights regarding their personal information. This subsection describes our personal information collection and disclosure practices, and explains how California residents can exercise their rights. These rights apply to all residents of California, regardless of whether you are a consumer or business contact. As a California resident,you have the right not to receive discriminatory treatment, including the right not to be retaliated against, for the exercise of your privacy rights.

To review the number of requests we have received over time and how we have complied with those requests, please view our Individual Rights Annual Report – January 1, 2021 – December 31, 2021.

Notice of California Consumer Data Collection and Sharing Practices

The Privacy Policy includes descriptions of our data collection practices, including the personal information we collect, the sources of that information, the purposes for which we collect information, and whether we sell or disclose that information to external parties. We may use any and all of the information for any of the purposes described in the Privacy Policy, unless limitations are listed. Some of the categories include very different types of information within the same category and certain personal information may fall into multiple categories. How we use and how long we keep the information within each category will vary and not all types of information within the same category will be used for all of the purposes listed.

California law also requires us to provide information regarding the criteria we use to determine the length of time for which we retain personal information. We use the following criteria: (1) the business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes; (2) whether we are required to retain the information in order to comply with legal obligations or contractual commitments, or retention is otherwise necessary to protect our or others rights; (3) the privacy impact on the consumer of ongoing retention, including the consumer’s likely expectations in light of the sensitivity of the information; and (4) the manner in which information is maintained in our systems and how best to manage the data in light of the volume and complexity of those systems. Individual pieces of personal information such as those listed below may exist in different systems that are used for different business or legal purposes. A different maximum retention period may apply to each use case of the information. For more information about the retention of cookie data, please see click here.

The CCPA requires us to disclose the personal information we have collected about consumers in the past 12 months in the following categories:

We share the above-listed information with service providers and contractors, which are external parties we engage for business purposes and are restricted from using personal information for any purpose not related to our engagement. The categories of service providers and contractors with whom we disclose information and the services they provide are described in the Privacy Policy.

We may also disclose information to other external parties who are not listed here when required by law or to protect FreeWheel or other persons, as described in our Privacy Policy.

Access To Specific Information And Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose to you:

Correction

If we hold personal information that is not accurate, California residents have the right to request we correct this information.

Deletion

You have the right to request that we delete personal information that we collected from you, subject to certain exceptions. We will delete (and direct our service providers and contractors to delete) your personal information from our records upon receiving your verifiable consumer request, unless an exception applies.

Do Not Sell or Share My Personal Information

On certain occasions, we sell or share information to third parties. To “sell” information means to disclose it to an external party for monetary or other benefit. To “share” personal information means to disclose it to a third party for cross-context behavioral advertising. The categories of these third parties are identified above in 1.2 How We Use And Share Your Information. An external party may be considered a third party either because the purpose of disclosure is not an enumerated business purpose under California law, or because our contract does not restrict them from using personal information for other purposes. We do not have actual knowledge that we sell any personal information of individuals under the age of 16. We sell or share the following information:

You have the right to opt out of this sale or sharing of your personal information. See 1.9 How We Use Cookies On Our Sites below for more information.

Exercising Your Access, Data Portability, Correction, Deletion, And Do Not Sell or Share My Personal Information Rights

To exercise your access, data portability, correction, deletion, and do not sell or share my personal information rights described above, please submit a request to us by either calling us at (888) 930-6228 or sending an email to: FW_California_Consumers_CCPA
_Data_Requests@freewheel.com
.

You are not required to create an account with us in order to make a request. You may also make a request on behalf of your minor child. When making your request, please confirm the nature of your relationship with us and provide an appropriate form of identification to enable us to locate your personal information. If you use an authorized agent to submit an access or deletion request, the authorized agent must provide proof that you gave the agent signed permission to submit the request and their proof of identity. We may also require you to verify your identity directly with us. We will only use personal information provided in a request to verify the requestor’s identity or authority to make the request.

You can also opt out of the sale or sharing of personal information that is automatically collected on our Sites by updating your Cookie Settings available on our website. See 1.9 How We Use Cookies On Our Sites below for more information.

We are not required to provide personal information to you more than twice within a 12-month period, but will consider additional requests on a case-by-case basis.

Right to Limit Use or Disclosure of Sensitive Personal Information

California residents have the right to request that we limit our use and disclosure of certain sensitive personal information to certain limited purposes authorized by California law. To request that we apply this limitation to your sensitive personal information, please submit a request to us by either calling us at (888) 930-6228 or sending an email to FW_California_Consumers_CCPA
_Data_Requests@freewheel.com

1.8 Important Information for United States Residents in Virginia

Virginia law provides Virginia residents with the right to access, delete, and correct certain personal information we collect about them, as well as to the restrict the use of that person for targeted advertising, restrict the “sale” of that personal information, and control our use of personal information that is considered sensitive. Virginia residents also have a right not to receive discriminatory treatment for the exercise of their privacy rights.

You or an authorized agent may submit a request to exercise your access, deletion, and correction rights by calling us at (888) 930-6228 or sending an email to FW_California_Consumers_CCPA
_Data_Requests@freewheel.com
. To opt-out of targeted advertising and the sale of personal information, or to set preferences regarding our use of sensitive personal information, please submit a request to us by either calling us at (888) 930-6228 or sending an email to FW_California_Consumers_CCPA
_Data_Requests@freewheel.com
. In addition, to manage the automatic sharing of information from our Sites for targeted advertising, you can update your cookie settings by setting your preferences on https://www.freewheel.com/cookie-settings. If we deny your request, you have the right to appeal our decision. To request an appeal, you must follow the instructions set forth in the denial.

1.9 How We Use Cookies On Our Sites

Like many companies, we use cookies (small files placed on your computer or device) and other common tracking technologies on the Services, including HTTP cookies, HTML5 and Flash local storage/flash cookies, web beacons/GIFs, embedded scripts, ETags/cache browsers, and software development kits (collectively, Cookies or a Cookie). A Cookie will usually contain the name of the website from which the Cookie has come from, the “lifetime” of the Cookie (i.e., how long the cookie will remain on your device), and a value, which is usually a randomly generated unique number. In this subsection we provide more information about these Cookies.

We Use Cookies:

What Cookies Do We Use On Our Sites?

For more information about the Cookies we use when you visit our Sites, please see the cookie consent tool that can be found here. The Cookies we use include the following categories:

Necessary Cookies (always active)

Essential cookies contribute to making the website operable, including enabling us to block any non-necessary Cookies you decline using the Cookie consent tool provided on this Site. The website cannot work properly without these Cookies.

Social Media and Video

These cookies enable the use of social networks’ functionalities on this Site and allow them to track your navigation on our services and analyze your interaction with their functionalities. Cookies placed via video sharing services are also designed to enable the user to view multimedia content directly on the Site.

Analytics

Cookies for audience and performance measurement allow us to establish statistics on traffic (e.g., number of visits, most visited pages, etc.). They allow us to understand how visitors interact with our Site and to improve the quality of our Services.

Advertising

Advertising cookies are used to track your behavior on websites and to provide more relevant advertising that is tailored to your interests as well as to measure the performance of advertising campaigns. We adhere to the Digital Advertising Alliance’s Self-regulatory Principles of Online Behavioral Advertising. Companies that engage in Online Behavioral Advertising (“OBA,” or Interest-based Advertising) use information gathered about your visits over time and across different websites or applications in order to predict your preferences and show you ads that are more likely to be of interest to you. We partner with third parties to provide certain services on our Sites, such as the ability to share content on other platforms. Our third-party partners may use cookies or similar technologies in order to analyze your behavior across websites.

What Is The Duration Of Cookies On Our Sites?

Cookie duration details can be found here (click Cookie Settings).

Can I Change My Cookie Preferences For The Sites Or On Mobile Devices?

You may indicate your Cookie preferences by using the Cookie consent tool provided when you first visit the Site or by selecting Cookie Settings during any subsequent Site visit, by changing your Cookie preferences in your browser settings on a desktop computer, or by declining tracking on a mobile device (see detail below). Declining any optional cookies through the Cookie consent tool provided on the Site will result in an ‘essential’ cookie being dropped to ensure the declined cookies are not re-assigned. Please note if you use the above link to opt out of our Cookies, we use a cookie to store this opt out preference which means 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 to restore your opt-out preference. Because definitions and rules for a “Do Not Track” standard have not yet been established, including whether such signals must be user-enabled, FreeWheel does not yet respond to “Do Not Track” signals sent from browsers.

To opt out of certain targeted advertising on your mobile device via your device’s identification number, follow the instructions below:

3. Site Visitors and Services: Additional Common Information

The following concepts also apply to the processing of personal information referred to in Sections 1 and 2:

3.1 International Transfer of Information

Our primary data centres are located in Europe (UK, Germany, France and Netherlands), Singapore, and the USA. We comply with all applicable laws to protect the security of data during international transfer, for instance by using EC standard contractual clauses and appropriate supplementary measures when a transfer is made to a third party country that is not considered adequate by the EU Commission or the UK.

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 information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We commit to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) to address any privacy-related complaints from you. If you do not receive timely acknowledgment of your privacy-related 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.

3.2 Security

We take appropriate technical and organizational measures to keep your personal information 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 we collect and the need to fulfil your request. Access to your personal information 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.

3.3 Updates

This Privacy Policy is effective as of the date set out above. We encourage you to check this Privacy Policy from time to time. If we change it, we will notify you by posting the updated version of it here. If, however, we intend to use personal information in a manner different from that stated at the time of collection we will post a notice on our Sites for thirty (30) days in advance of such use and, where applicable, we will give you the opportunity to opt out.

3.4 Children

This Site and our Services are not intended to be used by children under the age of 16.

3.5 Third Party Sites

If you access the Sites via a third-party website, we encourage you to read their privacy policy and any terms and conditions to understand how they apply to any personal information you might permit them to share with us. Where our Sites or this Privacy Policy contain hyperlinks to third party websites, you leave our Site when you click through those third- party hyperlinks. We do not control those 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 third-party sites at your own risk.

3.6 Contacts

For the purposes of European data protection law, a data “controller” is responsible for determining why your data is collected and how it is processed. You have certain rights regarding your personal information FreeWheel Media, Inc. processes as data controller. FreeWheel Media, Inc.’s address is 12th Floor, 1407 Broadway, New York, NY 10018. Our company in the European Union (EU) is Comcast International France SAS with offices in France, and our company in the United Kingdom (UK) is Comcast International Holdings UK Limited. You can write to 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. To exercise rights where we are a controller, please email legalnotices@freewheel.tv. For EU and UK purposes, our data protection officer (DPO) can be contacted at dpo@freewheel.com.

2. Services: Your Personal Information When You Are Our Customers’ End User or Authorized Account User

2.1 What FreeWheel Does

Our technology helps companies that publish video content online (through apps, websites and streaming services, including connected TV and “over the top” providers, Publishers and Publisher Content) permit advertising videos to be displayed to their end users (users).

We are also providers of a software platform, customers of which are Publishers wishing to sell their ad space, and Media Buyers (advertisers or their intermediaries wishing to buy or bid for the right have their ads shown in that Publisher’s video ad space). For one specific service we offer to Publishers, known as Managed Service, we may, as a controller, process personal information when purchasing ad space in our own right and when selling on to Media Buyers. Publishers and Media Buyers may also ask us to take audience data into our platform to better target their ad space or ad respectively. We may also provide these Publishers and Media Buyers with related services such as verifying that ads were actually delivered to the user’s device, and other reports such as users’ interaction with the ads.

The digital advertising ecosystem is complex, which means multiple platforms and entities come into contact with online personal information. This Privacy Policy describes the role FreeWheel has in the process, and how we collect, use, maintain, protect and share this personal information. This Privacy Policy does not apply to the privacy practices of other entities involved in the digital advertising ecosytem.

To set up and administer our customer accounts, we handle details of the customer’s authorised account user, generally limited to their name, work contact details, and login in details to provide their authorized access to our advertiser solution platform.

2.2 The Personal Information We Collect

Information We Generate

When you first visit a Publisher’s app, site or streaming service, FreeWheel’s software assigns a unique random identifier to your browser or device (Freewheel ID) which allows our technology to automatically recognise your device or browser next time it is used to access Publisher Content of any Publisher integrated with our technology. This allows our Publishers and partners to “sync” their own unique identifiers against the Freewheel ID so they can use their own data on our platform that they may have associated with your device.

Information We Collect Automatically

When a user views Publisher Content which the Publisher has integrated with our software platform, we, and the partners and vendors we work with, use Cookies and related technologies to collect information about the user and the device they are using when there is advertising space available in relation to the Publisher Content. See 2.8 How We Use Cookies As Part Of Our Services below for more information about Cookies.

This information can include device model, whether the device is using the Apple or Android operating system and its version number, the type and version of the web browser or Publisher app being used to access the Publisher Content (e.g., Chrome or Safari), IP address, referral URL, approximate device location (on a town or city level), mobile device IDs assigned by Apple, Android or other manufacturers of phones and operating systems (such as the IDFA for Apple devices and AAID or GAID for Android devices), the Publisher’s unique identifier (often a “VCID” used in video streaming) for that user or device. Our technology also looks for our Freewheel ID each time a user accesses Publisher Content.

Information Provided By Publishers And Third Parties

Through our Services, we process information about an individual’s interests and preferences, typically relating to demographic details such as age range and gender, product interest, and where legally permitted and with consent where applicable, precise geo-location. This interest and preference information is used to estimate what advertising the individual might be interested in by first placing the individual in one of a number of audience segments (Segments; together with interests and preferences Segment Data). Examples of Segments might be “women aged 18-30 interested in fashion”, “persons aged 25-35 interested in buying a car” and so on. Our Services involve Segment Data when connecting Publishers wishing to sell ad space with Media Buyers (either selected by Publishers or by us depending on the Services), so that ads are delivered in a more relevant and targeted way. Where we provide Services to a Publisher to deliver advertising to their ad space, they may upload their own data relating to their users to facilitate the targeting of advertisements to audiences most likely to be interested in the products or services advertised.

Data Management Platforms (DMP) are technology solutions that pull together data from multiple sources including publicly or commercially available data to identify Segments to be used in targeted advertising. Through use of our Services, a Publisher may direct DMPs within its network (either selected by Publishers or by us depending on the Services) to upload Segment Data to our platform. Media Buyers may also use Segment Data when deciding where to place their advertisements, to help them decide whether they want to purchase (or bid for) a Publisher’s ad space. This is enabled by a process known as “syncing”. We sync by sharing unique identifiers including the Freewheel ID with Media Buyers and any DMPs chosen from the Publisher’s network. The user-related information described above is collectively Platform Data.

Before the Publisher and Media Buyer’s respective data enters the platform to engage in a purchase or bid to purchase ad space event, our Services may facilitate the exchanging of Segment characteristics between the Publisher and Media Buyer; each entity only knows what Segments the other has, and not also the corresponding IP addresses or device IDs.

None of the information we collect or share through the Service in relation to users allows Media Buyers to directly identify an individual. We do not share names, email addresses, or residential addresses as part of providing the Services, and we do not expect any health/ medical, or other sensitive or special categories of personal information to be uploaded to our platform within Segment Data.

2.3 How We Use and Share Your Information

We Use Platform Data As Follows:

We May Also Share Personal Information As Follows:

2.4 FreeWheel’s Role Under EU and UK Data Protection Law

For users in the European Economic Area (EEA) and the UK, we act as controller and processor in the delivery of our Services, depending on the nature of the Platform Data and the processing that is taking place. Where we determine the means and purposes of the processing we act as controller and have legal responsibility under data protection legislation for the processing.

We Are A Controller:

Legal Bases:

We rely on legitimate interests to process Platform Data for anti-fraud purposes, internal reporting and analytics, existing product improvement, and authorised user logon.

We rely on consent for other processing of personal information, including relating to your job application and audience targeting functions.

Where we act as controller, you have a right to request that we:

For EU and UK users in cases where we act solely as controller, 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. For EU and UK purposes, our data protection officer (DPO) can be contacted at dpo@freewheel.com. We will respond to your request within a reasonable timeframe. Please note that we may in some circumstances require that you validate your identity prior to processing your request. If we are unable to process your request, we will provide you with our reasons. If you are located in the EU or the UK, you have the right to lodge a complaint with your local data protection authority about our use of your personal information.

FreeWheel participates in the IAB Europe Transparency and Consent Framework (identification number 285) and complies with its Specifications and Policies.

Please 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. However, please note that because Platform Data doesn’t include the corresponding user’s name or email address, we do not usually have a means to relate a particular request to the device or Cookie IDs we hold.

Where we act as processor, you should address your request to the Publisher(s) in question.

2.5 How Long We Keep Your Information

We will retain Platform Data for as long as we have a legitimate business reason (and for EU and UK end-users where we have a lawful basis under data protection legislation to do so). Generally, we retain Platform Data for up to 18 months from our receiving it. We may retain certain Platform Data for anti-fraud purposes, for instance, for a longer period. See 2.8 How We Use Cookies As Part Of Our Services below for information on Cookie duration.

2.6 United States Residents of California

The California Consumer Protection Act (CCPA) provides California residents with specific rights regarding their personal information. This subsection describes our personal information collection and disclosure practices, and explains how California residents can exercise their rights. These rights apply to all residents of California, regardless of whether you are a consumer or business contact. As a California resident, you have a right not to receive discriminatory treatment, including the right not to be retaliated against, for the exercise of your privacy rights.

To review the number of requests we have received over time and how we have complied with those requests, please view our Individual Rights Requests Annual Report – January 1, 2021 – December 31, 2021.

Notice of California Consumer Data Collection and Sharing Practices

This Privacy Policy includes descriptions of our data collection practices, including the personal information we collect, the sources of that information, the purposes for which we collect information, and whether we sell or share that information to external parties. We may use any of or all the information for any of the purposes described in this Privacy Policy, unless limitations are listed. Some of the categories include very different types of information within the same category and certain personal information may fall into multiple categories. How we use and how long we keep the information within each category will vary and not all types of information within the same category will be used for all of the purposes listed.

California law also requires us to provide information regarding the criteria we use to determine the length of time for which we retain personal information. We use the following criteria: (1) the business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes; (2) whether we are required to retain the information in order to comply with legal obligations or contractual commitments, or retention is otherwise necessary to protect our or others rights; (3) the privacy impact on the consumer of ongoing retention, including the consumer’s likely expectations in light of the sensitivity of the information; and (4) the manner in which information is maintained in our systems and how best to manage the data in light of the volume and complexity of those systems. Individual pieces of personal information such as those listed below may exist in different systems that are used for different business or legal purposes. A different maximum retention period may apply to each use case of the information. For more information about the retention of cookie data, please see click here.

The CCPA requires us to disclose the personal information we have collected about consumers in the past 12 months in the following categories:

We share the above-listed information with service providers and contractors, which are external parties that we engage for business purposes and are restricted from using personal information for any purpose that is not related to our engagement. The categories of service providers and contractors with whom we share information and the service they provide are described in the Privacy Policy.

We may also disclose information to other external parties who are not listed here when required by law or to protect FreeWheel or other persons, as described in this Privacy Policy.

Access to Specific Information and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose to you:

Correction

If we hold personal information that is not accurate, California residents have the right to request that we correct this information.

Deletion

You have the right to request that we delete personal information that we collected from you, subject to certain exceptions. We will delete (and direct our service providers and contractors to delete) your personal information from our records upon receiving your verifiable consumer request, unless an exception applies.

Do Not Sell or Share My Personal Information

On certain occasions, we sell or share information to third parties. The categories of these third parties are identified above in 2.3 How We Use And Share Your Information. An external party may be considered a third party either because the purpose of the disclosure is not an enumerated business purpose under California law, or because our contract does not restrict them from using personal information for other purposes. To “sell” personal information means to disclose it to an external party for monetary or other benefit. To “share” personal information means to disclose to a third party for cross-contextual behavioral advertising. We sell or share the following information:

You have the right to opt out of this sale of your personal information. See 2.8 How We Use Cookies As Part Of Our Services below for more information. We do not have actual knowledge that we sell any personal information of individuals under the age of 16.

Exercising Your Access, Data Portability, Correction, Deletion, and Do Not Sell or Share My Personal Information Rights

To exercise your access, data portability, correction, deletion, and do not sell or share my personal information rights described above, please submit a request to us by either calling us at (888) 930-6228 or sending an email to: FW_California_Consumers_CCPA
_Data_Requests@freewheel.com
.

You are not required to create an account with us in order to make a request. You may also make a request on behalf of your minor child. When making your request, please confirm the nature of your relationship with us and provide an appropriate form of identification to enable us to locate your personal information. If you use an authorized agent to submit an access or deletion request, the authorized agent must provide proof that you gave the agent signed permission to submit the request and their proof of identity.We may also require you to verify your identity directly with us. We will only use personal information provided in a request to verify the requestor’s identity or authority to make the request.

We are not required to provide personal information to you more than twice within a 12-month period.

Please note that, in relation to Platform Data, it is usually the case that we cannot respond to your request or provide you with your personal information because we cannot reasonably verify your identity or authority to make the request: because this data only contains identifiers which are not linked by us to your name, email or residential address or other information which allows us to verify your identity. Therefore, in relation to Platform Data, your request should be submitted directly to our customers. If we deny your request, you have the right to appeal our decision. To request an appeal, you must follow the instructions set forth in the denial.

Right to Limit Use or Disclosure of Sensitive Personal Information

California residents have the right to request that we limit our use and disclosure of certain sensitive personal information to certain limited purposes authorized by California law. To request that we apply this limitation to your sensitive personal information, please submit a request to us by either calling us at (888) 930-6228 or sending an email to FW_California_Consumers_CCPA
_Data_Requests@freewheel.com
.

2.7 Important Information For United States Residents in Virginia

Virginia law provides Virginia residents with the right to access, delete, and correct certain personal information we collect about them, as well as to the restrict the use of that personal information for targeted advertising, restrict the “sale” of that personal information, and control our use of personal information that is considered sensitive. Virginia residents also have a right not to receive discriminatory treatment for the exercise of their privacy rights.

You or an authorized agent may submit a request to exercise your access, deletion, and correction rights by calling us at (888) 930-6228 or sending an email to FW_California_Consumers_CCPA
_Data_Requests@freewheel.com
. To opt-out of targeted advertising and the sale of personal information, or to set preferences regarding our use of sensitive personal information, please submit a request to us by either calling us at (888) 930-6228 or sending an email to FW_California_Consumers_CCPA
_Data_Requests@freewheel.com
. In addition, to manage the automatic sharing of information from our Sites for targeted advertising, you can update your cookie settings by setting your preferences on https://www.freewheel.com/cookie-settings. If we deny your request, you have the right to appeal our decision. To request an appeal, you must follow the instructions set forth in the denial.

2.8 How We Use Cookies As Part of Our Services

Like many companies, we use cookies (small files placed on your computer or device) and other common tracking technologies on the Services, including HTTP cookies, HTML5 and Flash local storage/flash cookies, web beacons/GIFs, embedded scripts, ETags/cache browsers, and software development kits (referred to together from this point forward as “Cookies,” unless otherwise stated). A Cookie will usually contain the name of the website from which the Cookie has come from, the “lifetime” of the Cookie (i.e. how long the Cookie will remain on your device), and a value, which is usually a randomly generated unique number.

In this subsection we provide more information about these Cookies.

Our Services enable our Publisher customers to use information captured through our use of Cookies to enhance the targeting of ads served through the Platform. The Cookie lifespan/duration referred to below may be less than stated where necessary to meet regulatory guidance in specific country locations. Subject to applicable laws, the duration of these Cookies may also be extended when you further interact with Publisher Content.

Cookies We Use When Providing Our Services And Their Duration

Cookie Name Cookie Type Purpose for Cookie / Intended Use of Data Cookie Lifespan / Duration Data Elements Collected by the Cookie Data Recipient
The following relates to the Services we provide to facilitate the purchase or bidding to purchase the advertising inventory of Publishers
Session ID Session Cookie SessionID tells the system that the request is part of a single session by a user. Advertisers would prefer not to show too many of the same ads to the same user in a single session. This Cookie helps prevent that. The Cookie expires at the end of the session and should be removed by the browser. It may be deleted but will be re-issued when another advertisement is requested from the system and deletion may result in repeat showing of otherwise restricted advertisements. Expires at the end of a session Identity code generated by the system FreeWheel
UID Persistent Cookie This is a unique, anonymous browser-identifier that allows us to know that the browser has been seen before. The Cookie is used in the provision of the Services and to help generate statistics to show how many people may have seen particular advertising. The Cookie is valid for one month and may be deleted but will be re-issued when another advertisement is requested from the system. 1 month Identity code generated by the system FreeWheel
OA*CAP et OA*BLOCK Persistent Cookie These types of Cookies tell the system to limit the number of times a browser may see a particular advertisement. The Cookies can be valid for different time periods, depending on the limits of individual advertising campaigns, but are generally valid for between 30 days and 1 year or sooner where relevant regulatory guidance provides for a shorter Cookies expiry period. The Cookies are removed when the campaigns to which they are attached are completed. If the Cookies are rejected or deleted then the limitations on seeing individual advertisements may not be applied correctly. If the Cookies are deleted the limits are re-set and a browser may see more of the advertisements that intended by the advertiser. Between 30 days and 6 months Identity code for the campaign or the creation materialized by a « timestamp » FreeWheel
uid-bp MRM_ UID Persistent Cookie We connect customers to other advertising systems (buying partners) who buy video advertising space. Many of our buying partners need to know their unique identifier for a browser before they place advertisements. Generally, this prevents buyers from showing the same video too many times to a single user across multiple websites. In order to match a buyer’s identifier to our system a synchronization process will set a Cookie (beginning uid-bp-) which contains a user/browser identifier from the buying partner. This identifier can then be used in the advertising process. The Cookies are valid for 1 year or sooner where relevant regulatory guidance provides for a shorter Cookies expiry period. These Cookies may be deleted but will be re-set when the buyer is encountered again. The Cookie contains an identifier set by the buyer’s system. Details of the Cookies from our buying partners can be found on their websites. This data may be used by buying partners to target advertisements. We have no access to this data. 6 months Identity code generated by the system FreeWheel and Demand Partners
Dp- Persistent Cookie If our Publisher partner uses an external provider of data (also known as a Data Management Platform, or DMP) they may provide some of the data to our system to help when selling of advertisements. Our customers can set their own expiration period for this Cookie from 30 days to 1 year or sooner where relevant regulatory guidance provides for a shorter Cookies expiry period. It may be deleted but will be re-issued when a request is made to our system. The data contained is controlled by the marketplace & DMP who will be able to provide more details about the type of data referenced. This data is used to target advertisements. 30 days to a year depending on the provider Link to the reference database FreeWheel and potential data partners of the Publisher
output Persistent Cookie Indicate a user’s opt-out status 50 years
daa_opt_out Persistent Cookie Indicate a user’s DAA opt-out status 10 years
Cookie Name Cookie Type Purpose for Cookie / Intended Use of Data Cookie Lifespan / Duration Data Elements Collected by the Cookie Data Recipient
The following relate to the Services we provide to facilitate the delivery of ads to the Publisher’s ad space
_uid Persistent Cookie User ID 6 years The user id identifying the unique user, across browser session, across network FreeWheel
_sid Persistent Cookie Identifies the browser user session Expires at the end of a session Identifies the browser user session FreeWheel
_stid Persistent Cookie Describes which network the user comes from 6 years Correlates to settings of which scenario eg. CBP, UEX FreeWheel
_ab_test Persistent Cookie Used to split traffic for test Records the test group assignment for A/B test, where some users are exposed to certain product logic while other users are exposed to other or default product logic. FreeWheel
_av Persistent Cookie The Ad View Record 1 month Set when there are frequency cap for ads, update on ad callback defaultimpression FreeWheel
_sav Persistent Cookie Stream Ad View Record Expires at the end of session Set when there are frequency cap for ads at the stream level, update on ad callback default impression FreeWheel
_asav Persistent Cookie Ad View Record for Freq. Cap pre-assets for ads 1 month Set when there are frequency cap for ads at the pre-asset level, update on ad callback default impression FreeWheel
_ssav Persistent Cookie Ad View Record for Freq. Cap per site section for ads 1 month Set when there are frequency cap per site section for ads -asset level, update on ad callback default impression FreeWheel
_auv Persistent Cookie Ad Unit User tracking 1 month This Cookie keeps track of the ad unit user have last seen and the content(video asset) duration since then. the record is on a per website root base FreeWheel
_cv Persistent Cookie Creative Rotation Cookie 1 month The Cookie served as a creative rotation states indicator, one record mean for 1 creative, its last appearance is the nth in the rotation sequence FreeWheel
_cvr Persistent Cookie Commercial View Ratio 1 month This Cookie records users user experience record by user session(per website). the n_content and n_commercial value keeps track of UEC by video plays. and content_duration and commercial_duration are used to calculate user commercial view ratio FreeWheel
_pr Persistent Cookie Page Advertisement History Tracking 1 month This Cookie is turned on by adserve capaility which records every ad that delivered in page and serve as a source of exclusivity filter FreeWheel
_vr Persistent Cookie Video Advertisement History Tracking 1 month This Cookie is turned on by adserve capaility which records every video ad that delivered and serve as a source of exclusivity filter FreeWheel
_cph Persistent Cookie Commercial Pattern Cycling 1 month records the last pattern that current user’s ad request has used, identified by pattern_group_id, so next time when user’s request need to apply commercial pattern in the same pattern group which is in cycling mode, ads could decide which pattern to use, and update this Cookie accordingly FreeWheel
_sc Persistent Cookie Section Context for UEX for Wall Clock time 1 month this Cookie records all user sessions on different FW enabled site and renew on return to any of them. the ttl is the session duration customer has set on UI, the content_time and commercial_time is the duration elapsed FreeWheel
_wr Persistent Cookie Indicator of current active website in user session for UEX and CBPs. 1 month this is for the Cookie update on callbaks, like, _auv, _sc, etc… since most callbacks don’t echo back site_section context FreeWheel
_ue Session Cookie User Exchange for audience data Expires at end of session log the data provider id when it has user attribute ingest, ads doesnot accept the ingest from same data provider in the same session FreeWheel
_ul Session Cookie ads used the user attribute stored on Cookie for the ad request transaction Expires at end of session User attribute targeting and logging FreeWheel
_ro Session Cookie Testing Purposes for Tear Sheeting Expires at end of session This Cookie passes several attribute in key value pairs for overriding ad server request attributes, mainly for testing purpose, e.g, fake IP, Geo Location, Tearsheeting ads FreeWheel
_ha Session Cookie Historical Ads Tracking Expires at end of session This Cookie is used to tie into Ad Exclusivity across multiple requests FreeWheel
_ss Session Cookie Slot Sequencing for Ad Pod Targeting Expires at end of session Used to record slot sequencing to allow ADS to shuffle ad pod targeting FreeWheel
_drh Session Cookie Display Refresh History for Display Ads Expires at end of session This Cookie stores ad history in each display slot, when site section/group has display refresh configuration. Following display refresh requests will not have the same ads delivered. FreeWheel
daa_opt_out Persistent Cookie Indicate user’s opt-out status 5 years FreeWheel
opt_out Persistent Cookie Indicate user’s opt-out status 5 years FreeWheel
_fwex_ Persistent Cookie 3rd party Ad Server Cookie saved under FW domain Determined by 3rd party ad server 3rd party server Cookie will store under FW domain. A whitelist in oltp table lu_system_variable where column name=”global.allowed_proxy_cookie_domains”, now only doubleclick.net in this whitelist FW response to video player set Cookie as following: Set-Cookie: _fwex_<3p server domain>_=; expires=<3p expires>; domain=.fwmrm.net; path=/; An example of the co-kie name: _fwex_doubleclick.net_id 3rd party Ad Server, Currently only Google

2.9 Opting Out of Targeted Advertising

If you opt out of targeted advertising, you will still see advertising, but it may be less relevant.

Online Behavioural Advertising:

We have elected to participate in the Digital Advertising Alliance (DAA) and the EDAA so you can elect not to receive targeted advertising from FreeWheel customers and other companies. You should check these links to understand which companies are engaged in targeted advertising and opt out if you wish to.

Desktop:

Click here to opt out of FreeWheel’s Services Cookies. If you choose to opt out of our Cookies, you will be opted-out for all of the customers that use our Services, which means ads delivered to your browser on behalf of our customers using our ad-serving technology will be re-served based only on the device information that is automatically transmitted in the Internet environment (i.e., no name, email or other details are involved that would directly identify the end-user). The 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 information provided by the Site or customer such as data reflecting you have opted out of our Cookies being dropped on your device. Please note if you use the above link to opt out of our Cookies, we use a Cookie to store this opt out preference which means 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 to restore your opt-out preference.

Mobile Devices:

To opt out of certain targeted advertising on your mobile device via your device’s identification number, follow the instructions below:

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, either opt out of targeted advertising on your mobile device as described above, or turn off Location (note this may impact other functionality).

3. Site Visitors and Services: Additional Common Information

The following concepts also apply to the processing of personal information referred to in Sections 1 and 2:

3.1 International Transfer of Information

Our primary data centres are located in Europe (UK, Germany, France and Netherlands), Singapore, and the USA. We comply with all applicable laws to protect the security of data during international transfer, for instance by using EC standard contractual clauses and appropriate supplementary measures when a transfer is made to a third party country that is not considered adequate by the EU Commission or the UK.

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 information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We commit to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) to address any privacy-related complaints from you. If you do not receive timely acknowledgment of your privacy-related 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.

3.2 Security

We take appropriate technical and organizational measures to keep your personal information 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 we collect and the need to fulfil your request. Access to your personal information 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.

3.3 Updates

This Privacy Policy is effective as of the date set out above. We encourage you to check this Privacy Policy from time to time. If we change it, we will notify you by posting the updated version of it here. If, however, we intend to use personal information in a manner different from that stated at the time of collection we will post a notice on our Sites for thirty (30) days in advance of such use and, where applicable, we will give you the opportunity to opt out.

3.4 Children

This Site and our Services are not intended to be used by children under the age of 16.

3.5 Third Party Sites

If you access the Sites via a third-party website, we encourage you to read their privacy policy and any terms and conditions to understand how they apply to any personal information you might permit them to share with us. Where our Sites or this Privacy Policy contain hyperlinks to third party websites, you leave our Site when you click through those third- party hyperlinks. We do not control those 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 third-party sites at your own risk.

3.6 Contacts

For the purposes of European data protection law, a data “controller” is responsible for determining why your data is collected and how it is processed. You have certain rights regarding your personal information FreeWheel Media, Inc. processes as data controller. FreeWheel Media, Inc.’s address is 12th Floor, 1407 Broadway, New York, NY 10018. Our company in the European Union (EU) is Comcast International France SAS with offices in France, and our company in the United Kingdom (UK) is Comcast International Holdings UK Limited. You can write to 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. To exercise rights where we are a controller, please email legalnotices@freewheel.tv. For EU and UK purposes, our data protection officer (DPO) can be contacted at dpo@freewheel.com.