Privacy Policy

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This privacy policy (the “Policy”) describes the privacy practices of BrightRoll, Inc. (“BrightRoll,” “we,” “our,” or “us”) with respect to online video advertising services and the data collection and use practices of this web site: sandbox.brightroll.com. BrightRoll’s video advertising network (the “Network”) provides agencies and advertisers with access to large pools of ad inventory across our pool of high-quality, brand-safe websites. The BrightRoll Exchange (“BRX”) is a self-service, online video ad-buying platform that provides buyers with efficient and transparent access to video inventory with unmatched scale, efficiency and return on investment. This Policy describes how we, our subsidiaries and affiliate companies, collect, use and disclose information in connection with our operation of the Network, BRX, and the BrightRoll Website. The collection, use and disclosure of information by BrightRoll Network/BRX sites is governed by the privacy policies and practices of the BrightRoll Network/BRX sites and their operators; BrightRoll does not control such policies and practices.  

BrightRoll, Inc. has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's web privacy & TRUSTed Data Program, including transparency, accountability and choice regarding the collection and use of your personal information.  The TRUSTe program covers only information that is collected through the Network, BRX and this website and does not cover data collected by mobile devices. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy Trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at privacy@brightroll.com.  If you are not satisfied with our response you can contact TRUSTe here[JB2] . BrightRoll controls and operates its business from within the United States of America. Our online privacy practices are governed by the federal and State laws of the United States of America, which may differ from privacy laws in your state or home country. By submitting your personal information to us or our agents, through the use our online video advertising services, the Network or BRX you consent to the transfer of your personal information to any country and its use and disclosure in accordance with applicable U.S. federal and State laws and with this Policy. BrightRoll does not collect personal information regarding users for use in delivering ads via the Network or BRX, but does collect and use certain types of anonymous information for this purpose.

This policy covers the following areas in detail:
What Data We Collect and How We Collect It
Personally Identifiable Information (PII)
Cookies & Tracking Pixels
Opt-out
Mobile Opt-out
Third-Party Data Collection
Tracking Pixels
Other Information is Collected
What Data We Use and How We Use It
What Data We Disclose and Who We Disclose It To
Third-party Information Gathering
Correspondence
Sharing of Information
Changes to BrightRoll's Corporate Structure
Retention
Choice
Notice to California Residents – Your California Privacy Rights
Children’s Privacy
Changes to Privacy Policy
Security
Effective Date
Questions and Comments

What Data We Collect and How We Collect It
Non-Personally Identifiable Information. BrightRoll may collect anonymous data while you are visiting a BrightRoll website or the website of one of BrightRoll’s business customers, including advertisers and web publishers (collectively “Business Customers”). These anonymous data include information such as your IP address, search queries, web pages which have been viewed by you, ads viewed or interacted with by you, date and time, domain type and responses by you to an advertisement delivered by us or a third-party advertising technology vendor. We may also collect information about the mobile device you use to access the website, including the hardware model, operating system and version, unique device identifiers and mobile network information. Additionally, we may also collect information about your location each time you access or use one of our mobile applications or when you authorize your web browser to collect this information when you visit the websites. We and/or a third-party advertising technology vendor may use different types of technologies to collect this type of information, including cookies and pixels (see “Cookies” and “Pixels” below). In addition, as a part of the registration process, on our website for marketing materials or if you are a buyer signing up on the exchange for our services,  you may provide us with additional non-personally identifiable information. Examples of the non-personally identifiable data that may be provided with your consent would include age, gender and interests. None of the foregoing information (collectively referred to as “non-personally identifiable data”) by itself, or together, can by its nature be tracked to a specific individual’s personally identifiable information. You may elect not to allow us to use anonymous data by following the Opt-Out procedures set forth below in the “Choice” section.

Personally Identifiable Information (PII).
We do not collect any personally identifiable information regarding users for use in delivering ads via the Network or BRX. The IAB (Internet Advertising Bureau), which is a trade association for the internet marketing industry, defines personally identifiable information as, “information that can be traced back to a specific user and provide personal information such as name, address, phone number, etc.” In other words, it’s information about you that can identify you as a person rather than an anonymous profile.

As a member of the Network Advertising Initiative, BrightRoll does not collect or use data about health conditions or treatments for ad targeting.
With respect to our ad delivery capabilities, all of our profiles are anonymous and relate to a computer or mobile device rather than a specific user. For us, they are nothing more than a number with which we associate interests and/or an estimated or inferred demographic profile.

On our wholly owned websites we do not ask for personally identifiable information, other than outlined below for business purposes. BrightRoll will use commercially reasonable efforts to urge our partners to provide appropriate notice and an opt-out option to all consumers. When using such websites you will be subject to separate privacy policies, which you should review.

Cookies. 
We collect non-personally identifiable information through the use of cookies. A cookie is a small text file containing a string of characters that is placed by an Internet server on your hard drive. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. We use persistent cookies to store the non-personally identifiable information described above, and to store inferences we make based on that non-personally identifiable information about what a user’s interests might be. Most web browsers are initially set up to accept cookies, but you can change your web browser settings to cause your browser to refuse cookies or to indicate when a cookie is being sent. You can remove and/or disable cookies by following directions provided in your Internet web browser’s “help” file or menu. Please be aware, however, that some aspects of a Network/BRX site may not function properly if cookies are disabled.

The BrightRoll cookie does not harm your computer in any way or provide us with any information about your identity. The BrightRoll cookie is not spyware or adware. The general definition of spyware/adware is that of a software package installed on your computer for purposes of monitoring all your Internet or general computer activity. We do not install software of any kind on your computer and have no ability to monitor or track your general computer or overall Internet usage. Cookies can be easily avoided by opting out from them or by adjusting your browser settings. Cookies traditionally expire after 30 days, while data collected for advertising purposes is kept for no longer than 2 years.

Opt-Out.
 
You can also opt-out of the collection of data through cookies by following the instructions in the “Choice” section of this Policy below.

Mobile Opt-out. 
BrightRoll has partnered with TRUSTe to provide an industry leading, in app Opt-out for interest based ads. To Opt-out of BrightRoll's interest based advertising, download the appropriate TRUSTe Ad Privacy Manager application for your device's operating system below and opt-out of your desired ad provider:
Android Ad Privacy Manager
iOS Ad Privacy Manager

Tracking Pixels. 
We also collect non-personally identifiable information through the use of tracking pixels. A tracking pixel is a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a web page and, in combination with a cookie, allows for the collection of information regarding the use of the web page that contains the tracking pixel. We use tracking pixels to tell when an advertisement has been clicked on or otherwise interacted with, and use that information to judge which advertisements are more appealing to users. In some cases, we use third-party service providers to help us collect and analyze this information.

Third-party Data. 
We also receive non-personally identifiable information regarding user demographics and preferences from the operators of Network/BRX sites who choose to provide it to us, as well as from third-parties who collect and make available such non-personally identifiable information for advertisement-serving purposes. Please review the “Choice” section of this Policy below for instructions on how to opt-out of having anonymous information collected by these parties.

BrightRoll seeks to work only with Network/BRX site operators and other third-parties who comply with all applicable privacy laws with respect to activities that relate to their relationship with us, but ultimately does not have control over such third-parties.

Other Information that is Collected. 
At some BrightRoll websites, including this one, BrightRoll collects personal information on individuals and companies who want to enter into business relationships with BrightRoll, such as name, email address, phone number and company name (“business information”). An example of this would include web publishers who want to become a part of BrightRoll’s web network. We maintain business information for purposes of administering the program, such as maintaining account information, sending payments, etc. We may share business information with third-parties who provide administrative services (and they are required to maintain the confidentiality of the information). We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request and to any other third party with your prior consent to do so. If a consumer elects to provide BrightRoll with personally identifiable data, we may utilize such data for BrightRoll marketing purposes. In addition, that data may be combined with information collected from other sources to better serve consumers with offers that may be of interest to them. For example, you may fill out an online employment application or register for a newsletter and provide us with your email. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in those emails. BrightRoll, or a contracted third party, may also collect and/or maintain personally identifiable data from users while viewing a BrightRoll ad, on behalf of an advertiser or their agency. For example, a user may sign up for a special offer, request a brochure or newsletter, or participate in a brief survey while viewing a BrightRoll ad. As a result of such actions, the user might supply us with information such as their name, address, phone number, e-mail address, and personal shopping and product preferences. In all cases, data will be either passed directly to the advertiser or agency without being stored by BrightRoll or a contracted third party, or data will be stored in an isolated database that will never be merged with any other data in our systems.

 

If a consumer elects to provide us with personally identifiable data, he or she has the right to tell us not to make use of such data described herein or to inquire what personally identifiable data is retained or may have such data deleted in its entirety at any time. Simply contact us and provide the name of the service for which you provided information and let us know what level of opt-out you would like to exercise. These include: (1) Do not share information about me with business partners, (2) Do not solicit me with special offers other than those related to the service I signed up for, or (3) Remove my data from your database for such service completely. Once we receive this instruction, we will promptly take corrective action. Please note that we will need you to provide your email address or other previously provided personal identifier in order to identify you in the data opt-out process. Also, please remember that if you choose to delete your information completely you will no longer receive the service in question. You can contact us at privacy@brightroll.com or Privacy Officer, BrightRoll, Inc., 343 Sansome Street, Suite 600, San Francisco CA 94104.

What Data We Use and How We Use It
We use non-personally identifiable information for purposes of displaying advertisements to users that are more likely to be relevant to them than what we would be able to display without the use of such information. For example, if we have non-personally identifiable information that a user recently searched for laptop computers, we may use that information to decide to display an advertisement for a new laptop computer when that user requests a video on a Network/BRX site. Keep in mind that at no time do we know the name, address, phone number or other personal information of the user – the non-personally identifiable information we know relates only to the IP address and the recent activity of the web browser software to the extent that cookies are enabled in that software.

If requested by an advertiser, we may also use non-personally identifiable information to determine whether to serve an advertisement to a user and which advertisement to serve. For example, we may use a cookie to note whether a given advertisement has already been viewed by a particular user so that our server will not deliver the same advertisement a second time. If an advertiser wants us to deliver a series of advertisements in a particular sequence, we may use a cookie to note that the first advertisement has been delivered to a particular user so our server knows to deliver the second advertisement in the series when that user next visits a Network/BRX site.

We also use non-personally identifiable information to analyze usage of and improve our advertising services. In some cases, we use third-party service providers to assist us with such analysis.

What Data We Disclose and Who We Disclose It To
The non-personally identifiable information we collect and receive is provided to third-party service providers that assist us in running our business, including providers of data storage and processing facilities. We also provide aggregated, non-personally identifiable information regarding Network/BRX site and advertisement viewing and usage to Network/BRX site operators, advertisers and other third parties (such as comScore and other analysts) in order to report the performance of advertisements displayed through use of our services.

Third-party Information Gathering. 
We may allow third parties to serve advertisements on our behalf and to provide analytics services. These third parties may solicit personal information from you, use cookies, web beacons and other technologies to collect information about your use of the Network/BRX site, our website and other websites. This information may be used by BrightRoll and third parties to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on websites and better understand your online activity. For more information about each third-party content provider, cookies, and how to “opt-out,” please refer to such third-party advertiser’s privacy policy, aboutads.info/choices, or visit networkadvertising.org/choices. Our website may contain links to and from other websites on the Web. Please be aware that we are not responsible for the privacy practices of such other websites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every website that collects personally identifiable information. This Policy applies solely to information collected by BrightRoll.

Correspondence. 
If you contact us, we may keep a record of that correspondence and we may collect your email address.

Sharing of Information. 
We may share information about our users, including PII, with third party vendors, consultants and other service providers who need access to your information to carry out work on our behalf. We may also share information if we believe disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, to enforce applicable user agreements or policies, and to protect BrightRoll, our users or the public from harm or illegal activities.

Changes to BrightRoll’s Corporate Structure. 
Information about our users, including PII, may be disclosed as part of, or during negotiations of, any reorganization, restructure, merger, acquisition, or sale of company assets, as well as in the unlikely event of an insolvency, bankruptcy or receivership in which PII would be transferred as one of our business assets.

Retention
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Most of our cookies traditionally expire after 30 days and the longest they would be kept for is 2 years.

De-identified, aggregate data is kept indefinitely for reporting purposes within our database. This data does not identify an individual.

Choice
Since BrightRoll does not collect personal information from users across our Network or BRX, we are not able to relate any non-personally identifiable information in our possession to any specific individual. We are therefore unable to respond to requests from a particular individual to delete any non-personally identifiable information regarding such individual that BrightRoll may have. Please consult your web browser’s “help” file or menu for instructions on how to delete any cookies that may be placed by BrightRoll on your hard drive.

You may opt-out of the use of BrightRoll cookies for purposes of delivering more relevant advertising by clicking here or on the “Opt-Out” link at the bottom of this page. This will set an opt-out cookie on your browser that notifies our servers that no other BrightRoll cookies should be sent. This will opt you out of both collection & targeting from BrightRoll cookies. It should be noted that opting out does not mean you will not see BrightRoll advertisements online, but these advertisements will not be targeted based on your online user interest profile from us as an individual vendor. Anonymous segmentation data will still be collected by other third parties, but not used by BrightRoll for targeting. You can opt-out of receiving cookies from certain third-party partners who are members of the Network Advertising Initiative, as described above under the heading “Third-party Data,” by going to networkadvertising.org/choices/ and following the instructions.

Please note that if your change your computer, change your web browser, or delete your cookies, you will need to renew all of your opt-out choices.

Notice to California Residents – Your California Privacy Rights
The State of California enacted the Shine the Light law (California Civil Code Section 1798.83) that permits users who are California residents to request certain information regarding the disclosure of personal information during the past year for marketing purposes. To make such a request, contact privacy@brightroll.com or Privacy Officer, BrightRoll, Inc., 343 Sansome Street, Suite 600, San Francisco CA 94104.

Children’s Privacy
BrightRoll is very sensitive to the issue of children’s privacy. BrightRoll’s websites, products and services are neither developed for, nor directed at, children under the age of 13. BrightRoll does not knowingly collect personally identifiable information from children under 13 and we will promptly delete any information related to children, once brought to our knowledge. At times, persistent identifiers are used for internal operations and optimizations, but never for behavioral targeting.

If you believe your child has provided BrightRoll with personally identifiable data, or registered at one of BrightRoll’s websites and you would like to have the data removed, please contact privacy@brightroll.com or Privacy Officer, BrightRoll, Inc., 343 Sansome Street, Suite 600, San Francisco CA 94104.

Security
BrightRoll uses commercially reasonable physical, organizational and technical safeguards to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to BrightRoll and you do so at your own risk. Once we receive your transmission of information, BrightRoll makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you have any questions about security measures we use to protect information, you can contact us at privacy@brightroll.com

Changes to Privacy Policy
We may change this Policy from time to time. If we make changes, we will notify you by revising the effective date stated in the Policy and, in some cases of material change, we may provide you with more prominent notice (such as adding a statement to our homepage or sending you an email notification). We encourage you to review the Policy whenever you access the website to stay informed about our information practices and the ways you can help protect your privacy.

Effective Date
This Policy was last revised on July 2, 2013.

Questions and Comments
Questions and comments about our Policy should be directed to privacy@brightroll.com or mailed to Privacy Officer, BrightRoll, Inc., 343 Sansome Street, Suite 600, San Francisco CA 94104.