Privacy Policy

Last Updated: October 25, 2023
Effective: October 25, 2023

Introduction

Brand Networks, LLC (“Brand Networks,” “we,” or “us”) owns and operates the Brand Networks website and proprietary client-facing software platform (the “Sites”) and provides advertising technology services (the “Services”) to companies that engage us to perform services on their behalf (our “Clients”). Our Sites and Services enable Clients to plan, optimize, and automate advertising campaigns on social media, websites, and mobile apps; target advertising to specific audiences based on users’ online activities across websites, mobile apps, and linked devices; and gain insights about the performance and effectiveness of their advertising campaigns, as described further in this Privacy Policy.

This Privacy Policy describes:

• What data we collect through our Sites and Services;
• How the data collected through our Sites and Services is used;
• When and with whom data collected through our Sites and Services is shared;
• How we protect and retain data; and
• Your choices regarding our use of your data.

We encourage you to read this Privacy Policy and our Terms of Use carefully. We will post notices of all changes that materially affect the way in which your data may be used or shared in updates to our Privacy Policy, as described at the end of this Privacy Policy.

This Privacy Policy does not apply to the practices of the Clients for whom we provide the Services, nor does it apply to those third-party advertising systems, exchanges, networks, websites, or mobile applications that Brand Networks has a relationship with, including but not confined to social media platforms such as Facebook, Twitter, LinkedIn, Instagram, Pinterest, and SnapChat (the “Social Platforms”), as well as advertising technology partners such as The Trade Desk and Tapad (the “Inventory and Data Partners”) or of other companies or individuals that Brand Networks does not own, employ, manage or control.

If you have any questions about this Privacy Policy, please feel free to contact us through the “Contact Us” links on our Sites, by emailing us at info@bn.co (please include “Attn: Privacy” in the subject line), or by writing to us at: Attn: Privacy, Brand Networks, LLC, 101 Arch Street, 8th Floor, Boston, MA 02110.

Our Services

Information Collected through Our Services
We collect a variety of information through our Services, including, for example:

• Data that we receive from our Clients, including:
  • User IDs, such as Apple’s Identifier for Advertisers (IDFA), Google’s Advertising ID (AD-ID), Social Platform user IDs, or obfuscated (g., hashed) email addresses or user names;
  • Information about a user’s activities on our Client’s websites and mobile apps and customer segment information from the Client regarding users’ inferred commercial interests, including information based on which users have seen specific ads, or viewed content online;
  • Other demographic or inferred-interest information that a Client may have in its customer relationship management database, such as information based on whether a customer has purchased products or services from the Client in the past; and
  • Aggregated insights into users’ activities on the Client’s websites and mobile apps and demographic information associated with customer segments of interest to the Client, which we or our Clients may collect using third-party analytics providers as described in the section below titled “How We Share Information Collected through Our Services.”
  • Data that we receive from Social Platforms where we display advertising on behalf of our Clients, including:
  • Social Platform user IDs, such as users’ Twitter handles;
  • Aggregated information about users who interact with certain games, features, or other applications on Social Platforms where we might serve an ad (though not associated with User ID); and
  • Aggregated reporting on demographic information and the number of Social Platform users that have received specific ads through Brand Networks on behalf of our Clients, which we may collect directly from the Social Platform or by using third-party analytics providers as described in the section below titled “How We Share Information Collected through Our Services.”

• Data that we receive from our Inventory and Data Partners, including:
  • A unique, persistent identifier that is stored in a cookie that is placed by our Inventory and Data Partners (e.g., cookie ID). A cookie is information that is stored on your computer that can uniquely identify your browser;
  • Mobile advertising ID (such as AD-ID or IDFA);
  • Information regarding how a particular computer, browser, or mobile device may be linked to other computers, browsers, or mobile devices used by the same person or household (including the cookie IDs and mobile advertising IDs that seem to be related to the cookie ID or mobile advertising IDs on the device being used). These linkages are based on inferences made by our Inventory and Data Partners, including Tapad;For example, we or our partners may determine that a particular browser or mobile device is linked to another computer, browser, or mobile device used by the same person or household, and we may use information collected from one computer, browser, or mobile device to deliver ads or measure the effectiveness of ads on other, linked devices. If you would like to opt out of our Inventory and Data Partners’ use of collected data for cross-device linking purposes, please see “Opt Out of Interest-Based Advertising” below; and
  • Aggregated data regarding the ads we deliver for a specific Client’s advertising campaigns and how users responds to those ads, as measured by our Inventory and Data Partners using pixel tags (which are small, invisible images that are placed on webpages or in ads that allow our partners to understand whether a user has viewed an ad), ad server logs, SDKs, and related ad reporting technologies.

What is NOT collected by Brand Networks through our Services for targeted advertising, cross-device linking, or analytics purposes:

• Information that could be used to directly identify you, such as name, email address, phone number, and postal address in a format that is identifiable to Brand Networks. However, we may receive obfuscated forms of this data (g., “matching IDs”) from our Clients for the purpose of helping our Clients and Inventory and Data Partners understand which of the Client’s existing customers or otherwise known user IDs match data that we or our Inventory and Data Partners have collected from other sources.
• Information that we consider sensitive, such as:
• Information about any past, present, or potential future health or medical conditions or treatments, including genetic, genomic, and family medical history, based on, obtained, or derived from pharmaceutical prescriptions or medical records, or similar health or medical sources that provide actual knowledge of a condition or treatment (g., if the source is sensitive);
  • Information, including inferences, about sensitive health or medical conditions or treatments, including, but not limited to, all types of cancer, mental health-related conditions, and sexually transmitted diseases (g., if the condition or treatment is sensitive regardless of the source);
  • Information revealing a user’s sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership;
  • Government identifiers, financial account information, or insurance plan numbers;
  • Precise location (g., stored latitude/longitude coordinates that contain more than two decimal places or a geographic area with a radius of less than 500 meters), without your affirmative express consent to such collection or use; and
  • Use of, or interest in, gambling, alcoholic beverages, or “adult” products or services.
• The Brand Networks Sites and Services are not directed to children under the age of 13, nor do we knowingly collect personal information from children under the age of 13 or through any online services that are directed to children, as those terms are defined in the Children’s Online Privacy Protection Act.

How We Use Information Collected through Our Services
We may use information collected through our Services for a variety of purposes, including:

• To determine the demographic characteristics of users that our Clients would like to advertise to;
• To infer users’ likely commercial interests and demographic information, such as inferring that a user is a sports enthusiast based on the fact that the user viewed sports-related content;
• To evaluate the performance and effectiveness of advertising placed on behalf of a Client;
• To build aggregated insights about marketing trends for our own internal use and to report such trends to third parties, such as our partners, prospective Clients, or the media;
• To evaluate, through our partnership with Tapad, the probability and nature of connections between devices, including to understand which computers, browsers, or mobile devices are likely to be owned or used by the same person or household (g., computers, browsers, or mobile devices that are linked to the current device being used) for the purpose of delivering ads and measuring the effectiveness of ads across linked devices;
• To determine whether to deliver an advertisement to a user on web pages and mobile apps where the user is browsing, based on the user’s inferred commercial interests and/or the user’s demographic characteristics, as determined by us, our Inventory and Data Partners, or based on data from third-party sources; and
• To provide insights, facilitate ad delivery, and provide reporting back to Clients and partners, including statistical reporting in connection with the activity on a website or mobile app, optimization of location of ad placement, ad performance, reach and frequency metrics, billing, and logging ads served on a particular day to a particular website or application.

How We Share Information Collected through Our Services
We may share information that we collect through our Services with certain third parties, including:

• To share aggregated reporting data with our employees, Clients, and Social Platforms regarding the scope and effectiveness of advertising campaigns that we manage or deliver on behalf of our Clients;
• To share information with our Inventory and Data Partners, including Tapad, to help our Inventory and Data Partners determine the other computers, browsers, or mobile devices that may be linked to the user’s current computer, browser, or mobile device;
• To allow third-party analytics providers to collect information in connection with the Services, such as to determine whether a user has seen or clicked on an ad. These third parties may set and access cookies on users’ computers or other devices and may use web beacons to collect information about users’ activities. In particular, we or our Clients may use Google Analytics and Adobe Analytics to help collect and analyze certain information for these purposes. Users may opt out of the use of cookies by Google Analytics here and by Adobe Analytics here;
• To share aggregated information with other third parties, such as by publishing reports on trends in the usage of our Services with prospective clients or the media;
• In the normal course of business, Brand Networks may also share information with individuals (such as employees and contractors) or our service providers to perform tasks on our behalf;
• We may be required to share information for legal purposes, including in response to a regulation, court order, subpoena, or other legal process, when we believe it’s necessary to comply with the law, to respond to a government request, when we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Brand Networks, our customers, or others, to prevent harm or loss, or in connection with an investigation of suspected or actual unlawful activity; and
• We may share information collected through the Services in the event of a corporate sale, merger, acquisition, dissolution, bankruptcy, or similar event.

Our Sites

Information Collected on Our Sites
We also collect a variety of information on our Sites, including:

• Information You Give Us. When a Site user creates an account or requests to access certain materials or to contact Brand Networks, we may ask the user for certain information such as name, phone number, email address, geographic location (including city, state/province, country, and zip/postal code), age and birth date/year, and gender. We use this information to contact or identify the user. Site users can choose not to provide us with any or all of the information we specify or request, but then the user may not be able to register with us or to take advantage of some or all of the features on our Sites.
• User-generated Content. Site users may upload or create content on the Services, such as text or image files or other media (“Content”), which may be displayed to us and other authorized users along with associated metadata such as date, location, and time created. As with any profile information, Site users should exercise caution when uploading or creating Content that will be available to the public through Social Platforms or Inventory and Data Partners. We restrict use of the Sites to individuals age 18 and above and do not knowingly seek or collect information or Content from anyone under the age of 18.
• Automatic Information Collected. Like many other websites, we also collect information through cookies and other automated means. Information of this sort includes:
  • Technical information about a Site user’s browser and mobile device: This information, such as browser or operating system type and version, is used in the aggregate to help us optimize the Sites for common browsers and devices.
  • Site and email usage information, such as the features and emails from Brand Networks that Site users interact with, the emails that they open, and whether a user visits our Sites: We may use this information to generate statistics about users and understand how the Sites are being used, and to facilitate targeted communications and advertisements. Please see “Third-Party Analytics and Interest-Based Advertising on the Sites,” below, for further information and choices about how we use and share information with third parties for such purposes.
  • IP address and log file information, web beacons, cookies, tokens, and device identifiers: These are alphanumeric identifiers that help us to distinguish between unique browsers and devices in order to avoid showing Site users the same information multiple times, keep users logged into the Sites, prevent duplicate actions, prevent duplicate coupon redemptions, and improve our users’ experience. The information we collect from cookies may include the Site user’s IP address, browser and device characteristics, referring URLs, and a record of the user’s interactions with our Sites. By using the Sites, users are consenting to such use of cookies. Most Web browsers can be set to inform the user when a cookie has been placed on the browser and provide the user with the opportunity to refuse that cookie. We will respect your choices if you choose to reject individual cookies or set your web browser to reject cookies, but please note that refusing a cookie may, in some cases, preclude the Site user from using, or negatively impact the display or function of, the Sites or certain areas or features of the Sites.
  • Crashes and error reports: If a user encounters a crash or error while using our Sites, we may generate a crash report that includes technical, usage and, if the user is logged in, account information so that we can diagnose and potentially prevent the problem in the future.
• Information Collected from Other Sources. We may also periodically obtain information about Site users from our Clients, contractors, and other third parties. For example, we may receive the username and email address of our Client’s employees or agents to help identify the employees or agents and obtain access to their Social Platform accounts, which allows us to manage advertising campaigns on the Social Platform on behalf of our Clients.

How We Use Information Collected on Our Sites
We use the information we collect on our Sites for a variety of purposes, including:

• To establish and manage Site users’ accounts, provide the Sites, and communicate with Social Platforms, Inventory and Data Partners, and Clients;
• To conduct research and analysis, including to perform Site analytics, enhance Site navigation, improve our web design and functionality, count and recognize visitors to the Sites, and better understand how users access and use our Sites and our products and services;
• To tailor the content, information, and advertising that we may display to you, including as discussed below in the section titled “Third-Party Analytics and Interest-Based Advertising on the Sites”;
• To identify users on the Sites and communicate with users regarding important account information, surveys, and promotional offers; and
• To operate, evaluate, and improve our business and our Sites and to develop new products and services.

How We Share Information Collected on Our Sites
We share information collected on our Sites with third parties, including:

• With Clients. We provide Site users’ profile information and usage data (such as what purchases users have made on the Sites) to the Client linked to the user’s account, and may also share Site users’ Content with the Client depending upon the Client’s settings on the Sites. By using the Sites, users authorize us to provide this information to the Client, and understand that we will not be responsible for Client treatment, usage, or protection of such information. The use of this profile and usage information by the Client, as well as any information that a user directly provides to such Client, is governed by the internal policies of the Client and is not subject to our control.
• With Social Platforms and Inventory and Data Partners. We may share a Site user’s Content with designated Social Platforms and Inventory and Data Partners when the user tells us to. When Site users share Content with Social Platforms and Inventory and Data Partners, whether directly or through the Sites, the Content becomes subject to the terms of use and privacy policies of the Social Platforms and Inventory and Data Partners, which we encourage users to review and understand.
• With Service Providers. In the normal course of business, Brand Networks may also share Site users’ information with individuals (such as employees, contractors and lawyers) and companies (such as consultants and providers such as a push notification delivery service) to perform tasks on our behalf and may need to share certain information with them in order to provide products or services to our Site users. However, our service providers do not have any right to use the information we share with them beyond what is necessary to assist us in providing the services to our Site users as described in this Privacy Policy.
• With Our Third-Party Analytics and Interest-Based Advertising Partners. We allow our third-party analytics and interest-based advertising partners to collect certain information on the Sites, as described below in the section titled “Third-Party Analytics and Interest-Based Advertising on the Sites.”
• Through Third-Party Plugins on the Sites. We may integrate third-party plugins into our Sites in order to personalize Site users’ experience or offer chat features. Even if a Site user does not click on these plugins, they may collect information about the user, such as IP address and Site pages viewed. They also may set and/or access a cookie. This Privacy Policy only covers the use of cookies by Brand Networks. Cookies placed by third-party plugins or services are governed by the third-party terms and privacy policies applicable to those services (which we encourage Site users to read).
• Aggregated Data. We may provide aggregate usage and demographic information to Clients and Inventory and Data Partners to help them understand our Site audience and target their communications accordingly.
• For Legal Purposes. Sometimes we may be required to share your information for legal purposes, including in response to a regulation, court order, subpoena, or other legal process, when we believe it’s necessary to comply with the law, to respond to a government request, when we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Brand Networks, our customers, or others, to prevent harm or loss, or in connection with an investigation of suspected or actual unlawful activity.
• In the Event of a Merger or Sale. We may also share Site users’ information in the event of a corporate sale, merger, acquisition, dissolution, bankruptcy, or similar event.

Third-Party Analytics and Interest-Based Advertising on the Sites

We partner with third parties to engage in analysis, auditing, research, and reporting on the usage of our Sites. These third parties may set and access cookies on Site users’ computers or other devices and may use web beacons to collect information about users’ activities on the Sites. In particular, the Sites use Google Analytics to help collect and analyze certain information for the purposes discussed above. Site users may opt out of the use of cookies by Google Analytics here.

We also partner with third parties to collect information on our Sites to market our own products and services, based on users’ online activities on our Site and on unaffiliated websites (“Interest-Based Advertising”). These third parties may use cookies and web beacons to collect information about users’ activity on our Sites, and they may combine it with information about our Site users’ activities on other, unaffiliated websites. For example, third parties may use the fact that a user visited the Sites to target ads for Brand Networks to that user on non-Brand Networks websites. In addition, our third-party advertising providers might use information about users’ visits to the Sites to help target non-Brand Networks advertisements based on users’ online activities in general. Finally, these third parties may use information collected on the Sites to infer that a particular browser or mobile device is linked to another computer, browser, or mobile device used by the same person or household, and they may use information collected from one computer, browser, or mobile device to deliver ads or measure the effectiveness of ads on other, linked devices. If you would like to opt out of these interest-based advertising and cross-device linking practices, please review your choices in the section below titled “Opt Out of Interest-Based Advertising.”

Please note that our Sites do not respond to browser Do Not Track signals at this time.

Your Choices Regarding the Information We Collect

Opt-Out of Targeted Advertising on Social Platforms

The Social Platforms that you use may allow you to adjust your advertising preferences on the Social Platforms and to limit or control any advertising that is targeted to you based on information that we or our Clients share with them (such as Social Platform user IDs, obfuscated email address or user name, or customer segment information based on demographic information or inferred commercial interests). Please review the privacy policies of the Social Platforms you use for more information about your choices and how to opt out of targeted advertising on those Social Platforms.

Opt Out of Interest-Based Advertising

We leverage our Inventory and Data Partners, including Tapad and The Trade Desk, to deliver advertising based on your online activities across unaffiliated websites and mobile apps (“Interest-Based Advertising”) and to provide cross-device linking services to our Clients. You may opt out of our Inventory and Data Partners’ interest-based advertising practices in web browsers and mobile apps on your current browser or mobile device by following the instructions below. You may also learn more about Tapad’s services and how to opt out by visiting the Tapad Privacy Policy, or learn more about The Trade Desk’s services and how to opt out by visiting The Trade Desk Privacy Policy.

In addition, exercising the opt-out choices below will stop our Inventory and Data Partners from: (1) collecting information on the browser or mobile device from which you opt out for use on other, linked browsers or mobile devices for advertising purposes; (2) collecting information on other, linked browsers or mobile devices for use on the browser or mobile device from which you opt out for advertising purposes; and (3) sharing information collected on the browser or mobile device from which you opt out with unaffiliated third parties for advertising purposes.

Please note, however, that mobile applications and web browsers operate with different identifiers, even though they may be on the same device, and different web browsers on your computer have independent identifiers. Accordingly, the opt-out will apply only to the specific browser or mobile device from which you opt out (and to certain data collected or used on linked devices, as discussed above), and you will need to opt out separately on all of your browsers and mobile devices. If you delete or reset your cookies or mobile identifiers, change browsers, or use a different device, any opt-out cookie or tool may no longer work and you will need to opt out again.

• Web Browser Opt-Out. To opt out in web browsers, please visit:
  • Network Advertising Initiative (NAI) Consumer Opt-Out Page at http://optout.networkadvertising.org/;
  • Digital Advertising Alliance (DAA) WebChoices page at http://optout.aboutads.info/;
  • Digital Advertising Alliance of Canada (DAAC) Consumer Choice page at www.youradchoices.ca/choices (for Canadian users); or
  • European Interactive Digital Advertising Alliance (EDAA) Choice page at www.youronlinechoices.eu (for users in the EU).

To help preserve the choices that you make in the DAA’s WebChoices page, you can install the DAA’s “Protect My Choices” extension that is available at http://www.aboutads.info/PMC. Please note that our Services do not respond to browser Do Not Track signals at this time.

• Mobile Application Opt-Out. To opt out in mobile apps, you can adjust the advertising preferences on your mobile device. For example:
  • In iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking.
  • In Android, visit Settings > Google > Ads > Opt out of interest-based ads.

You can also opt out of interest-based advertising in mobile apps for companies that participate in the Digital Advertising Alliance’s AppChoices tool by downloading AppChoices at www.aboutads.info/appchoices and following the instructions in the app. For more information about opting out on mobile devices, please see https://www.networkadvertising.org/mobile-choice.

Brand Networks adheres to the DAA Principles for Online Behavioral Advertising, the DAA Principles for Multi-Site Data, the Application of Self-Regulatory Principles to the Mobile Environment, and the Application of the DAA Principles of Transparency and Control to Data Used Across Devices.

Access, Update, Correct, or Request Deletion of Your Information

You may choose to:

• Update and correct your information;
• Cancel your Brand Networks account or request that we no longer use your information to provide you services; and
• Request removal of your information or Content from our Sites or Services.

To do any of these, simply notify us of this request by one of these methods:

• Send an email to us at info@bn.co (please include “Attn: Privacy” in the subject line) or contact the Client.

How We Protect the Information We Collect

Brand Networks uses reasonable security measures to store and protect the information collected on our Sites and Services that are under our control and appropriately limit access to it. However, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.We use a variety of information security measures to protect your online transactions with us. The Sites use encryption technology, such as Secure Sockets Layer (SSL), to protect your sensitive information during data transport.

We want you to feel confident using the Sites and Services. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your information, Content, or other communications will always remain secure. We will notify you by email if we have reason to believe that your information has been compromised due to a security breach or used in an unauthorized manner, but by using the Sites or Services, you agree to release us from any and all claims arising out of unauthorized use of your information.

Data Retention

Retention of Information Collected through Our Services

We do not deliver ads based on individual level data that is more than fourteen (14) months old. We retain the information that is reasonably linkable to a device and collected for ad targeting and/or ad delivery and reporting only as long as is reasonably necessary for running advertising campaigns and in no event longer than fourteen (14) months. We may keep opt-out information for longer than this period so that we can continue to honor opt-out requests. Aggregate reports generated from this information may also be kept longer.

Retention of Information Collected on Our Sites

We will retain a Site user’s profile information and Content for as long as the user’s account is active or as needed to provide our services to the user, comply with our legal obligations, resolve disputes, and enforce our agreements. If a Site user closes an account, we may still retain certain information associated with the user’s account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, collect any fees owed, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our Sites or our Site users or take other actions otherwise permitted by law. Deactivating an account does not automatically delete the account or Content from our database, but regardless of any retention policy, we will make reasonable efforts to enable a user to delete profile information from our database upon request. However, if certain information has already been provided to third parties, retention of that information will be subject to those third parties’ policies. Additionally, if a Site user has posted information to Social Platforms or Inventory and Data Partners or otherwise made it available to the public, the Site user may not be able to remove or edit information from some internet databases.

Links to Other Websites

Our Sites may contain links to other websites including those of our Clients, Social Platforms, and Inventory and Data Partners, many of which have their own privacy policies. Be sure to review the privacy policy on any site you are visiting or uploading Content to, whether directly or through the Sites.

Children’s Privacy

The Brand Networks Sites and Services are not directed to children under the age of 13, nor do we knowingly collect personal information from children under the age of 13 or through any online services that are directed to children, as those terms are defined in the Children’s Online Privacy Protection Act.

Information for Users Outside the United States

This Privacy Policy is intended to cover the collection of information from residents of the United States and is not intended for users located outside the United States. If you are accessing the Sites from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Sites, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

Agreements and Exceptions

In certain circumstances, our Statements of Work (SOWs) and Master Services Agreements (MSAs) may supersede this privacy statement. We encourage you to review the terms of any SOW or MSA carefully to understand how they may impact your privacy rights. Your use of our services governed by such agreements will be subject to the terms outlined therein.

Changes to This Privacy Policy

Please note that this Privacy Policy may change from time to time. We will post any Privacy Policy changes on this page and, if the changes are significant, we will notify Site users by delivering an announcement via our Sites or to our Site users’ account email addresses. If a Site user opts out of communications from Brand Networks, the user may not receive these notifications, however, they will still govern the use of the Sites, and Site users are responsible for proactively checking for any changes. If a Site user continues to use the Sites after changes have been posted, the user agrees to abide by and be bound by the modified privacy policy. Each version of this Privacy Policy will be identified by its effective date found at the top of this page.

If you have any additional questions or concerns about this Privacy Policy, please feel free to contact us any time through the “Contact Us” links on our Sites, by emailing us at info@bn.co (please include “Attn: Privacy” in the subject line), or by writing to us at: Attn: Privacy, Brand Networks, LLC, 101 Arch Street, 8th Floor, Boston, MA 02110.