Brand Networks, LLC
Last Updated: January 29, 2020
Effective: January 29, 2020
- 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.
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 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.
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.
- 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 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.”
- 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
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
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 email@example.com (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.
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
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