FREEWHEEL PRIVACY AND COOKIES POLICY
Last Updated: January 22, 2020
FreeWheel Media, Inc. and its wholly-owned subsidiary, Comcast International France SAS (together, “FreeWheel”, “we”, “us” or “our”) is committed to protecting your privacy and ensuring that your personal data is protected.
Summary of Privacy and Cookies Policy
If you would like us to change how we deal with your personal data, you can send us an email at firstname.lastname@example.org.
Full Privacy and Cookies Policy
Our Sites include social media features, such as the Facebook “Like” button, and widgets, such as the “Share This” button or interactive mini-programs that run on our Sites. These features may collect your IP address or which page you are visiting on our Sites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Sites. Your interactions with each these features are governed by the privacy statement of the company providing it. Our Careers Page also allows you to login using single sign-on services such as Facebook Connect, Google+, LinkedIn, or an Open ID provider. These services will authenticate your identity, provide you the option to share certain personal data (such as your name and email address) with us, and enable you to pre-populate the sign-up form. Services like Facebook Connect give you the option to post information about your activities on our Sites to your profile page to share with others within your network.
Types of information we collect from you directly:
The types of information you may give us directly include:
Types of information we collect when you visit our Sites:
You can visit and navigate our Site to find information about our companies and Services without stating who you are. We use “cookies” in connection with a Site analytics service that helps us better understand how you use the Site and how you navigate through the Site, helps us learn what content is being reviewed, and helps us administer the Site. We do not link data collected from these cookies to personally identifiable information (direct identifiers) we collect from you.
Here are examples of the types of information we may collect from you when you visit the Sites:
Types of information we collect from other sources (such as Facebook Connect, Google+, LinkedIn, or an Open ID provider):
Collecting your personal data helps us to better understand what you need from us so that we can provide it. When you provide your personal data and related information about your interests, we can learn more about what types of products and services you might be most interested in so that we can present the right information to you and improve your experience of our Sites. We will hold your personal data for as long as we need it to provide information, products and services to you, or until you withdraw your consent for us to process your personal data, whichever is earlier (see “Your rights and whom to contact”).
We use personal data that we collect about you for the following purposes:
We use personal data that we collect about you with your consent to send you information regarding our companies or partners (such as marketing promotions and events).
When you express interest in purchasing our services, we also use personal data that we collect about you for the following additional purposes:
When you click “Accept” on our cookie banner, you agree to the placement of cookies on your device by us and our analytics providers. If you do not click accept, we will place an opt-out cookie on your browser instead of our tracking cookie. You may change your preferences or withdraw your consent at any time. Most internet browsers are initially set to accept cookies, however it is possible to change the settings to block the cookies in order to opt out of the cookies we use on our Sites or to alert you when cookies are being sent to your device. You can refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings or follow the instructions as provided below. But please remember, if you disable the cookies that we use, or you do not accept our cookies, you may not be able to visit certain areas of our Site or you may not receive personalised information when you visit the Site. If you would like more information about the types of cookies we use and how we use them, please click here.
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.
FreeWheel Media Inc has elected to participate in the DAA’s Consumer Choice Page in order to offer you the ability to elect not to receive such targeted advertising from FreeWheel customers.
Comcast International France SAS does not collect data, nor set cookies, to build profiles for OBA. Some of Comcast International France SAS’ buying partners may do this from their systems. You should check http://www.youronlinechoices.com/ to understand which companies use this data and opt out if you wish to.
If you choose to opt-out of our cookie, you will be opted out for all of the Sites and customers that use our Services. If you do not want a unique cookie from us, there is a simple procedure to follow.
Click here to replace your unique FreeWheel Media Inc cookie with an opt-out FreeWheel Media Inc cookie.
Click here to replace your unique Comcast International France SAS cookie with an opt-out Comcast International France SAS cookie.
If you select an opt-out cookie, ads delivered to your browser on behalf of our customers using our ad-serving technology will be targeted based only on the device identifiable information (“DII”) that is automatically transmitted in the Internet environment. The non-personally identifiable 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 non-personally identifiable information provided by the Site or customer such as data to confirm that you have opted out of our cookie being dropped on your device. When you receive this cookie, our systems will not attempt to assign other of our companies’ cookies in the future.
PLEASE NOTE: 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.
For Android: (1) Open the Google Settings app on your device; and (2) select Ads.
For iOS: devices with iOS 6 and above use Apple’s Advertising Identifier. To learn more about limiting ad tracking that uses this identifier, visit the Settings menu on your device.
Location Tracking: Standard functionality of FreeWheel’s Monetization Rights Management® Service (“MRM”) enables MRM customers to associate a zip code from the IP address FreeWheel Media Inc collects from you when you view an ad FreeWheel Media Inc has served. FreeWheel Media Inc may, on behalf of a customer, use this location information to improve the relevance of ads you see. Comcast International France SAS does not collect or utilize such location information.
For Android, there are 2 methods:
(1) Go to Settings; (2) go to Privacy; (3) go to Location Services; and (4) turn off the “Location Services” functionality and/or review information about specific Applications and System Services.
Through our SSP Services, the following cookies are dropped onto our clients’ customers’ devices:
|Cookie Name||Cookie Type||Notes|
|UID||Persistent. This cookie is always set.||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.|
|SessionID||Session. This cookie is always set.||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.|
|OA*CAP and OA*BLOCK cookies||Persistent. These cookies are only set when required.||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. 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.|
|Uid-bp-||Persistent. These cookies are always set.||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 an 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. 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.|
|Dp-||Persistent. This cookie is only set when a marketplace has activated a third-party data service.||If our publisher partner uses an external provider of data (also known as a Data Management Platform, 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. 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 & data management platform who will be able to provide more details about the type of data referenced. This data is used to target advertisements.|
Through our MRM Services, the following cookies are dropped onto our clients’ customers’ devices:
|Cookie Name||Cookie Type||Notes|
|_uid||Persistent Cookie||The user id identifying the unique user, across browser session, across network|
|_sid||Session Cookie||Identifies the browser user session|
|_ab_test||Persistent Cookie||Used to split traffic for test|
|_stid||Persistent Cookie||Describes which FW network and scenario the user comes from|
|_av||Persistent Cookie||Used to record user ad views|
|_sav||Persistent Cookie||Used to record user stream ad views|
|_asav||Persistent Cookie||Used to record user ad views for frequency capping, pre-assets|
|_ssav||Persistent Cookie||Used to record user ad views for frequency capping, per site section for ads|
|_auv||Persistent Cookie||Used for ad unit user tracking|
|_cv||Persistent Cookie||Used for creative rotation cookie|
|_cvr||Persistent Cookie||Used for commercial view ratio|
|_pr||Persistent Cookie||Used for page advertisement history tracking|
|_vr||Persistent Cookie||Used for video advertisement history tracking|
|_cph||Persistent Cookie||Commercial pattern cycling|
|_sc||Persistent Cookie||Section content for user experience, for wall clock time|
|_wr||Persistent Cookie||Indicator of current active website in user session for User experience capping and Commercial break patterns|
|_ue||Session Cookie||User exchange for audience data|
|_ul||Session Cookie||Ads used the user attribute stored on cookie for the ad request transaction|
|_ro||Session Cookie||Used for testing against tear sheeting|
|_ha||Session Cookie||Historical ads tracked|
|_ss||Session Cookie||Slots sequencing for ad pod targeting|
|_drh||Session Cookie||Display request history for display ads|
Are any third party cookies set?
There are a number of suppliers that also set cookies, beacons, tags, and scripts on your device on our behalf when you visit our Sites to allow them to deliver the services they are providing (for example if you connect via Twitter Facebook or LinkedIn), analyse trends, administer the Sites, track users’ movements around the Site, and gathering demographic information about our user base as a whole. This means that when you visit the Sites you receive cookies from third party websites or domains. We do not control the placing of these cookies and you should check the relevant third party’s website for more information about these cookies. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
Web Analytics Tools
The Sites uses web analytics tools, specifically Google Analytics to track your interactions with a Site and to store information, such as your IP address, what time you visited, whether you’ve visited before and what Site referred you to our Site. Site measurement statistics may be used to personalise your website experience, as well as to evaluate (anonymously and in the aggregate) statistics on website activity. We use this information to measure the effectiveness of our web presence and to compile statistical reports.
Where we use Google Analytics, we share this information with Google to help Google improve its capabilities for analyzing sites. For more information about Google Analytics, go to: http://www.google.com/intl/en/analytics/privacyoverview.html
When do our cookies expire?
Except for essential cookies, most of the cookies on our Site expire at the end of your current session on our Site.
We use an opt-in standard for sending you marketing communications, which means we will only do so with your express consent. If you wish to opt out of receiving emails from us (such as FreeWheel’s Video Monetization Reports), please follow the unsubscribe instructions in any emails you receive from us or contact us as provided below.
If you access the Sites via a third party website, we encourage you to read their individual privacy policies and any terms and conditions to understand how they apply to any data you might permit them to share with us. Where our Sites contain hyperlinks to third party websites you leave our Site when you click through the hyperlinks. We do not control these third party websites or any of the content they contain and we encourage you to read their privacy policies. We do not accept responsibility or liability in relation to your use of any third party Site that you access from our Sites, or which you use to access ours. You use such Sites at your own risk.
We will keep the data we hold about you for as long as we believe is necessary to provide you the information you requested or as reasonably useful for commercial purposes unless you tell us you would like us to stop holding your data. We retain IP addresses that we have collected on behalf of our customers for a maximum period of 18 months from the date of our receipt. For cookie data, please see above.
In connection with our Sites, we use the services of third parties (i.e., technology consultants, CRM vendors, etc.) who will sometimes, in the course of providing services to us, be given access to the information you have provided to us. Each of these service providers is contractually obligated to provide services to us in a manner consistent with this Policy. We may share your personal data with third parties as described below:
Any such third parties are not authorised by us to use your personal data in any other way and will be required by us to implement measures to protect your personal data. Please note that we may need to disclose your personal data if we are required to do so by law including to meet national security or law enforcement requirements.
We sometimes offer you the option to post content to a blog, message board, or chat room. In the course of doing so, you may provide personal data. You should be aware that any visitor may view your postings on a blog, on a message board, or in a chat room. Furthermore, any information that you post, including your profile information, is available to all users of that blog, message board, or chat room, and thus is neither private nor confidential. We cannot guarantee the security of such information that is disclosed or communicated online in these public areas, to the extent that they do not constitute personal data, and you do so at your own risk. We reserve the right at any time to remove any content that you may post on any blog, message board, or chat room and/or restrict your access to any blog, message board, or chat room, as well as to republish any user postings, to the extent that they do not constitute personal data, from blogs, message boards, or chat rooms elsewhere on the Internet in any format. To request removal of your personal data from the blog or community forum, contact us as provided below. You understand and acknowledge that even after removal, copies of submitted content may remain viewable if other users have copies or stored your submitted content. In some cases we will not be able to remove your personal data, in which case we will let you know if so and why.
Your interactions with the user community programs we have with third party social networking Sites such as Facebook, LinkedIn, and Twitter may be displayed on this Site and used by us in a manner consistent with this Policy. Your interactions may also be displayed in your social networking profile. These interactions may be viewable by anyone that has access to that profile, depending on your privacy settings with the social networking Site. You should review the privacy policies of these social networking Sites to understand who may have access to your interactions and how the Site may use them.
Our primary data centres are located in Europe, Singapore, China and the USA. These data centres are used to store data that we receive from end-users. We comply with all applicable laws to protect the security of data during international transfer. FreeWheel Media, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.
We are responsible for the processing of personal data we receive, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland. We may be liable for onward transfers of such personal data where our agent processes personal data inconsistent with the Privacy Shield Principles.
With respect to personal data received or transferred pursuant to each Privacy Shield Framework, we are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We further commit to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal data. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us email@example.com. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration to resolve disputes when other dispute resolution procedures have been exhausted.
We take reasonable precautions to keep your personal data secure and where we share your data with third parties we require them to do the same. The information is collected and stored in a manner that is appropriate for the nature of the data that we collect and the need to fulfil your request. Access to your personal data is restricted to prevent unauthorised access, loss, modification or misuse and is only permitted among our staff on a need-to-know basis. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
Please note that you always have the right to request that we:
If you would like us to change how we deal with your personal data, you can send us an email at email@example.com or write to us at: FreeWheel Media, Inc., 12th Floor, 1407 Broadway, New York, NY 10018, Attn: Legal Counsel. We will respond to your request within a reasonable timeframe. Please note that we will require that you validate your identity prior to processing your request. If we are unable to accept your request, we will provide you with our reasons.
In addition, if you are located in the EU, you have the right to lodge a complaint with your local data protection authority about our use of your personal data.
Your California Privacy Rights. California residents have the right to request and obtain a list of the third parties, if any, to which personal information (as defined by California law) has been disclosed for their direct marketing purposes during the immediately prior calendar year (e.g. requests made in 2018 will receive information about 2017 sharing activities, if any). California residents also have the right to opt out of having their personal information shared for direct marketing purposes. You may do so by sending an email to firstname.lastname@example.org, using this Policy as the subject line, and include your full name, e-mail address, phone number and postal address in your message, or you may contact us at the postal address below, including the same information.
On January 1, 2020, the California Consumer Protection Act (CCPA) will provide California residents with specific rights regarding their personal information. This section describes and explains how California residents can exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
Deletion Request Rights
You have the right to request that we delete personal information that we collected from you and retained, subject to certain exceptions. We will delete (and direct our service providers to delete) your personal information from our records upon receiving your verifiable consumer request, unless an exception applies.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a request to us by either:
You are not required to create an account with us in order to make a request. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a request related to your personal information. You may also make a request on behalf of your minor child.
We are not required to provide personal information to you more than twice within a 12-month period.
We cannot respond to your request or provide you with your personal information if we cannot reasonably verify your identity or authority to make the request.
We will only use personal information provided in a request to verify the requestor’s identity or authority to make the request.
Notice of California Consumer Data Collection and Sharing Practices
For individuals who provide data directly to Freewheel:
Freewheel’s services may use cookie-based frequency capping, including when it is acting in its capacity as a service provider.
On certain occasions, we sell information to third parties. An external party may be considered a third party either because the purpose of sharing 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” information means to disclose it to an external party for monetary or other benefit. We sell the following information:
When we collect tracking information on our web sites, we do not respond to Users’ Do Not Track settings in browsers. You may choose to decline cookies in your browser settings on a desktop computer, or by declining tracking on a mobile device.
This Site is not intended for, nor does it seek to receive information from, children under the age of 13.
We are an application services provider, and host a software application that our customers access online. Although end users have a right to access their personal data collected by our customers, we have no direct business relationship with the end users of our customers. If you are a customer of one of our customer and would no longer like to be contacted by one of our customers that use our Service, please direct your requests to our customer that you interact with directly. We will transfer personal data to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.
An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the FreeWheel’s customer (the data controller). If requested to remove data we will respond within a reasonable timeframe.
We also have no control over the content of the advertisement, including any cookies and web beacons set by advertisers on our customers’ Sites. Each customer understands that in the course of providing Services to it, we collect or receive information from the web browsers of individuals that are either visiting such customer’s web property or viewing content that is owned or displayed by such customer. This information includes frequency of ads delivered and other delivery statistics, time, browser type and version, visitor’s operating system, device type, referral URL, visitors’ IP addresses, visitors’ countries inferred from their IP addresses, and cookie data, including user IDs. We require our customers to obtain consent for our use of such information and we use it for our provision of Services and enforcement of our rights as described in the applicable customer contract, to improve our Services, and to compile aggregated statistics for internal or marketing purposes.