Effective Date: February 1, 2018
Information We Collect
Cookies and Similar Technologies
Our Use of Information We Collect
Sharing of Information with Third Parties
Your Choices, Including Opt-Out Options
Our ad technology service, used for the delivery of our (or a third party’s) enhanced video ads and related advertising content (collectively, "Content"), Content renderer and accompanying development tools (the “SDK”), and any other products, features, tools, materials, or other services offered from time to time by BrightLine through the OTT Platforms are referred to collectively as the "BrightLine Services."
2. Information We Collect
BrightLine may collect the following information from or about you (collectively, “Information”):
Information You Provide To Us. On the BrightLine Site, you may sign up for our CTV Insight Newsletter by providing your email address, at which point you will receive marketing emails in the form of news and updates. Further, we may request via the Content delivered through the BrightLine Services that you provide your name, email address, phone number, or other Information to us and/or Business Partners (the term “Business Partners” is defined in 9. Sharing of Information with Third Parties) , such as for promotions or for other reasons that are disclosed within such Content.
Usage and Log Data. We also collect Information when you interact with or view Content through the BrightLine Services or when you interact with or view the BrightLine Site (such as through our use of Google Analytics). Examples of such Information may include your IP address, device, browser, and software characteristics (e.g., type and operating system), location, activity on the BrightLine Services (e.g., metrics regarding exposure and interactions with Content) or BrightLine Site, device identifiers or other unique identifiers such as advertising identifiers (e.g., AAID or IDFA), cookies identifiers, and server-generated identifiers based on a combination of device, carrier, and location attributes (see our description of "Cookies and Local Storage" below for the technology behind such data collection).
3. Cookies and Similar Technologies
Like many online services, we use various technologies to collect certain Information described above (e.g., Usage and Log Data). These technologies are discussed below.
Cookies and Local Storage. One technology we use is called a cookie. A cookie is a small data file that is transferred to your computer’s hard disk. We may use both session cookies and persistent cookies to better understand how you interact with the BrightLine Services, monitor aggregate usage and web traffic routing on the BrightLine Site and BrightLine Services, and to customize Content. These uses allow us to improve the BrightLine Site and the BrightLine Services, as applicable. We may create a unique device or user ID for you and store it in a cookie so we can customize your experience based on your preferences.
Web Beacons or Pixels. In addition to cookies, we may use other technologies such as web beacons or pixel tags, which can be embedded in web pages, videos, or emails, to collect certain types of Information from your browser or device, check whether you have viewed a particular web page, ad, or email message, and determine, among other things, email open rates, the time and date on which you viewed the Content, the IP address of your computer, and the URL of the web page from which the Content was viewed.
SDKs. An SDK is computer code that app developers can include in their apps to enable ads to be shown, designate the data fields to be collected, and implement any related services and functionality. An SDK integrated into an OTT Platform is, in effect, the app version of a pixel tag or beacon. We may use or work with third parties, including our Business Partners and service providers, who use our SDKs within OTT Platforms to collect Information, such as device or advertising identifiers and Information related to how such identifiers interact with the BrightLine Services. We may use this Information, for instance, to analyze how you interact with Content and advertisements and to enable analytics or other features through OTT Platforms.
Server Side Identifiers. In some cases, BrightLine will not be able to collect a device ID or set a browser cookie. In these cases BrightLine will create an identifier or fingerprint from a combination of user agent, carrier, and location Information that will provide a high probability of uniqueness of your OTT Platform.
4. Our Use of Information We Collect.
We use the Information we collect from or about you in order to help deliver a first-class user experience. Our use of this Information may include the following:
Providing, securing, enhancing, or improving the BrightLine Site and/or BrightLine Services;
contacting you, including for promotional purposes;
customizing the Content you view and evaluating how well such Content performs in cooperation with Business Partners, service providers, and other third parties;
compiling aggregate data for internal and external business purposes;
preventing potentially illegal or harmful activities;
protecting your and our rights;
any other purpose that is disclosed to you at the time we collect the Information or that is related to a request made by you.
Use of Aggregate or De-Identified Information.
5. Sharing of Information with Third Parties
We may share Information collected from or about you with third parties as explained further below, including Business Partners, service providers, and other third parties not affiliated with BrightLine.
We work with a number of third-party distribution and media partners that have embedded our SDK, advertisers/advertising technology companies, data vendors, and other strategic partners who use or help us offer the BrightLine Services or BrightLine Site, as applicable (collectively, “Business Partners”).
For example, many of our Business Partners seek to measure the performance of their Content across many OTT Platforms, including through implementation of the BrightLine Services. Accordingly, BrightLine may permit the use of or provide measurement/attribution software or functionality that enables third parties (such as Nielsen) to include your viewing of Content on the BrightLine Services in the calculation of measurement statistics, such as, but not limited to, TV and Digital ratings. To learn more about your choices with respect to Nielsen measurement software, please see the information we have provided in 6. Your Choices, Including Opt-Out Options.
Relatedly, we may also share certain Information collected from or about you with Business Partners in order to tailor advertisements, measure and improve advertising effectiveness, and enable other enhancements. This Information includes your advertising identifier, IP address, or user agent string (e.g., browser, operating system). On certain Content, we may request to pass along your email address or other certain Information that you input to Business Partners to provide offers displayed in such Content.
We may share the Information collected from or about you with companies that provide general services to us, including companies that assist with payment processing, analytics, Content distribution, data processing and management, account management, hosting, customer and technical support, marketing (e.g., email, online, or direct mail communications), and other services. These companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.
We may also share your Information with any of our parent companies, subsidiaries, or other companies under common control with us.
When Required By Law or When Necessary to Protect Your or Our Rights.
Third Parties in Connection with Certain Transactions.
In the event of a merger, reorganization, dissolution, or similar corporate event, such as selling all or part of our business, making a transfer of assets, or otherwise being involved in a change of control transaction, or in the unlikely event of bankruptcy, we may transfer Information from or about you to one or more third parties as part of the transaction, including in the due diligence process.
Third Parties with Your Consent or When You Otherwise Choose to Share.
6. Your Choices, Including Opt-Out Options
Personal Information Rights.
You may manage your receipt of marketing and non-transactional communications by clicking on the "Unsubscribe" link located on the bottom of any BrightLine marketing email and following the instructions found on the page to which the link takes you. You cannot opt out of receiving transactional or administrative e-mails. Please allow us a reasonable time to process your request.
BrightLine Site Analytics.
The BrightLine Site uses Google Analytics for analytics purposes. For more information on Google Analytics, including how to opt out of data collection, please visit https://www.google.com/analytics.
Further, if you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this. However, if you decide not to accept cookies from us, some features of the BrightLine Site may not function properly.
Opt-Out from Nielsen Measurement.
Opt-out Options for Interest-Based or Online Behavioral Advertising within Mobile Devices (iOS and Android)
On your mobile device, you may also go to your device settings and select "Limit Ad Tracking" (for iOS devices) or "Opt out of Interest-Based Ads" (for Android devices), which will allow you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests. Please note that if you opt out using one of the methods set forth above, that opt-out will apply at the “device level” (i.e., only to the specific device from which you opted-out).
Opt-Out Options for Interest-Based or Online Behavioral Advertising within OTT Platforms.
AppleTV. To opt-out of OBA ads on an AppleTV device, please follow the instructions found here: https://support.apple.com/en-us/HT202074
Samsung. You can opt out of receiving targeted advertising from AdHub here: https://account.samsung.com/membership/etc/setPersonalOption.do?openPage=adsCombination. Please note that if you opt out, you will continue to see ads, but they may be less relevant to you because they will not be based on your interests.
FireTV. Go to Settings>System>Advertising ID and toggle the “Interest-based Ads” button to Off
Xbox devices. Go to http://choice.microsoft.com/en-us/opt-out and toggle the “Personalized ads wherever I use my Microsoft account” to On. Does require that you login with your Microsoft account used on your Xbox device.
Do Not Track.
If an OTT provider passes to us a “Do Not Track” signal in an HTTP header, we will honor it. However, there is currently no consensus among industry participants as to what "Do Not Track" means and how/if to respond to or send "Do Not Track" signals. As such, we do not honor “Do Not Track” signals except as mentioned above.
California Privacy Rights.
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please email us at email@example.com.
We use a variety of physical, technical, and administrative measures to safeguard Information in our possession against loss, theft and unauthorized use, disclosure, and modification. For example, we take steps to limit internal access to Information from or about you to those BrightLine employees, agents, and contractors who have a legitimate business reason to access such Information. We also use measures like encryption and hashing to help protect sensitive Information when in transmission. Despite these efforts, please note that there is always a possibility that a breach in data transmission or storage may occur. We want you to feel confident in our security when using the BrightLine Services and BrightLine Site, but we cannot guarantee the security of any Information from or about you 100% of the time.
9. Third-Party Websites
10. Applicable Law
BrightLine is headquartered in the U.S. and the BrightLine Services are intended strictly for U.S. audiences. The BrightLine Services, the BrightLine Site, and BrightLine’s servers are operated in the United States. If you are located outside the United States and choose to use the BrightLine Site, the BrightLine Services, and/or any Content you do so at your own risk. Please be aware that your Information, including your personal information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.
12. Questions/Contacting Us