PRIVACY POLICY

Last update: April 14, 2022

 This Privacy Policy pertains to the Bidstream Media website — https://www.bidstreammedia.com — and is applicable to all users that visit the site.

 Bidstream Media, Inc. (“Bidstream Media”, “we” “us”) is an agency which functions as a leading direct-to-publisher ad network (the “Network”) facilitating digital media buys between top brands and publishers. This Privacy Policy pertains to the Bidstream Media Website at https://www.bidstreammedia.com (the “Website”) as well as the Network. Please read the following policy to understand how your personal information will be treated. This policy may change periodically to reflect any changes in legal requirements, company procedures, company products, service offerings and/or technology.

 Privacy Practices for the Website

 The Website is used for providing business information to prospective clients and business partners. It also serves as a marketing vehicle for Bidstream Media. Bidstream Media is committed to respecting your privacy and conducting business matters that follow all policies as required by law.

 Collection and Use of “PII” (Personally Identifiable Information) on the Website

Personally identifiable information is only collected when you choose to provide it to Bidstream Media, such as in an email or by completing a form on the Website. The Website does contain a contact page where you can contact Bidstream Media personnel and request additional information. This PII may include: name, company name, address, telephone number or email address. This information is only used by Bidstream Media to contact you in response to your inquiry, conduct business activities with you, provide customer service and provide new products and services to existing and prospective customers. While Bidstream Media may use the information it collects to notify you of necessary changes to the Website, new services/offerings and unique opportunities, you can contact Bidstream Media at any time if you do not wish to receive these notices by emailing Bidstream Media at privacy@bidstreammedia.com

 Collection and Use of “Non-PII” (Non-Personally Identifiable Information)

Bidstream Media also collects Non-Personally Identifiable Information (“Non-PII”) from visitors to this Website. Non-PII is information that cannot by itself be used to identify a particular person or entity, and may include your IP host address, pages viewed, browser type, Internet browsing and usage habits, Internet Service Provider, domain name, the time/date of your visit to this Website, the referring URL and your computer’s operating system.

This Website uses Google Analytics to help analyze how users use the Website. The tool uses “cookies,” which are text files placed on your computer, to collect standard Internet log information and visitor behavior information in an anonymous form. The information generated by the cookie about your use of the Website (including IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the Website and to compile statistical reports on Website activity for Bidstream Media.

 Cookies and Other Tracking Technologies

 Bidstream Media and our partners use cookies or similar technologies to analyze trends, administer the website, and track users’ movements around the website. Users can control the use of cookies at the individual browser level. For more information about cookies, please visit https://www.allaboutcookies.org/cookies/

 We work with a third party to manage our advertising on other sites which is sometimes based upon your visit to this Website and other sites. Our third-party partners may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. Sometimes this practice is referred to as interest-based advertising. If you wish to opt out of interest-based advertising from our partners, click here. Please note you will continue to receive generic ads.

 Privacy Practices for the Network

 Bidstream Media operates a virtual advertising network (the “Network”) where we direct 3rd party technology platforms (our “Partners”) to help advertisers (our “Clients”) find the right digital audience and to help website and mobile application publishers (our “Publishers”) do a more effective job monetizing their content. We purchase media on behalf of our Clients and engage our Partners to serve the ads and provide additional services pursuant to ensuring the media we buy for Clients from our Publishers. We adhere to the Digital Advertising Alliance Code to the extent that it is applicable to our business.

 Applicability

 This Privacy Policy applies to the Network and its third party ad service vendors’ and advertisers’ delivery of advertisements on the Network, and applies whenever and however you access or use publisher websites on the Network, whether via personal computers, mobile devices or other devices. 

 The publisher websites on the Network are subject to additional or different privacy policies, which are posted on the publisher websites. Please visit each publisher website on the Network for additional privacy policies and terms and conditions related to your privacy.

 Collection of Information via the Network

Bidstream Media operates an ad server, Bidstream Amplitude, located at https://bidstreamserver.com. We encourage you to read our Bidstream Amplitude privacy policy at https://privacy.bidstreamserver.com. We also encourage you to read our advertising partners’ privacy policies. Generally, these partners collect Non-PII including but not limited to browser type, operating system, Internet Service Provider, IP address, and basic ad serving information such as the time and date an ad is served, the name of the mobile app or URLs from the web page visited. Some Partners work with us and our Clients to enable our Clients to bring their offline data into our systems for use by our technology.

 Cookies and Tracking Technologies for the Network

 Our Partners generally use cookies, mobile advertising IDs and similar tracking technologies in order to more effectively run ad campaigns on our behalf. Bidstream Media does not generally use cookies in connection with the Network.

 Choice Mechanisms

While Bidstream Media doesn’t directly process data via the Network, many of our Partners provide choices regarding how information is collected or used on the Network. Each of these opt-out mechanisms are designed to enable you to exercise choice as is applicable for each Partner:

Xandr – https://www.xandr.com/privacy/ 
Yahoo – https://legal.yahoo.com/xw/en/yahoo/privacy/topic/b2bprivacypolicy/index.html 
Index Exchange – https://www.indexexchange.com/privacy/ 
Google – https://policies.google.com/technologies/ads 
Sovrn – https://www.sovrn.com/legal/privacy-policy/ 
AdaptMX – https://adaptmx.com/privacy-policy/ 
EMX – https://enginemediaexchange.com/privacy/ 
OneTag – https://www.onetag.com/privacy/ 
Pubmatic – https://pubmatic.com/legal/privacy-policy/ 
Epsilon – https://www.epsilon.com/us/privacy-policy 
Sonobi – https://sonobi.com/privacy-policy/ 
OpenX – https://www.openx.com/privacy-center/ad-exchange-privacy-policy/ 
Magnite – https://www.magnite.com/legal/advertising-technology-privacy-policy/ 
Smart – https://smartadserver.com/end-user-privacy-policy/ 
33Across – https://www.33across.com/privacy-policy/ 
Amazon – https://www.amazon.com/gp/help/customer/display.html?nodeId=468496&ref_=abn_bfooter_privacy 

 When you use publisher websites on the Network, we share information that we may collect from you, such as your email (in hashed form), IP address or information about your browser or operating system, with our partners and service providers to set and use a first party cookie on your browser to match your shared information to their marketing databases in order to provide back a pseudonymous privacy-centric identifiers for our use in real time bidding in digital advertising. These third parties may in turn link further demographic or interest-based information to your browser. Each of these opt-out mechanisms below are designed to enable you to exercise choice as is applicable for each Partner:

LiveRamp – https://liveramp.com/opt_out/ 
Lotame – https://www.lotame.com/about-lotame/privacy/privacy-manager-opt-out/ 
Criteo– https://www.criteo.com/privacy/disable-criteo-services-on-internet-browsers/ 
PubCommonID – See publishers’ websites for opt out 
The Trade Desk – https://www.adsrvr.org/ 
ID5 – https://id5.io/platform-privacy-policy/ 
Parrable – https://parrable.com/opt-out/ 
The Trade Desk – https://www.adsrvr.org/ 
ID5 – https://id5.io/platform-privacy-policy/ 
Live Intent – https://optout.aboutads.info/ 

 In general, in order for any of these tools to work on your computer, your browser must be set to accept third party cookies. If you buy a new computer, change web browsers or delete this cookie, you will need to perform the opt-out task again.

 You may also visit the Digital Advertising Alliance’s (DAA) website and use the opt-out procedure, which can be used to opt-out from the use of data for interest based advertising purposes from digital advertising companies, including many of our Partners. To access this service, please visit the DAA at: https://www.aboutads.info/choices/.  

 The NAI also provides a mechanism to opt out of its member networks here: https://www.networkadvertising.org/managing/opt_out.asp and the European Digital Advertising Alliance opt-out page may be found at https://youronlinechoices.com/

 If you are looking to exercise choice regarding your mobile device, please visit the NAI’s Mobile Choice information page at https://www.networkadvertising.org/mobile-choice/ and follow their instructions.

 Onward Transfer of Information

 We do not share PII collected via the Website with anyone outside of Bidstream Media, unless specifically stated otherwise. Bidstream Media does not sell, rent or lease such PII collected on the Website to non-affiliated third parties without your consent. We don’t generally share PII provided from Clients, Publishers or Partners other than with our agents and service providers who are bound by confidentiality provisions. In cases of onward transfer to third parties of the personal data of EU and Swiss individuals received pursuant to the EU-US and Swiss-U.S. Privacy Shield, Bidstream Media is potentially liable.

 Bidstream Media may share information for the following purposes: (i) to enable third party service providers to assist or facilitate in the services Bidstream Media provides; (ii) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information Bidstream Media receives, whether or not a response is required by applicable law, and to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Access, or as otherwise required by law; (iii) for law enforcement or national security purposes including sharing data of EU and Swiss individuals in response to lawful requests from public authorities to meet national security and law enforcement requirements; (iv) to enforce an agreement or to protect Bidstream Media’s rights; with any parent, affiliated or successor entity; (v) in connection with any asset sale, transfer, divestiture, bankruptcy or liquidation; (vi) in connection with strategic alliances, partnerships or other business arrangements to permit the offering of products or services Bidstream Media believes may be of interest to you or where Bidstream Media has determined that the information will be used in a responsible manner by the third party; or (vii) as permitted under any agreement with you. Bidstream Media may also share aggregated data with others.

 While our Partners may provide Bidstream Media, our Publishers and our advertising Clients with reports pertaining to advertising campaigns, neither Bidstream Media, our Publishers nor our clients have access to IP addresses, cookie IDs or other forms of pseudonymous data via the Network, although Publishers and Clients may obtain this data independent from the Network. To the extent that our partners may transfer data across international borders, they are required by law to have an appropriate data transfer mechanism such as membership in the Privacy Shield program.

 Children’s Information

 Bidstream Media is respectful and keenly aware of the privacy rights of children. Bidstream Media’s products and services are not intended for persons under 18 years of age and the Website is not directed to children. Bidstream Media does not knowingly solicit or collect any PII from children under the age of 18, nor knowingly markets Bidstream Media products and services to children under this age. If you are a parent and are aware that your child has provided Bidstream Media with PII without your knowledge or consent, please contact us immediately at privacy@bidstreammedia.com.

 Data Subject Access Rights

You can request the PII that Bidstream Media has collected about you, correct factual inaccuracies in information, remove personal information and/or update your personal information by contacting privacy@bidstreammedia.com. Some of the Non-PII collected on behalf of the Network is considered personal data under EU Data protection laws. While Bidstream Media doesn’t place cookies nor process any data directly on the Network, interested persons may contact our Partners to see what type of access rights they offer.

 Security Measures

 Bidstream Media uses appropriate measures to ensure the security of all information, including the use of passwords, firewalls, encryption and remote servers, and routinely evaluate our practices to identify security threats or opportunities for the improvement of our services. No transmission of information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. You acknowledge and agree to assume this risk when communicating with us.

 Other Notices

 We reserve the right to modify this privacy policy at any time in the future. Please note that the use of information that we gather is subject to the privacy notice in effect at the time of use.

 European Economic Area

 As of May 25, 2018, the General Data Privacy Regulation (“GDPR”) will afford additional rights to EU data subjects. For example, with respect to EU data subjects, the definition of personal data includes pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID. EU Data subjects have the right to complain to EU Supervisory Authorities and the right to access, correct and delete certain personal data processed by Bidstream Media and those Partners that serve ads on our behalf to EU data subjects. You may access those rights with respect to Bidstream Media by scrolling up and reading the section entitled “Data Subject Access Rights” or by sending us an email at privacy@bidstreammedia.com.

 Bidstream Media does have Clients located in the EU and we do place media buys on behalf of Clients which may collect data from data subjects located in the EU. Our Clients and Publishers direct us to process data under their general instructions but we may direct our technology Partners to adjust advertising campaigns where we feel appropriate. We rely on the consent of the individual to process personal data in some instances (for example, when the user inputs personal data onto a web form of our Website). On other occasions, Bidstream Media may process personal data when needed to fulfill a contract with a Client or partner or where required to do so by law.

 We may also process data when it is in our or our Clients’ legitimate interests to do this and when these interests are not overridden by the individual’s data protection rights (which may vary based on an individual’s jurisdiction). Certain Publishers, Clients and Partners choose not to operate in the EU and/or collect data from EU data subjects – and each has a process to ensure they are not collecting personal data from the EU on the Network.

 Privacy Information for California residents

 If you are a California resident, California law requires us to provide you with some additional information regarding your rights with respect to your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).  We describe the categories of personal information we collect, the sources and uses of such information and the entities to which we share such information in our California Privacy Notice, below.

California Data Access & Deletion Rights

If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

  • Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
  • Provide access to and/or a copy of certain personal information we hold about you.
  • Delete certain personal information we have about you.
  • Provide you with information about the financial incentives that we offer to you, if any.

Certain information may be exempt from such requests under California law, and we may need certain information in order to service your request.

  • Verification. We will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address.
  • Authorized Agent. You are also permitted to designate an authorized agent to submit certain requests on your behalf.In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney.  We may also follow up with you to verify your identity before processing the authorized agent’s request.
  • Further Information. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at privacy@bidstreammedia.com .
  • Notice of Right to Opt Out of Sale of Personal Information.California residents may opt out of the “sale” of their personal information.  For the purpose of providing targeted advertisements, we provide non-PII information to third parties to provide you with offers and promotions that may be of interest to you.
    • Under the CCPA, sale is broadly defined such that it may include allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising on the Services or other services.Advertising, including targeted advertising, enables website publishers to provide you certain content for free and allows us to provide you offers relevant to you.
    • Depending on what publisher websites on our Network you use, we may provide the following categories of information to third parties for these purposes:
      • For online targeted advertising purposes: demographic and statistical information, device information and identifiers, connection and usage data, geolocation, and social media information.
      • For sharing with third parties to send you relevant offers and promotions and opportunities:contact and registration information; demographic and statistical information, employment and education data, and geolocation.
    • If you would like to opt out of Bidstream Media’s use of your information for such purposes that are considered a “sale” under California law, you may submit a sale opt-out request by emailing us at privacy@bidstreammedia.com. You can also submit a sale opt-out request by emailing us at privacy@bidstreammedia.com. We do not knowingly sell the personal information of minors under 18 years of age.

 Privacy Shield

Bidstream Media complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. Bidstream Media has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Bidstream Media is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

 In compliance with the Privacy Shield Principles, Bidstream Media commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact privacy@bidstreammedia.com.

 We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you. If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

 Third-party Websites

 Bidstream Media is not responsible for the methods by websites or applications that contain links on the Website or are linked to its website nor the contact and information presented therein. Third-party Internet websites and services accessible through Bidstream Media have separate privacy and data collection practices, independent of Bidstream Media. Bidstream Media has no responsibility or liability for these independent policies or actions. The collection and use of that data is governed by the privacy policy and legal terms of the data collector and the website using the data; it is not governed by Bidstream Media.

Contact

 If you have any questions or concerns about your privacy in connection with this policy, please send us a thorough description to privacy@bidstreammedia.com and we will try to resolve it. You may also contact us by mail at: 

Attn: Privacy Officer Bidstream Media 1084 N El Camino Real, Ste B-518 Encinitas, CA 92024