At Bright Mountain LLC d/b/a BrightStream (“BrightStream”), privacy is important to the success of our organization and we take the protection of user information seriously.
This privacy policy (“Privacy Policy”) tells you about the range of digital advertising services we provide to our clients and the software we use to deliver them. Broadly, these services help our advertiser clients buy advertising space and show video ads to the right audience. They also help our online publisher clients generate revenue by selling advertising space on their websites and apps. This policy describes the data we collect; describes how we use and share that data; and covers the information we collect or receive through our digital advertising software technologies (“BrightStream Technologies”).
This Privacy Policy also describes your rights in determining what we do with the information that we collect or hold about you. We aim to be transparent about how we deal with data so that online users can understand what we do and can exercise control over how we deal with data about them. If you have questions, you can contact our Data Protection Officer at dpo_US@BrightStream.ai, and we will be happy to help.
CONTENTS
- Data Collection and Use
- Scope of Privacy Policy
- Disclosure of Information
- Your Choices for Limiting the Use and Disclosure of Your Personal Data.
- Lawful Basis for Processing Personal Data of European Users.
- Safeguarding Information We Collect and Use
- Geolocation Data
- Access
- California Data Subjects
- Contact Us
- BrightStream Website
- Changes to This Privacy Policy
Data Collection and Use
Data Collected
The BrightStream Technologies facilitate the collection of online users’ data to help publishers maximize revenue from available ad space and advertisers find the best space for their ads. The data which is typically collected and passed includes, without limitation, the following: browser type, IP address, domain names, operating systems, language preference, platform type, device location, access dates and times, referring website addresses, online transactions, randomly-generated unique cookie ID numbers relating to a specific user, and, in some cases, estimated age range and gender. This data is received through integrations with online publishers, streaming services, and mobile applications. We also receive data from third parties in the form of audience segments that we use to target advertising campaigns.
Is that PII/personal data?
We do not collect PII as defined by the Network Advertising Initiative. Some of the data we collect is considered personal data under privacy legislation—for example, where we collect unique cookie IDs. We do not collect users’ names or other identifying information such as email address, phone number, or home address.
How Information is Put to Use
We use the data we collect to (i) help our publisher clients monetize their available ad space and (ii) help advertisers and the agencies who represent them execute ad campaigns. For publishers, we run real-time auctions for the publishers’ advertising space. For advertisers, we allow them to bid in real-time on advertising space made available through our marketplace.
Sharing Data
In connection with the provision of our digital advertising services, we may share the data we collect with our advertiser clients, demand-side platforms (DSPs), ad exchanges (who will make the information available to advertisers and their agencies to facilitate decisions about whether to show an online ad to a user), third party service providers (including data centers, hosting providers, anti-fraud vendors, and technology and security providers with whom we have contracted), BrightStream affiliates, and our publisher clients.
Cross-device Tracking
Third parties we work with may use data we share with them to engage in cross-device tracking. The purpose of this tracking is to show you advertisements that are more relevant to your interests.
Scope of Privacy Policy
This Privacy Policy applies only to BrightStream. It does not apply to the privacy practices of any of our affiliates, advertisers, publishers, service providers, or other platforms involved in digital advertising.
Disclosure of Information
We disclose information to the following parties:
- clients (including publishers, supply-side platforms, demand-side platforms, advertisers and ad exchanges);
- we may disclose data to our advertisers for reporting purposes;
- we may share aggregated information with other third parties for advertising, marketing and analytical purposes.
We may also disclose information to service providers (including data centers, hosting providers, and anti-fraud, technology and security providers). Other third-party service providers used by BrightStream include: (a) cloud computer, data storage and file storage providers, (b) survey vendors, and (c) outsourced computer programmers helping ensure our systems are operating properly. These agents work on our behalf and use data only as directed by us, provided that such third-party agents provide at least the same level of privacy protection as we do. We may disclose information to BrightStream affiliatesto use for any of the purposes described in this Privacy Policy.
If you do note want your personal information shared with these types of third parties please see the section below titled “Your Choices for Limiting the Use and Disclosure of Your Personal Data.”
Disclosure and Compliance with Law
BrightStream may also need to disclose information:
- If we believe that there has been a violation of the law, of your rights, or of our rights;
- to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements, or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law, and
Your Choices for Limiting the Use and Disclosure of Your Personal Data
You can control the collection and use of data in your browser or device by adjusting your browser’s or device’s settings. You also have the option to out with the Network Advertising Initiative or Digital Advertising Alliance at either https://www.networkadvertising.org/choices/ or https://www.aboutads.info/choices. Moreover, if you are using a desktop or mobile browser, you may be able to opt out from data collection by digital publishers whose sites you visits. Please see those publishers’ privacy policies for more information.
Some web browsers may give you the ability to enable a “do not track” setting. This setting sends a special signal to the websites you encounter while web browsing. This “do not track” signal is different from disabling certain forms of tracking by declining cookies in your browser settings, as browsers with the “do not track” setting enabled still have the ability to accept cookies. For more information about “do not track,” visit www.allaboutdnt.org.
You may also control the collection and use of data by uninstalling or electing not to install apps on your device.
For mobile apps, you can typically limit ad tracking within the settings function. On most Android devices, in the “Ads” menu, you can opt out of receiving interest-based advertising, or reset your advertising ID. On most Apple iOS devices, you can use the Ad Tracking settings to limit receipt of interest-based advertising or reset your device’s Advertising Identifier. Please note that your experience may be different depending on your individual device and service. In addition to using the options above, as noted above, you may also uninstall the relevant application from your device. If you download a mobile application, it may use advertising to fund its development and maintenance of its software in iOS and Android. In situations involving applications, if you do not want to receive interest-based advertising, you may need to remove the applications from your device.
Lawful Basis for Processing Personal Data of European Users
Data protection law in Europe contains a number of “lawful bases” for processing of data. We have been careful to ensure we have a lawful basis for the data we process. Our lawful bases include:
- the user’s consent, previously given to the publisher of the app or website we work with; and
- a legitimate interest to collect data which constitutes “personal data” under European law, except where such interests are overridden by a user’s privacy rights. Our legitimate interests are the operation of our platform and business and the provision of online advertising services to our clients as required of by our agreements with them.
European users have the right to lodge a complaint about our processing of personal data with a European Data Protection Authority—in particular, the Member State of your habitual residence, place of work or the location of the alleged infringement of General Data Protection Regulation. For contact details of your relevant local Data Protection Authority, please look here: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
Safeguarding Information We Collect and Use
The security of your information is important to us. We have implemented reasonable and appropriate security measures to protect the information in our care. We take appropriate physical and technical security measures to protect our data from unauthorized access, as well as unauthorized disclosure.
Geolocation Data
We may receive information about your location when you access a site or application that uses our services. The information will be conveyed to us either by the site or your device. The information may take the form of your IP address. The degree of precision of the location data can vary depending on the source of the information.
Where permitted, we may pass this location-related data to our buyers; they may use the data to serve more relevant advertising to you.
Opting Out
You may disable the collection and use of your location data through your device settings. To change location settings on your device, please refer to your device’s official documentation.
Access
Upon request, we will confirm whether we hold or are processing information that we have collected from you. You also have the right to amend or update inaccurate or incomplete personal information, request deletion of your personal information, or request that we no longer use it. Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event we will respond to your request within a reasonable timeframe and provide you an explanation. In order to make such a request of us, please email us at dpo_US@BrightStream.ai, or contact us via mail at the following address: Data Protection Officer, BrightStream, 6400 Congress Avenue, Suite 2050, Boca Raton, FL 33487.
California Data Subjects
California law provides additional privacy protections for California individuals, including: (a) the right to see what data we have about you, your computer or device (i.e., the right to know), (b) the right to delete the data we have about you, your computer or device (i.e., the right to delete) and (c) the right to opt-out of the sale of data about you, your computer or device to certain third parties (i.e., the right to opt-out from sales of your information).
You may access those rights with respect to BrightStream by sending us an email at dpo_US@BrightStream.ai calling us via our toll-free California data subject hotline at 833-457-0281. We will make a good faith attempt to fulfill your request within forty-five (45) days. BrightStream does not discriminate against you if you exercise any of the above rights. Please note that we may not be able to honor one or more of these rights if doing so would violate applicable law.
California law defines personal information broadly and as such, it includes identifiers such as cookie IDs and mobile advertising IDs. Under California law, your request to see the personal information that we have about you may include: (1) specific pieces of personal information that we may have about you; (2) categories of personal information we have collected about you; (3) categories of sources from which the personal information is collected; (4) categories of personal information that we sold or disclosed for a business purpose about you; (5) categories of third parties to whom the personal information was sold or disclosed for a business purpose; and (6) the business or commercial purpose for collecting or selling personal information.
We may take reasonable steps to verify your request. We will fulfill requests we are able to verify so long as we are not prohibited from doing so by applicable law and/or the information is not essential for us for billing, fraud prevention or security purposes. In the event that we are unable to fulfill your request, we will share our reason(s) for denying your request.
You may make an access or deletion request via an authorized agent. Please note that we may request any authorized agent to demonstrate that they have been authorized by you to make a request on your behalf. We may require any authorized agents to provide us with contact details such as an email address and phone number so that we may ensure a timely response.
Contact Us
If you have any questions about this Privacy Policy please email us at dpo_US@BrightStream.ai or contact us via mail at the following address: Data Protection Officer, BrightStream, 6400 Congress Avenue, Suite 2050, Boca Raton, FL 33487. You may also contact us via our data subject hotline at 833-457-0281.
BrightStream Website
In addition to the above, this section applies specifically to information collected via the BrightStream website located at www.brightstream.ai (the “Site”).
Information We Collect
BrightStream may collect information from or about you when you visit the Site.
Information you give us: BrightStream collects information that you choose to provide to us when you complete the contact us form which asks for your name, email address, and other information.
Information collected by the Site: When you visit the Site we automatically collect information, where permitted by law, about how you browse through the Site using cookies and other data collection technology. Where we are required to get your consent before gathering this information, we do so.
- Usage Information: We may collect information about your activity on the Site, such as the date you viewed our page.
- Device Information: We may collect information from and about the computer, tablet or mobile telephone you use to access the Site, including hardware and software information such as IP address, device type, advertising IDs, browser type and language, operating system, time zones, and identifiers associated with cookies that may uniquely identify your browser.
- Third Party Vendors: Third party service providers may assist us with our business operations and may collect and use information gained through browser activity on the Site and may share the collected information with us.
How We Use Information Collected Through Our Site
We use information collected through the Site as follows:
To offer services to you, where applicable
- We may respond to your requests, such as when you contact us using our contact us form
To market our products and services
- We may use information we obtain about your interests to help us ensure that marketing material that we send you is relevant to what you are interested in.
To improve the Site
- We may analyze users’ behavior to improve the Site and its content and develop new Site features.
To ensure legal compliance
- We may use the information to comply with laws applicable to BrightStream
How We Share Information Collected Through Our Site
We share information as follows:
- With our service providers
We use third parties to help us operate and improve the Site.
- With our affiliates
We may share information with a BrightStream affiliate to assist us in processing the information, data hosting and maintenance, marketing and targeted advertising, better understanding how the Site is used, or improving the Site.
- For corporate transactions
We may transfer information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
- When required by law
Applicable law may require us or our service providers to disclose information if: (i) reasonably necessary to comply with a legal process, such as a court order, subpoena or search warrant, government investigation or other legal requirements; or (ii) doing so is necessary for the prevention or detection of crime (subject in each case to applicable law).
- To enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity or other wrongdoing.
- With your consent or at your request
We may ask for your consent to share your information with third parties. When we do, we will make it clear why we want to share the information.
Changes to This Privacy Policy
From time to time we may change this Privacy Policy by posting a revised privacy policy on this site. We encourage you to periodically review this page for the latest information on our privacy practices.
LAST UPDATED July 24, 2024
