Clearstream Privacy Policy

Welcome! At Clearstream, consumer privacy is very important to the success of the organization. A primary reason we craft our own tech into purpose-built solutions is because we follow a Privacy by Design approach to consumer privacy. It is with this deep level of dedication to our clients and consumers that we can devote ourselves to managing the use of consumer data across the marketing services’ product life cycle while protecting consumer privacy. It is with this mindset that we can say with confidence that we are proud to be a true innovator in the way people, including ourselves, obtain important information online that are relevant to us while respecting consumer privacy. 

Our privacy policy is aimed to clarify what information Clearstream TV and/or its subsidiaries including Engine Media, Inc., Balihoo, Inc., and EMX Digital, LLC (d/b/a bRealTime) (hereinafter collectively “Clearstream”) collects for use. We describe our practices for data collection on this website as well as how we collect, use, and safeguard data collected through publishers and advertisers while innovating to provide better ways to keep the Internet free through the framework of digital advertising.
 

Contents

  1. Short Form Privacy Policy
  2. What Does Clearstream Do?
  3. Scope of Privacy Policy
  4. Privacy by Design
  5. How Does Clearstream Provide Consumers Relevant Advertising? 
  6. How Does Clearstream Find Consumers on the Web?
  7. What is a “Cookie” or “Pixel Tag”?
  8. Disclosure of Information
  9. Data Retention
  10. Your Choices
  11. Mobile Device Choices
  12. Safeguarding Information We Collect and Use
  13. Privacy of Children
  14. Changes to This Privacy Policy and How to Contact Us
  15. Terms & Conditions During Your Visit to the Clearstream Website

In this privacy policy, we discuss our data use practices in relation to individuals and devices. Personally Identifiable Information (“PII”) refers to data that is used, or intended to be used, to identify a particular individual; Non-PII refers to data that is not linked, or reasonably linkable, to an individual, but is linked or reasonably linkable to a particular computer or device; and De-Identified Data refers to data that is not linkable to either an individual or a device.

1. Short Form Privacy Policy
While we encourage you to read the entire privacy policy, the following summary provides some key information relating to our privacy disclosures and practices.

Information Collection: PII
We do not collect PII, as defined by the Network Advertising Alliance and Digital Advertising Alliance. For example, PII may be collected should a consumer contact Clearstream on his/her own initiative or opt-in to register with a publisher to download a mobile app.

Information Collection: Non-PII
The Non-PII we collect may include, as an example, browser types, IP address, domain names, operating systems, language preference, platform type, access dates and times, referring website addresses, browsing, search activity, and online transactions.

How Information is Put to Use
We may use your Non-PII for purposes such as enhancement of our services, marketing, and to more effectively match advertisements to devices, browsers, and applications.

Sharing Your Information
We may share your information with third party service providers with whom we have contracted, Clearstream and its subsidiaries and affiliates, third party marketing partners, business partners and our clients and publishers, and as expressly provided for herein.

Your Choices
You may regulate the collection and use of Non-PII in your browser, by uninstalling or electing not to install an app, or opting out with the Network Advertising Initiative or Digital Advertising Alliance at either http://www.networkadvertising.org/choices/ or http://www.aboutads.info/choices/

Security
We use reasonable and appropriate security measures to protect your data.

Retention
We retain Non-PII for no more than is reasonably necessary for advertising purposes. Aggregate Non-PII data for reporting may be retained for a longer period.

Changes
We may change this Privacy Policy at any time by posting the revised Privacy Policy on the Site along with the date such Privacy Policy was last updated.

Contact Us
If you have any questions about this Privacy Policy please email us at privacy@enginemedia.com.

2. What Does Clearstream Do?
Clearstream was founded with the basic premise that people are empowered when they receive content that is free and that access to information is available to as many people as possible. We work very hard to develop timely, relevant, and appropriate digital advertising to the public for advertisers and publishers. We provide users with a more relevant and better online experience through the responsible use of data for advertising. This belief that a better user experience creates a better Internet for everyone is incorporated into our Privacy by Design approach, which is the belief that each person’s private information should be protected while striving to provide benefits of a free Internet through digital advertising. Our success, in part, comes from our ability to achieve two basic needs in a holistic fashion:

  • Preserve every person’s right to receive free information from publishers by maximizing the value that advertisers and publishers get from better relevancy, analytics, and resulting yield maximization; and
     
  • Respect every person’s privacy by not utilizing personally identifiable information to determine what advertising is appropriate to them.

This experience has helped us forge our business around one central belief: It is possible to provide each individual with the privacy they deserve, while giving them access to positive-sum innovation that is valuable to society in the form of a free Internet experience that is both relevant to consumers and economically viable for advertisers and publishers.

3. Scope of Privacy Policy
This Privacy Policy applies to Clearstream and not of any of our third party partners. We discuss the online method of collection and use of anonymous information gathered by us for this website. It also does not apply to the privacy practices of any of our advertisers or publishers.

4. Privacy by Design
Our foundation of building a strong privacy framework at Clearstream follows an internal framework of Privacy by Design. We integrate privacy in strategy, product development, and more. Our internal procedures include privacy protection early and often, proactively keeping PII out of our systems, and building infrastructure that is effective without the use of PII. We can protect consumer privacy AND provide relevant advertising, which benefits everyone involved, especially advertisers, consumers, and small business websites. Ensuring the protection of privacy throughout the entire lifecycle of the data is of the utmost importance and Clearstream is careful to protect privacy as data is collected, used, and destroyed responsibly.

Clearstream has developed a strong privacy foundation and has a company culture aimed at the prevention of the receipt and use of PII for use with interest-based advertising (“IBA”).

5. How Does Clearstream Provide Consumers Relevant Advertising?
We partner with businesses (“Advertisers”) whose Privacy Policy allow them to share anonymous information about their customers and/or inquirers as well as information about a consumer’s interests. This information may include the date and time of a visit to an Advertiser’s website, the pages or product information viewed during that visit, and links or ads that were clicked. The information allows us to analyze and understand more about the things you are or might be interested in, allowing Clearstream to show more interesting and relevant ads to you.

Clearstream does not collect or maintain PII for marketing purposes. This means that we do not accept or use your name, address, email address, or any sensitive information such as your credit card numbers, Social Security numbers, or medical records to provide our personalized advertising service.

6. How Does Clearstream Find Consumers on the Web?
When a consumer visits our website, one of our Advertiser’s websites, or engages with an advertisement we serve, a “cookie” or “pixel tag” may be placed on the consumer’s machine or we may collect device identifiers like iOS and Android Unique Identification Number (UID). Information collected from a cookie, UID, or pixel tag are not linked to PII. No PII is transferred in the Clearstream cookie, UID or pixel tag. Clearstream only knows that consumer by an anonymous ID, so that we can provide more relevant advertisements to the consumer. Again, we don’t know who the consumer is, we just know the consumer’s preferences through that identifier.

7. What is a “Cookie” or “Pixel Tag”?
A cookie is an industry-standard small data file placed on a consumer’s computer. Cookies allow marketers to “remember you” when you return to their website. Again, no PII is transferred in the Clearstream cookie. Consumers have the capability of deleting cookies on their machine; however, if they enjoy the convenience of a website remembering them, consumers are advised not to delete their cookies. This website may contain, in addition to Clearstream cookies, other third party cookies that assist us in supplying information that will make it easier for you to navigate on our site.

A pixel tag (also commonly known as a web beacon or clear gif) is an industry-standard, often transparent graphic image usually no larger than a 1x1 pixel that is placed in a website or e-mail. Again, no PII is transferred in this pixel tag. Clearstream cookies and pixel tags do not track the consumer outside this site or outside of the Advertisers’ websites unless it is to display an advertisement through publishers.

Pixel tags are used by Clearstream to transfer relevant anonymous data from this website or an Advertiser’s website to Clearstream’s servers for the purpose of providing personalized video and display advertisements. Cookies are used by Clearstream to link this anonymous data to non-identified unique users. Pixel tags and cookies may also be used to link additional non-identifiable information provided by a third party to Advertiser’s data. 

We may collect information about your visits to our and other websites, including the pages you view, the links and advertisements you click, search terms you enter, and other actions you take in connection with website visits and advertisements we serve. We may also collect certain information from the browser you used to come to our or one of our advertiser’s or publisher’s websites, such as your Internet Protocol (IP) address, browser type and language, access times, the Uniform Resource Locator (URL) of the website that referred you to our/other websites and to which URL you browse away from our site if you click on a link on a site. This information also assists us in measuring things like possible fraud, analytics or measuring the viewability of advertisements for ad serving and billing purposes. We also collect this data to display different and changing content depending on user input, environmental conditions (such as the time of day), or other variables. This helps us ensure that the ads we deliver are displaying correctly as we seek to maintain the right user experience and value exchange between consumers, advertisers, and publishers.

8. Disclosure of Information
We may disclose proprietary, anonymous information to our Advertisers for reporting purposes, and we may share anonymous, aggregated information with other third parties for advertising, marketing and analytical purposes. Clearstream may also need to disclose anonymous information if (1) we believe that there has been a violation of the law, of your rights, or of our rights, (2) to respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law, and (3) if our company or substantially all of its assets are acquired.

9. Data Retention
Clearstream retains data it uses for marketing purposes for eighteen (18) months, after which the information is removed from the user marketing profiles. If you have contacted us or provided PII to Clearstream to be contacted or joined our mailing list, we will retain your information for as long as you’re active or as needed to provide you with information. If you wish to have your information deleted or request that we no longer use your information to provide you services, please email us at privacy@clearstream.tv.

10. Your Choices
We hope that after reading through this Privacy Policy that you accept that Clearstream is collecting and using data responsibly, and that the cumulative benefits of our work are beneficial to the free Internet as a whole and your browsing experience. However, you may determine that you want opt-out of Interest Based Advertising (“IBA”). Please learn more about IBA or opt out by clicking here. You may also wish to use browser settings to modify your preferences. At Clearstream our goal is to offer a harmonized online experience whatever browser you use. Most browsers accept our cookies by default but in certain cases, like Safari, our cookies are blocked by default by the browser settings (and potentially without your knowledge). In cases where you interact with our service and want to experience our personalized ads your browser settings may nonetheless be configured to block certain third party cookies.

Clearstream is a member of the Network Advertising Initiative (“NAI”) and adheres to its Code of Conduct. You can learn more about the NAI by visiting www.networkadvertising.org. NAI offers an online opt-out platform to allow customers to express their choices and provides general information related to Interest Based Advertising.

Clearstream may place ads on websites that are part of the Google Display Network. Based on your visits to these websites, Google uses an advertising cookie (from DoubleClick) to associate your browser with interest and demographic categories. Google then uses these categories for IBA on these websites. To learn more about this and your choices from Google, please click here.

Some web browsers may also 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. Clearstream and most advertising exchanges and networks do not respond to web browser “do not track” signals at this time. If we do so in the future, we will describe how we do so in this Privacy Statement. For more information about “do not track,” visit www.allaboutdnt.org. You may control the collection and use of Non-PII in your browser by uninstalling or electing not to install an app, or through the Digital Advertising Alliance and Network Advertising Initiative choice pages.

11. Mobile Device Choices
For mobile websites, you can delete our cookie via the browser settings. 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 IBA, or reset your advertising ID. On most Apple iOS devices, you can use the Ad Tracking settings to limit receipt of IBA 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, you may also uninstall the 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 IBA you will need to remove those applications from your device.

12. Safeguarding Information We Collect and Use
The security of your information is important to us. We have implemented appropriate security measures to protect the information in our care, both during transmission and once we receive it. We take physical and technical security measures to protect our data from unauthorized access, as well as unauthorized disclosure.

13. Privacy of Children
We are committed to protecting the privacy of children. Neither Clearstream’s website nor Clearstream online activities with its advertisers are intended or designed to knowingly attract children under the age of 13.

14. Changes to This Privacy Policy and How to Contact Us
We may change this Privacy Policy from time to time. When we do, we will post the change(s) on our website. If we made a material change, we will provide prominent notice on this site in the future. We encourage you to periodically review this page for the latest information on our privacy practices. If you have questions or concerns regarding this statement, please contact us at privacy@clearstream.tv

15. Terms & Conditions During Your Visit to the Clearstream Website
The place of performance for this website is Illinois. Clearstream makes no representation that materials at this site are appropriate or available for use outside of the United States and access to them from territories where their contents are illegal is prohibited. You are responsible for compliance with local laws in relation to the use of this site outside the United States. The use of this site does not establish any joint venture, partnership, employment, or agency relationship between you and Clearstream. The Choice of Law is Illinois. You hereby consent to the jurisdiction and venue in the state and federal courts in Chicago, Illinois. Please be aware that Clearstream may provide links to other websites, which if you click on them may collect personal information about you. The information practices of those third party websites linked to Clearstream are not covered by this Privacy Statement.

Headings are for reference purposes only and in no way define, limit, construe or describe the scope or extent of such section. As a visitor to this website, YOU UNDERSTAND AND CONSENT THAT ANY DISPUTE CONCERNING PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND APPLICABLE SITE TERMS AND CONDITIONS. You also agree that you have provided notice to, and obtained consent from, any third party individuals whose information you supply to us with regard to: (a) the purposes for which such third party’s information has been collected; (b) the intended recipients or categories of recipients of the third party’s information; (c) which of the third party’s data are obligatory and which data, if any, are voluntary; and (d) how the third party can access and, if necessary, rectify the data held about them. It is the express wish of the parties that the Privacy Policy and all related documents have been drawn up in the English language and that the English version of this Privacy Policy shall be the sole version used in interpreting and enforcing this Privacy Policy.

Your use of this website constitutes agreement to indemnify Clearstream and affiliated entities and hold them harmless from any and all claims and expenses, including attorney’s fees, arising from your use of the website.

YOU AGREE THAT OUR LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY US TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY OUR TERMS AND CONDITIONS. THE EFFECTIVE DATE OF THIS PRIVACY POLICY IS DECEMBER 6, 2016.