Beeswax Privacy Policy

Updated: August 7, 2018

WHAT IS BEESWAX

Beeswax is an advertising technology platform headquartered in New York City. We are providing this privacy policy to inform you about how our technology platform processes information on behalf of online advertisers, website owners, data providers and other businesses that use our technology and services.

If you have any questions about this privacy policy, please feel free to contact us at privacy@beeswax.com.

Beeswax runs a technology buying platform for digital media. The Beeswax technology allows our customers to buy ad space on websites, mobile apps, video players, and other devices. When ad space is bought or sold our technology fulfills the transaction by delivering the ad to Internet users who visit that site, apps, or device. Generally, an Internet user's computer or mobile device comes into contact with Beeswax technology when a user views an ad delivered by our technology or clicks or taps on the ad to visit the advertiser's website or app.

PRIVACY PRACTICES FOR OUR TECHNOLOGY

Advertising supports free content and digital user experiences that we all love. Our goal is to make advertising more effective by helping to display ads that may be of interest to you. We believe that relevant ads are more valuable to users than less relevant ads. More relevance also helps the services that depend on advertising because advertisers pay more for effective ads which in turn leads to higher quality and richer consumer experiences.

Beeswax is a member of the Network Advertising Initiative (NAI) and we adhere to the NAI Codes of Conduct. To learn more about the NAI and the Code of Conduct please visit: http://www.networkadvertising.org/code-enforcement/code.

Beeswax adheres to the Self-Regulatory Principles for Online Behavioral Advertising and the Application of Self-Regulatory Principles to the Mobile Environment published by the Digital Advertising Alliance (DAA). We honor the DAA’s opt-out mechanism for data collection and use in connection with mobile applications. To learn more about the DAA and your choices, please visit www.aboutads.info/choices.

With regard to the General Data Protection Regulation ("GDPR"), Beeswax acts as a Data Processor for our customers. Our customers are obligated to get proper consent from end consumers in order to use any personal data within our system. For example, if a Beeswax customer is using cookies collected on the customer's website to retarget users with ads, the customer is obligated to have the proper consent for the use of that data within Beeswax's system, and to respect opt-outs and the other obligations under the GDPR. We process personal data in a number of ways, each with respect for lawful consent:

  • Performance of contract. We need to collect and process Personal Data in order to deliver our online advertising platform and services for our customers.
  • Legitimate business interests. We may use Personal Data for our legitimate business interests to administer our platforms, ensure the integrity of our transmission network, and to enforce our Terms of Service, for example, by analyzing data for signs of fraud.
  • Data Subject Consent. To the extent Customers need to collect and share, or allow us to facilitate collection and sharing of Personal Data to enable our Services, it is the responsibility of Customers to provide necessary privacy notices and obtain required consent(s).
WHAT INFORMATION WE COLLECT, THE PURPOSE OF COLLECTION AND USE

The Beeswax technology collects information on behalf of its customers to help target online advertising to you based on your interests. This information may include your IP host address (which we truncate for users from the European Economic Area), your browser type (e.g. Chrome or Firefox), the date and time of the ad request, pages viewed, your operating system (e.g. Macintosh, Windows, Android, OSX), the URL or App you are using, and your Internet Service Provider (e.g. Verizon or Comcast).

Contact Information

We collect contact information through our technology from customers, vendors and distributors who wish to obtain information or support, or to obtain access to our platform. Contact information includes: first name, last name, email address, job title, name of the organization, country, state/region and phone numbers (cell and/or landline). This contact information is used by our sales, support and operations teams to contact our customers, vendors and distributors for the purpose of providing the requested information or support, and/or providing our services. We may collect additional information from individuals applying to work at Beeswax, and we may retain that data as long as necessary to comply with legal obligations regarding employment. We also collect contact information to respond to general inquiries, solicit feedback regarding our platform and support, and to communicate with you via email regarding our current and future offerings.

Analytics

Like most organizations, we rely on automatic data collection technology (Google Analytics). Google Analytics may collect information on our behalf such as your IP host address, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, number of links you click, search terms, and other data. This information is collected automatically and anonymized by Google Analytics.. For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics.

Mobile Tracking

To provide relevant ads to users on mobile devices we may also collect the following mobile specific information: device type, make and model, operating system, mobile advertising identifiers, operating system device identifier (For example, IDFA for iOS and Android ID for Android) and information about the apps you use. We may also use the GPS location of your device if you have opted-in to provide it to one of Beeswax's publisher partners as described below under "Location Tracking."

Your iOS mobile device may provide a “Limit Ad Tracking” setting. On Android devices, your settings may allow you to “Opt out of Interest-Based Ads.” When you have opted out using this setting on a device and that information is passed to Beeswax, Beeswax will not use your information to target ads to you or place you in segments for future marketing.

Cookies

Cookies are small packets of data that are stored on your computer’s hard drive so that your computer will “remember” information about your visits to websites or your viewing of ads. Our cookie policy is available at www.beeswax.com/cookies. If you do not want us, or Google Analytics to place a cookie on your hard drive, you may be able to turn that feature off on your device. Please consult your Internet browser’s documentation for information on how to do this, such as by using your browser in private mode to block cookies.

Pixel Tags

We also use pixel tags, which are small, invisible 1x1 images on a web page. Pixel tags allow the web page or a third party who serves the pixel tag to set, read and modify cookies. Our pixel tag allows Beeswax cookies to be set, read, and modified when you visit the websites or apps of our partners.

Please click here if you'd like to opt-out from having Beeswax collect your information in connection with our technology.

When you opt out, we will place an opt-out cookie on your computer. This cookie tells us not to collect your information to tailor our online advertising campaigns. Please note that if you block, delete or restrict cookies in any way, or if you use a different computer or Internet browser, you may need to renew your opt-out choice.

Location Tracking

Beeswax may receive latitude and longitude of mobile users from publishers or exchanges. We use such data for targeting ads and evaluating their success, and may share it with third party companies acting as controllers (See, Onward Transfers to Third Parties). This information is also maintained in our logs in accordance with our data retention policy (below). In the European Union, when we receive precise location information we truncate the location data to three decimal places to be less precise before storing such data.

Information We Receive from Third Parties

We may also receive information about you from third parties when you use our services on such third party sites. We may combine the information we receive from these third parties with the information we directly collect from you and use such information in accordance with this Privacy Policy and requirements under applicable EU data protection and privacy laws.

ONWARD TRANSFER TO THIRD PARTIES

Beeswax may share your information with its customers in connection with the offering of its services. For example, a Beeswax customer may receive a log of all ads they served through our platform, including anonymous cookie IDs, IP host addresses, and other information in non-aggregated form. For users within the European Union, any personal data is pseudonymized (one-way hashed) before being shared with customers and are sufficiently protected as required by Privacy Shield participants (see below for more information about how we handle the transfer of data outside the EEA).

Like many businesses, we hire other companies to perform certain business-related services. We may disclose personal information to certain types of third party companies but only to the extent needed to enable them to provide such services. The types of companies that may receive personal information and their functions are: data analytics vendors, data hosting providers, optimization vendors, email delivery providers, customer relationship managers, and marketing services companies. All such third parties function as our agents, performing services at our instruction and on our behalf pursuant to contracts which require they provide at least the same level of privacy protection as is required by this privacy policy and implemented by Beeswax. You may opt out of having your personal information transferred to any or all of our categories of agents by contacting us at privacy@beeswax.com. Please allow us a reasonable time to process your request.

Business Transfers. In the event of a merger, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such information as set forth in this privacy policy.

Disclosure to Public Authorities. We are required to disclose the information that we have collected in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

OPT-OUT FOR DIRECT MARKETING

You may opt out at any time from the use of your personal information for direct marketing purposes by clicking here or by contacting us at privacy@beeswax.com. Please allow us a reasonable time to process your request.

DATA TRANSPARENCY

You may review the information Beeswax's customers store with us about you by visiting our data transparency page here.

ACCESS TO PERSONAL INFORMATION

Upon request to privacy@beeswax.com, we will provide you with confirmation as to whether we are processing your personal information, and have the data communicated to you within a reasonable time. As a data processor, we do not directly control any personal data, so any changes or inaccuracies in the data we collect should be addressed to the controllers of such data. Please allow us a reasonable time to respond to your inquiries and requests.

HOW WE PROTECT YOUR INFORMATION

Beeswax takes very seriously the security and privacy of the personal information that it collects pursuant to this privacy policy. Accordingly, we will implement reasonable and appropriate security measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations.

CHILDREN

We do not knowingly collect any personal information from children under the age of thirteen through the platform. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our privacy policy by instructing their children never to provide personal information to us without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at privacy@beeswax.com, and we will endeavor to delete that information from our databases.

LINKS TO EXTERNAL WEBSITES

The Beeswax technology may contain links to third party websites (“External Sites”). Beeswax has no control over the privacy practices of these External Sites. As such, we are not responsible for the privacy policies of those External Sites. You should check the applicable third party privacy policy and terms of use when visiting any External Sites, and before providing any personal information to such External Sites.

IMPORTANT NOTICE TO ALL NON-US RESIDENTS

Our servers are located in the US. If you are located outside of the US, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the US. Except in the case of data transfers under the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, your decision to provide such data to us, or allow us to collect such data it through our technology, constitutes your consent to this data transfer.

IMPORTANT NOTICE FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA AND SWITZERLAND

Beeswax complies with the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from the European Union member countries (including Iceland, Liechtenstein and Norway) and Switzerland to the United States, respectively. Beeswax has certified that it adheres to the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability (the “Privacy Shield Principles”). With regard to the Principle of Accountability for Onward Transfer, for example, we remain liable if our agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage. If there is a conflict between this privacy policy and 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/.

Beeswax is subject to the investigatory and enforcement powers of the Federal Trade Commission.

In compliance with the EU-US and the Swiss-U.S. Privacy Shield Principles, Beeswax commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Beeswax at privacy@beeswax.com. Beeswax has further committed to refer unresolved privacy complaints under the EU-US and the Swiss-U.S. Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and 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 by Beeswax, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. If these processes do not result in a resolution, you may also contact your local data protection authority, the US Department of Commerce, and/or the Federal Trade Commission for assistance. If your complaint still remains unresolved, then you have the right to invoke binding arbitration by the Privacy Shield Panel upon written notice to Beeswax at privacy@beeswax.com.

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 contact Beeswax via email at privacy@beeswax.com. Beeswax does not monitor, recognize or honor any opt-out or do not track mechanisms including general web browser, “Do Not Track” settings and/or signals.

DATA RETENTION

We retain the information that is reasonably linkable to a device and collected for ad targeting and/or ad delivery and reporting only as long as is legitimately necessary for running advertising campaigns and in no event longer than thirteen (13) months. We keep opt-out information for longer than this period so that we can continue to honor opt-out requests. Aggregated data, such as the results of campaigns or the amount spent on different inventory sources, may be retained indefinitely provided that the data is not reasonably linkable to a device. Our cookie's duration on your browser may exceed 13 months, but no data associated with that cookie will do so.

CHANGES TO OUR POLICY

We may revise this policy at any time. Any changes and/or updates to the policy will be updated directly on this page. We encourage you to visit this page periodically to review our privacy policy so that you will always know what information we gather and how we may use that information.

CONTACTING US

Should you have any questions in regards to this policy or Beeswax's privacy practices, please contact us at the following email and they will be more than happy to clarify and assist you in any way possible: privacy@beeswax.com. If you are unable to obtain the information or resolution that you seek, you may also contact our Data Protection Officer at dpo@beeswax.com.