Last Updated: May 04, 2023
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.
Advertising supports the free content and digital user experiences that we all love. Our goal is to make advertising more effective by helping our customers 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
When you utilize our Services, we and our third-party service providers collect all or some of the following types of Information:
Personal Identifiers: 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, communicate via email regarding our current and future offerings, and/or provide and receive feedback on our Services. We also collect cookie and mobile advertising identifiers, your IP host address (which we truncate when we know the user or the ad request is subject to GDPR), and other online identifiers, which we use to target online advertising, as described in more detail below.
Internet or Other Electronic Network Activity Information:
Analytics & Advertising: Like most organizations, we rely on automatic data collection technology to collect information your activities online, such as your 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. We use this data to analyze the use of and improve our Services.
The Beeswax technology also collects information on behalf of its customers to help target online advertising to you based on your interests. This information includes the personal identifiers described above, your browser type (e.g. Chrome or Firefox), the date and time of the ad request, advertiser 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).
We collect this information through the use of tracking technologies, such as first and third-party “cookies” and “pixel tags”, as further discussed below:
Geolocation Information: Beeswax may receive latitude and longitude of mobile users from publishers or ad exchanges. We use such data for targeting ads and evaluating their success, and we 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 and we know the user or the ad request is subject to GDPR, we truncate the location data to three decimal places to be less precise before storing such data. Similarly, if you are resident of Virginia or Colorado, when we receive precise location information and we know the user or the ad request, we truncate the location data to three decimal places to be less precise before storing such data
Inferences drawn from any of the information identified in this subdivision. We may draw inferences from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We may sell or share the categories of Personal Information specified above, including:
Inferences drawn from any of the categories of information specified above.
For information about how to opt-out of sale or sharing of your Personal Information please see Section 12 (Important Notice for to Residents in the United States).
Provide and share important information about our Services, and for our marketing efforts to customers.
Understand and improve our and our customers’ websites, marketing activities and services.
Provide our Services and help our customers delivered tailored advertising to consumers.
Deliver targeted, location-based ads for our customers as part of our Services.
Help our customers buy digital media and deliver targeted ads to consumers. This third party information includes information about consumer preferences and behaviors that third parties collect to create profiles about consumers reflecting their preferences, characteristics, psychological trends, predispositions, behaviors, attitudes, intelligence, abilities and aptitudes.
Comply with legal and regulatory laws & regulatory obligations.
The categories of sources from which we collect Personal Information are: (1) our customers, who are advertisers that buy and publishers that sell digital advertising for the purpose of delivering ads to consumers; (2) our Services, typically when we encounter a consumer’s cookie or mobile advertising identifier while providing our Services; and (3) third parties who provide or sell data that helps our customers with their marketing efforts or helps us to deliver our Services. We have no actual knowledge that we sell Personal Information of children under 16 years of age.
To provide relevant ads to users on mobile devices we 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 also use the GPS location of your device if you have opted-in to provide it to one of the publishers or ad exchanges who make digital advertising inventory available through the Services as further described below under “Location Tracking”.
Your iOS mobile device may provide a “Limit Ad Tracking” setting and other settings that allow you to control the data that applications use for location and interest-based advertising. 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 unique device identifier to target ads to you or place you in segments for future marketing. Learn more about setting your privacy preferences on mobile devices at the NAI’s Your Options page.
To opt-out of interest-based advertising for a CTV (i.e., televisions with third party connected applications, smart televisions and/or digital media streaming devices), please visit the NAI’s Internet Connected TV Opt-Out Instructions Page located at https://www.networkadvertising.org/internet-connected-tv-choices/ for detailed instructions on how to use the advertising choice mechanisms for various types of CTVs.
Our affiliates. We share information with our affiliated companies, i.e. companies within our corporate family, which are also subject to this policy.
Our Customers. Beeswax shares certain Personal 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 with data about your cookie and mobile advertising identifiers that interacted with the ads, including IP host addresses and other pseudonymous information in non-aggregated form. When we know the user or the ad request is subject to GDPR, any personal data for which a separate consent has not been received are pseudonymised (one-way hashed) before being shared with customers and are sufficiently protected as required by GDPR (see below for more information about how we handle the transfer of data outside the EEA).
Advertising Partners. We share information with vendors and other third party advertising partners for analytics and advertising-related purposes. Personal Information received by these companies may also be subject to their privacy policies. These parties may act as our service providers, or in certain contexts, may independently decide how to process your information.
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 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.
Administrative or Legal Process. We may disclose your information to third parties in order to protect the legal rights, safety, and security of Beeswax, our corporate affiliates, subsidiaries, business partners, and the users of our Services. We may also disclose your information to respond to and resolve claims or complaints; prevent fraud or for risk, management purposes; and comply with or respond to law enforcement or legal process or a request for cooperation by a government or other entity, whether or not legally required.
Aggregate Information (De-Identified Data): Sometimes, we and/or our services providers aggregate or de-identify information so that it can no longer identify you, under applicable laws and regulations. We share aggregated information, such as usage statistics, with advertisers, sponsors or other organizations. This helps us to better understand and represent our users, such as when we measure ad performance, create advertising interest-based segments or compile survey results. We will use and disclose this aggregated or de-identified information for any purpose, unless such use is prohibited by applicable law.
Other Parties with Your Consent: We may share information with third parties when you affirmatively consent to or direct such sharing.
You may also request that we delete your personal information by sending a verifiable request to email@example.com. Please note that the information we collect and retain through the Beeswax technology for our customers is limited to cookie identifiers. We will need you to provide us with your Beeswax cookie ID in order for us to delete your data. On Chrome, you can find this information in the developer console of your browser.
Our computer servers that store Personal Information for our Services may be located in the U.S. If you are located outside of the U.S., please be aware that any information provided to us, including Personal Information, will be transferred from your country of origin to, and processed in, the U.S. We comply with all applicable laws to protect the security of data during international transfer, for instance by using European Commission approved standard contractual clauses and appropriate supplementary measures when a transfer is made to a third party country that is not considered adequate by the EU Commission or the UK.
We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We commit to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) to address any privacy-related complaints from you. If you do not receive timely acknowledgment of your privacy-related complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.
With regard to the General Data Protection Regulation (“GDPR”), Beeswax’s role depends upon the personal data we collect and the circumstances under which we process it.
We process personal data in several ways, each with respect for the privacy rights of individuals. When we are acting either as the data controller or data processor for our customers, we rely on the following lawful bases for our processing:
Performance of contract. We need to collect and process personal data in order to deliver our Services as required by our contracts with 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 legal and contractual rights and obligations, for example, by analyzing data for signs of fraud.
Data subject consent. To the extent our we or our customers need to collect and share, or to allow us to facilitate the collection and sharing of personal data to enable our Services, we or our customers may do so after providing necessary privacy notices and obtaining required consents.
Residents of the UK and EU have the right to request that we:
Provide you information about how we use your Personal Information;
Give you access to, and a copy of, your Personal Information we hold in our systems;
Stop contacting you;
Correct, update or delete your Personal Information in our records;
Restrict how we use your Personal Information;
Stop using, and ensure that all of our service providers stop using, some or all of your Personal Information; and
Lodge a complaint with your local data protection authority about our use of your Personal Information. A list of data protection authorities can be found here.
To initiate any of the actions set forth above, please contact us at Privacy@beeswax.com.
Beeswax has appointed EU and UK Representatives to act as its direct contact for Data Subjects and relevant Supervisory Authorities.
Comcast International France SAS has been appointed to act as Beeswax’s EU Representative under Article 27 of the GDPR.
All enquiries from EU Data Subjects related to personal data processing in the EU or from the Supervisory Authorities should be addressed to firstname.lastname@example.org or by sending a letter to address listed below:
Comcast International France SAS
123 Avenue Charles de Gaulle
Neuilly Sur Seine
Comcast International Holdings UK Limited has been appointed to act as Beeswax’s UK Representative under Article 27 of the UK GDPR.
All enquiries from UK Data Subjects related to personal data processing in the UK or from the UK Information Commissioner’s Office should be addressed to email@example.com or by sending a letter to the address listed below:
Comcast International Holdings UK Limited
5 Churchill Place
The categories of Personal Information we collect and how that information is used can be can be found in Section 2 (What Information We Collect & How We Use It). Information about how long we retain Personal Information can be found in Section 13 (Data Retention).
We sell or share the following categories of Personal Information:
Personal Identifiers (e.g. IP addresses and cookie IDs)
Internet Activity Information
We sell or share this information with our customers and advertising partners to provide the Beeswax Services.
Right to Deletion of Personal Information. You have the right to request that we delete Personal Information about you that we have collected from you. We will delete such Personal Information except where a legal exception applies. In cases where we do not delete your data as requested, we will notify you of the categories of data we did not delete and why.
Right to Correct Personal Information. If you believe that any of the information we store or maintain about you is incorrect, you may request that we correct that information. You may be required to provide documentation to verify the accuracy of the information in question. Right to Opt-Out from Sales of Personal Information
Right to No Discrimination. We may not discriminate against you because of your exercise of any of the foregoing rights under the CCPA. Beeswax does not discriminate in response to privacy rights requests from California consumers.
Except for the methods for managing your Personal Information described in this policy and your ability to opt-out via a GPC enabled browser, 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.
We do not use Sensitive Personal Information for profiling purposes.
If you are a California resident, you may request to exercise the foregoing rights by:
Submitting a request to firstname.lastname@example.org or by calling us at +1 (866)-I-OPT-OUT (service code 1071).
In addition to the methods specified above, you may also opt of the sale or sharing of your Personal Information by clicking on the “Do Not Sell or Share My Personal Information” link, located at the bottom of our Site. In our role as a service provider to website publishers and their other service providers, Beeswax participates in the Digital Advertising Alliance’s CCPA/CPRA Opt Out program. For more information on exercising your right to opt-out of sales of your Personal Information by these third parties, see the DAA’s CCPA Opt Out Tools page.
Consumers located in the U.S. may also authorize an agent to make a request on your behalf. If you use an agent, you must instruct them to contact us as instructed above. Please note that we may take steps to verify your or your agent’s identity, as well as your agent’s authority to act on your behalf, before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. We cannot disclose or delete Personal Information if we cannot verify the identity of the person making the request, including verifying that your agent is acting on your behalf. We may also limit our response to your exercise of the above rights as permitted by law.
In our role as a service provider to website publishers and their other service providers, Beeswax participates in the Digital Advertising Alliance’s CCPA Opt Out program. For more information on exercising your right to opt-out of sales of your Personal Information by these third parties, see the DAA’s CCPA Opt Out Tools page.
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 necessary for running advertising campaigns and for no longer than 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 advertising 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.
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: email@example.com. If you are unable to obtain the information or resolution that you seek, you may also contact our Data Protection Officer at firstname.lastname@example.org.