PRIVACY POLICY

Effective Date: February 1, 2018

  1. Introduction

  2. Information We Collect

  3. Cookies and Similar Technologies

  4. Our Use of Information We Collect

  5. Sharing of Information with Third Parties

  6. Your Choices, Including Opt-Out Options

  7. Security

  8. Children

  9. Third-Party Websites

  10. Applicable Law

  11. Changes to this Privacy Policy

  12. Questions/Contacting Us 

1. Introduction 

BrightLine Partners LLC ("BrightLine," "we," "us," or “our”) respects your privacy. This Privacy Policy explains how, when, and why BrightLine collects, uses, and shares information from or about the visitors to brightline.tv (the “BrightLine Site”) and subscribers to ‘over-the-top’ or ‘living room’ applications (or “apps,”including mobile apps), services, or devices (“OTT Platforms”) that may interact with or use the BrightLine Services, as such term is defined below.

Our ad technology service, used for the delivery of our (or a third party’s) enhanced video ads and related advertising content (collectively, "Content"), Content renderer and accompanying development tools (the “SDK”), and any other products, features, tools, materials, or other services offered from time to time by BrightLine through the OTT Platforms are referred to collectively as the "BrightLine Services."

By visiting the BrightLine Site, you are agreeing to the terms of this Privacy Policy and the BrightLine Site’s Terms of Use

By viewing, interacting with, or using the BrightLine Services (such as through interaction with Content), you are agreeing to the terms of this Privacy Policy. Please note that the privacy policy, terms of use, or other agreement of the OTT Platform using the BrightLine Services may also apply to your and/or our use of the BrightLine Services (see 9. Third Party Websites).

This Privacy Policy includes certain embedded hyperlinks that, depending on the device through which you are viewing it, may not be accessible. Therefore, you may need to visit the BrightLine Site on your computer to access the hyperlinks.

2. Information We Collect

BrightLine may collect the following information from or about you (collectively, “Information”):

  • Information You Provide To Us. On the BrightLine Site, you may sign up for our CTV Insight Newsletter by providing your email address, at which point you will receive marketing emails in the form of news and updates. Further, we may request via the Content delivered through the BrightLine Services that you provide your name, email address, phone number, or other Information to us and/or Business Partners (the term “Business Partners” is defined in 9. Sharing of Information with Third Parties) , such as for promotions or for other reasons that are disclosed within such Content.

  • Usage and Log Data. We also collect Information when you interact with or view Content through the BrightLine Services or when you interact with or view the BrightLine Site (such as through our use of Google Analytics). Examples of such Information may include your IP address, device, browser, and software characteristics (e.g., type and operating system), location, activity on the BrightLine Services (e.g., metrics regarding exposure and interactions with Content) or BrightLine Site, device identifiers or other unique identifiers such as advertising identifiers (e.g., AAID or IDFA), cookies identifiers, and server-generated identifiers based on a combination of device, carrier, and location attributes (see our description of "Cookies and Local Storage" below for the technology behind such data collection).  

  • Third-Party Data. We may also collect Information about you from other sources, such as data aggregators, public databases, and our Business Partners. Examples of this may include Information (whether identified, de-identified, or anonymous, and whether collected online or offline) about your interests, demographic data, purchasing behavior, and your activities online (such as websites visited and advertisements viewed). We may combine the Information we collect from or about you and use it in the manner described in this Privacy Policy or as otherwise permitted by law.

3. Cookies and Similar Technologies

Like many online services, we use various technologies to collect certain Information described above (e.g., Usage and Log Data). These technologies are discussed below.

  • Cookies and Local Storage. One technology we use is called a cookie. A cookie is a small data file that is transferred to your computer’s hard disk. We may use both session cookies and persistent cookies to better understand how you interact with the BrightLine Services, monitor aggregate usage and web traffic routing on the BrightLine Site and BrightLine Services, and to customize Content. These uses allow us to improve the BrightLine Site and the BrightLine Services, as applicable. We may create a unique device or user ID for you and store it in a cookie so we can customize your experience based on your preferences.

  • Web Beacons or Pixels. In addition to cookies, we may use other technologies such as web beacons or pixel tags, which can be embedded in web pages, videos, or emails, to collect certain types of Information from your browser or device, check whether you have viewed a particular web page, ad, or email message, and determine, among other things, email open rates, the time and date on which you viewed the Content, the IP address of your computer, and the URL of the web page from which the Content was viewed.

  • SDKs. An SDK is computer code that app developers can include in their apps to enable ads to be shown, designate the data fields to be collected, and implement any related services and functionality. An SDK integrated into an OTT Platform is, in effect, the app version of a pixel tag or beacon. We may use or work with third parties, including our Business Partners and service providers, who use our SDKs within OTT Platforms to collect Information, such as device or advertising identifiers and Information related to how such identifiers interact with the BrightLine Services. We may use this Information, for instance, to analyze how you interact with Content and advertisements and to enable analytics or other features through OTT Platforms.

  • Server Side Identifiers. In some cases, BrightLine will not be able to collect a device ID or set a browser cookie.  In these cases BrightLine will create an identifier or fingerprint from a combination of user agent, carrier, and location Information that will provide a high probability of uniqueness of your OTT Platform.

4. Our Use of Information We Collect.

We use the Information we collect from or about you in order to help deliver a first-class user experience. Our use of this Information may include the following:

  • Providing, securing, enhancing, or improving the BrightLine Site and/or BrightLine Services;

  • contacting you, including for promotional purposes;

  • customizing the Content you view and evaluating how well such Content performs in cooperation with Business Partners, service providers, and other third parties;

  • customizing recommendations;

  • conducting research;

  • compiling aggregate data for internal and external business purposes;

  • preventing potentially illegal or harmful activities;

  • protecting your and our rights;

  • other uses consistent with this Privacy Policy and our Terms of Use; and

  • any other purpose that is disclosed to you at the time we collect the Information or that is related to a request made by you.

Use of Aggregate or De-Identified Information.

In addition to the individual data use described in this Privacy Policy, we may aggregate Information about you and other individuals together, or otherwise "de-identify" the Information about you (which means that the Information does not identify you personally). We may use Information in these forms for any legitimate business purpose, including for research and analysis, administration of the BrightLine Services, advertising, and promotional purposes.

5. Sharing of Information with Third Parties

We may share Information collected from or about you with third parties as explained further below, including Business Partners, service providers, and other third parties not affiliated with BrightLine.

Business Partners.

We work with a number of third-party distribution and media partners that have embedded our SDK, advertisers/advertising technology companies, data vendors, and other strategic partners who use or help us offer the BrightLine Services or BrightLine Site, as applicable (collectively, “Business Partners”).

For example, many of our Business Partners seek to measure the performance of their Content across many OTT Platforms, including through implementation of the BrightLine Services. Accordingly, BrightLine may permit the use of or provide measurement/attribution software or functionality that enables third parties (such as Nielsen) to include your viewing of Content on the BrightLine Services in the calculation of measurement statistics, such as, but not limited to, TV and Digital ratings. To learn more about your choices with respect to Nielsen measurement software, please see the information we have provided in 6. Your Choices, Including Opt-Out Options. 

Relatedly, we may also share certain Information collected from or about you with Business Partners in order to tailor advertisements, measure and improve advertising effectiveness, and enable other enhancements. This Information includes your advertising identifier, IP address, or user agent string (e.g., browser, operating system). On certain Content, we may request to pass along your email address or other certain Information that you input to Business Partners to provide offers displayed in such Content.

Service Providers.

We may share the Information collected from or about you with companies that provide general services to us, including companies that assist with payment processing, analytics, Content distribution, data processing and management, account management, hosting, customer and technical support, marketing (e.g., email, online, or direct mail communications), and other services. These companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.

We may also share your Information with any of our parent companies, subsidiaries, or other companies under common control with us.

When Required By Law or When Necessary to Protect Your or Our Rights.

In some instances, we may disclose Information from or about you without providing you with a choice. For example, we may disclose your Information in the following ways: to protect the legal rights of BrightLine, affiliates, Business Partners, service providers, or other third parties, and each of our respective equity holders, directors, officers, employees, and agents; to protect the safety and security of users of the BrightLine Site, BrightLine Services or third parties; to enforce or as consistent with this Privacy Policy or our Terms of Use; to protect against fraud; for risk management purposes; and to comply with or respond to the law or legal process or a request for cooperation by a government entity, whether or not legally required. If you notify us that you believe your legal rights have been violated by BrightLine, we may provide the Information that you provide to us to others to the extent that we believe it is necessary to evaluate and respond to your complaint.

Third Parties in Connection with Certain Transactions.

In the event of a merger, reorganization, dissolution, or similar corporate event, such as selling all or part of our business, making a transfer of assets, or otherwise being involved in a change of control transaction, or in the unlikely event of bankruptcy, we may transfer Information from or about you to one or more third parties as part of the transaction, including in the due diligence process.

Third Parties with Your Consent or When You Otherwise Choose to Share.

In addition to the sharing described in this Privacy Policy, we may share any Information from or about you with any party when we have your consent or when you otherwise choose to share such Information. Also, certain functions within the BrightLine Services may give you the option to share Information about your activities on the BrightLine Services, for example, by email, text message, social networking, or other sharing function.

6. Your Choices, Including Opt-Out Options

Personal Information Rights.

Subject to applicable law, you have the right to request correction, amendment, or deletion of personal information that we may have on you by sending an email to us at privacy@brightline.tv with “Privacy Policy” in the subject line. Please allow us a reasonable time to respond to your request.

Email Marketing.

You may manage your receipt of marketing and non-transactional communications by clicking on the "Unsubscribe" link located on the bottom of any BrightLine marketing email and following the instructions found on the page to which the link takes you. You cannot opt out of receiving transactional or administrative e-mails. Please allow us a reasonable time to process your request.

 BrightLine Site Analytics.

The BrightLine Site uses Google Analytics for analytics purposes. For more information on Google Analytics, including how to opt out of data collection, please visit https://www.google.com/analytics.

Further, if you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device.  Please consult your Internet browser’s documentation for information on how to do this.  However, if you decide not to accept cookies from us, some features of the BrightLine Site may not function properly. 

Opt-Out from Nielsen Measurement.

The BrightLine Services may feature Nielsen Total Audience or Digital Ad Ratings when you view Content on BrightLine Services, which is used to measure the audience composition of ad campaigns. To learn more about the information that Nielsen software may collect, and opt-out information for browser and mobile, please see the Nielsen Digital Measurement Privacy Policy at http://www.nielsen.com/digitalprivacy.

 Opt-out Options for Interest-Based or Online Behavioral Advertising within Mobile Devices (iOS and Android)

On your mobile device, you may also go to your device settings and select "Limit Ad Tracking" (for iOS devices) or "Opt out of Interest-Based Ads" (for Android devices), which will allow you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests. Please note that if you opt out using one of the methods set forth above, that opt-out will apply at the “device level” (i.e., only to the specific device from which you opted-out).

Opt-Out Options for Interest-Based or Online Behavioral Advertising within OTT Platforms.

OTT Platforms may provide their own opt-out mechanisms. In such case, you will be opted out at the “app level” (i.e., for that OTT Platform only). Please note that the below are only a subset of opt-outs that may be available; please check your OTT Platform’s privacy policy for any applicable opt-out mechanism.

  • Roku. To opt-out of OBA ads on a Roku device, please visit the Roku privacy policy at https://docs.roku.com/doc/userprivacypolicy/en-us where you will find the latest information on opting out.

  • AppleTV. To opt-out of OBA ads on an AppleTV device, please follow the instructions found here: https://support.apple.com/en-us/HT202074

  • Samsung. You can opt out of receiving targeted advertising from AdHub here: https://account.samsung.com/membership/etc/setPersonalOption.do?openPage=adsCombination. Please note that if you opt out, you will continue to see ads, but they may be less relevant to you because they will not be based on your interests.

  • FireTV. Go to Settings>System>Advertising ID and toggle the “Interest-based Ads” button to Off

  • Xbox  devices. Go to http://choice.microsoft.com/en-us/opt-out  and toggle the “Personalized ads wherever I use my Microsoft account” to On.  Does require that you login with your Microsoft account used on your Xbox device.

Do Not Track.

  • If an OTT provider passes to us a “Do Not Track” signal in an HTTP header, we will honor it. However, there is currently no consensus among industry participants as to what "Do Not Track" means and how/if to respond to or send "Do Not Track" signals. As such, we do not honor “Do Not Track” signals except as mentioned above.

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 email us at privacy@brightline.tv.

7. Security

We use a variety of physical, technical, and administrative measures to safeguard Information in our possession against loss, theft and unauthorized use, disclosure, and modification. For example, we take steps to limit internal access to Information from or about you to those BrightLine employees, agents, and contractors who have a legitimate business reason to access such Information. We also use measures like encryption and hashing to help protect sensitive Information when in transmission. Despite these efforts, please note that there is always a possibility that a breach in data transmission or storage may occur. We want you to feel confident in our security when using the BrightLine Services and BrightLine Site, but we cannot guarantee the security of any Information from or about you 100% of the time.

8. Children

BrightLine does not knowingly collect personal information from children under thirteen (13) years of age. If you are under thirteen (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 to never provide us personal information.  If you have reason to believe that a child under the age of thirteen (13) has provided personal information to us, please contact us, and we will endeavor to delete that personal information from our databases.

9. Third-Party Websites

When you interact with the BrightLine Services or BrightLine Site,BrightLine, Business Partners, and service providers may collect some information from or about you. The information practices of these third parties are governed by their own privacy policies and are not governed by this Privacy Policy. Please be aware that BrightLine does not notify you when you have chosen to click through to a website or other digital property when using the BrightLine Services. We recommend that you familiarize yourself with the privacy policies of such websites or digital properties to determine how they handle any information they separately collect from you. To learn about opting out of interest-based or online behavioral advertising, please see the information we have provided in 6.Your Choices, Including Opt-Out Options.

10. Applicable Law

BrightLine is headquartered in the U.S. and the BrightLine Services are intended strictly for U.S. audiences. The BrightLine Services, the BrightLine Site, and BrightLine’s servers are operated in the United States. If you are located outside the United States and choose to use the BrightLine Site, the BrightLine Services, and/or any Content you do so at your own risk. Please be aware that your Information, including your personal information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. 

11. Changes to this Privacy Policy

From time to time, we may revise this Privacy Policy to reflect changes in the law,the BrightLine Services, the BrightLine Site,or for other reasons. Therefore, it is important to check the effective date of the Privacy Policy posted at the top of this page each time you visit the BrightLine Site or use any of the BrightLine Services to ensure you are familiar with our most updated policies and practices. If we make any material change to this Privacy Policy, we will notify you by posting a notice on the BrightLine Site. Please be aware that, to the extent permitted by applicable law, our use of your Information is governed by the Privacy Policy in effect at the time we collected such Information. 

12. Questions/Contacting Us

If you have any questions regarding this Privacy Policy, you may email us at privacy@brightline.tv.