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PLATFORM PRIVACY POLICY 

It’s worth knowing what we will and won’t do with your information.

Beachfront Media, LLC, (“Beachfront”, “BFM”, “we”, or “us"), is committed to protecting your privacy when you use our products and services, including transparency and accountability in our privacy practices. The following Platform Privacy Policy was prepared to inform you of the information we collect about you, how that information is used, whether and to whom we disclose it, and the choices you have regarding your personal information relating to. the collection, use and disclosure of information we receive from users of our services (“Services”). For information specific to your access to and use of BFM’s website at www.beachfront.com (“Site”), please visit our “Website Privacy Policy” available at https://www.beachfront.com/beachfront-media-corporate-website-privacy-policy.  

The purpose of this Platform Privacy Policy is to inform you of the following:

  • Who we are and the Services we provide so that you can understand how our business may impact your privacy.
  • What kind of information, including any personally identifiable information, is collected from you.
  • Who collects the information, how the information is used, with whom the information may be shared.
  • What choices are available to you regarding collection, use, deletion, and distribution of the information.
  • The security procedures that are in place to protect the information; and how you can correct any inaccuracies in the information.

It is very important that you read and understand our Platform Privacy Policy. If you do not accept the terms set out in our Platform Privacy Policy, please do not use our Services. We may update this Platform Privacy Policy from time to time. We will advise you that changes have been made by posting a notice on our website or otherwise. Your use of our Services constitutes your acceptance of the terms of our Platform Privacy Policy, as may be amended or revised by us, and you are advised to consult our Platform Privacy Policy regularly for any changes (revisions will be reflected by the “last update” notation above). If you have any questions regarding BFM’s policies or practices relating to privacy, please direct them to privacy@beachfront.com.

This privacy policy applies only to BFM. It does not apply to the practices of companies that BFM does not own or control, or to people that we do not employ or manage.

OUR BUSINESS

BFM has a technology platform.

We use our proprietary technology to offer advertising solutions to our clients, which includes working with advertisers to deliver their advertising campaigns across our network of publishers and application (“app”) developers (our ”BFM Platform”).

We offer technologies to advertisers and publishers that allow them to sell and purchase space or digital advertisements to try and ensure that the audience they desire sees their ads and that the advertising itself is delivered and its performance can be analyzed. We act as intermediaries that connect advertisers and publishers to deliver relevant digital ads. Types of data that may be used for this purpose range from behavioral or interest-related information to geographical or demographic user data. We participate in the IAB’s Transparency & Consent Framework and comply with its specifications and policies.      

INFORMATION COLLECTION AND HOW WE COLLECT IT

Personally Identifiable Information.

We collect personally identifiable information in order to help our clients buy, sell, and deliver online advertising. “Personally Identifiable Information” or “PII” means information that alone or when in combination with other information we collect, may be used to readily identify, contact, or locate you. There may be some opportunities, for example when you use our Site or Services, where you may choose to enter your name, contact information, and other personal details. For example, if you were interested in becoming one of our clients or using our Services you could provide us with contact details through our Site.

We also may collect device advertising IDs: unique identifiers used for advertising purposes on various devices, including mobile devices, Connected TV (CTV) devices, and others. Some examples of device advertising IDs (not an exhaustive list) are the following: (a) Identifier for Advertisers (IDFA) is used on Apple devices running iOS (b) Android Advertising ID (AAID) is used on Android devices; (c) Google Advertising ID (GAID) is a unique advertising ID assigned to Android devices by Google Play services (d) Roku Advertising ID is a unique identifier assigned to Roku devices; (e) LG Smart TV Advertising ID is a unique identifier assigned to LG smart TVs, (f) Samsung Smart TV Advertising ID is a unique identifier assigned to Samsung smart TVs; and (g) third-party IDs: unique identifiers that belong to third parties. Third-party IDs may be associated with broad aggregate audience segments and shared with advertisers to serve more relevant ads to you based on your interests (for example, ads related to sports or fashion).

Non-Personally Identifiable Information.

Non-personally identifiable information is information that, without additional information, cannot be linked to a specific individual by us. We may collect non-personally identifiable information while you are visiting our Site or the websites of one of our advertisers or publishers (collectively, “Customers”). For example, while providing the Services to publishers, advertisers and those working for them, we may collect your IP address, Web pages that you visit, the time and date, and whether or not you clicked on various advertisements (collectively, “Web Surfing Data”).         

TECHNOLOGIES WE MAY USE FOR DATA COLLECTION

We use different types of technologies to collect non-personally identifiable information, including cookies, action tags, Web beacons, and single pixel GIFs.

Cookies

A cookie is a small data file that is transferred to your computer’s hard disk for record-keeping purposes when you request through your browser to receive a particular Web page or content. We use these cookies for three purposes:

Persistent Cookies for Customers Use of Our Site

For our Customers who login to our Site so that they may use our Services, we utilize persistent cookies to potentially save your login information for future logins to the Site. This functionality works as it does on many websites that enable you to have an easier experience logging in and navigating their websites. We do not use persistent cookies in connection with helping our customers buy, sell, and deliver online advertising.

Session Cookies to Help Ad Delivery and Accounting

We utilize session ID cookies to enable certain features of the Services, to better understand how you interact with the Services, and to monitor aggregate usage by our users and Web traffic routing on the Services. Unlike persistent cookies, session cookies are deleted from your computer when you close your browser.

User Data Cookies for Ad Targeting

We utilize cookies to store user data that can aid in targeting of advertisements. This data is usually collected by our Customers and used to deliver advertisements that are more relevant to a user’s interests.

Use of Cookies By Others

Also, the Web publisher or advertiser with whom we partner may use cookies, action tags, GIFs, or Web beacons to collect information when you are visiting their websites. The information they collect is governed by their individual privacy policies, not ours. You are encouraged to read the privacy policies or statements of the other websites that you visit. You can learn more about how cookies and related technologies are used in connection with online advertising and analytics by visiting: http://www.aboutads.info/how-interest-based-ads-work.

OPT-OUT PROCEDURE AND COOKIE CONTROL

Should you wish to opt-out of us placing a cookie on your browser, you can click here to deploy an “opt-out” cookie on your browser. This cookie, when installed on your browser, will prevent us from placing a new cookie on that browser and from collecting data on that browser.

Our opt-out tool is cookie-based. Opt-out tools only prevent us from collecting data pertaining to you on the browser on which they are installed and will only function if your browser is set to accept third-party cookies. If you delete an opt-out cookie from a browser’s cookie files, we may collect data and place a new cookie unless an opt-out cookie is reset on that browser. If you block third-party cookies from being set on your browser, you may not be able to enjoy some features or functionality, and you may see the same content and advertisements repeatedly on some websites.

OPT-OUT PROCEDURE FOR MOBILE INTERNET-BASED, MOBILE DEVICE OR CTV ADVERTISING

Some of our partners may collect information on mobile internet based sites, mobile or CTV (also known as smart TVs or connected TV devices). Should you wish to opt-out of this type of targeting on both Android and/or IOS platforms please click on the below links:

Android:

https://developer.android.com/google/play-services/id.html#get_started 

IOS:

http://support.apple.com/kb/HT4228 

Opting Out of Interest-Based Advertising on CTVs

Our Customers may display interest-based advertising on CTVs (based on your use of CTVs over time and across non-affiliated CTV apps). To learn more about these practices and how to opt out, please review your connected TV’s settings menu and visit https://thenai.org/opt-out/connected-tv-choices/.   

USE OF INFORMATION WE COLLECT

Use of Non-Personally-Identifiable Information

The non-personally identifiable data that we and/or our Customers collect when using the Services are used for marketing and sales efforts and to better target advertisements to people across the different websites they visit. We may also use the non-personally identifiable data to better target content to individuals in an effort to create a personally relevant experience for each person. The non-personally identifiable data is also used to predict responses to advertisements, and to help determine which ads perform best and which ads are most appropriate for different individuals.

Use of Personally-Identifiable Information

We use personally identifiable information we receive primarily to communicate with our Customers as we provide the Services. We use information we receive from business customer prospects in the same ways.

Data from Customers

We allow our Customers to import data that they have collected or purchased to deliver advertisements to certain audiences through the Services. We are not responsible for and do not control the collection of this data. If you wish to opt out of collection of your information by third parties, then you must do so directly with those third parties.

SHARING AND DISCLOSURE OF COLLECTED INFORMATION

We do not provide personally identifiable information to our Customers or other third parties for their marketing purposes except under the following conditions. If a visitor to our Site provides personally identifiable information as part of an inquiry about products or services provided by us, we will provide that information only to the proper unit/individual so that they may attempt to respond to the inquiry.

We may share non-personally identifiable information collected via our BFM Platform with unaffiliated third parties for our business purposes. This does not include users from the European Economic Area (“EEA”), the United Kingdom (“UK”) and Switzerland. We may also disclose and share user level Non-PII and aggregate Non-PII collected via our BFM Platform with unaffiliated third parties for our business purposes, including but not limited to enabling our business partners to help us target ads via the BFM Platform. This information cannot be used to contact or identify any person individually.

We may also disclose your information to third parties when obligated to do so by law and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person.

Like most businesses, we will use information we receive for our business purposes and keep this information for as long as we have a legitimate business purpose as permitted by applicable law. We may also disclose your information to third parties when obligated to do so by law and in order to investigate, prevent, or take action regarding suspected, or actual prohibited activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person.

Purposes and Legal Bases for Processing Personal Data

We Process your information to provide our Services when it is permitted by law and supported by a valid legal justification (“Legal Basis”). We rely on the Legal Basis of consent for the following Processing activities:

  • Ad delivery: to deliver ads to you;
  • Ad reporting: to verify an ad was delivered to you with accuracy;
  • Cookie syncing: to match our cookie IDs with third-party IDs to more effectively deliver relevant ads to you. When we are authorized to use a cookie ID, we try to match it against third-party IDs and third-party cookie IDs.; and
  • Impression Counting: to count the number of times ads are displayed against a Digital ID.

We rely on the Legal Basis of legitimate interests for the following Processing activities:

  • Ad vetting: to prevent fraud, malware, and other unacceptable behavior; and
  • Troubleshooting, optimizing, and product improvement: to improve our Services and ensure ads are delivered correctly to you.

We rely on the Legal Basis of legal obligations for the following Processing activity:

  • Privacy Rights: to view and enforce your opt-out choices, and honor your privacy choices/rights. For example, if you make a request to delete your Personal Data, we will use your Personal Data to search, identify, and delete your Personal Data.
We do not sell, license or share information that individually identifies our customers with companies, organizations, or individuals outside of BFM.

Service Providers

We may employ third-party companies and individuals to provide the Services on our behalf, including without limitation, maintenance services, database management, Web analytics, security and quality of advertising, and improvement of the Site’s features, or to assist us in analyzing how our Site and Services are used (“Service Providers”). These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. For a list of our current Service Providers, you can contact privacy@beachfront.com. If you object to your information being shared by any new Services Providers after you have signed up for the Services, we will tell you how you may opt-out of having your information shared with these new Services Providers.

Compliance with Laws and Law Enforcement

We may disclose information when necessary, in cooperation with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose information about you to government or to law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including, but not limited to subpoenas), or to protect our rights, property, or those of others.

Business Transfers

In addition to the above, there is also the possibility that we may one day be purchased by, or merged with, another company or otherwise be reorganized or sold. If that’s the case, the acquiring (or merging) company will have access to your information.

DATA RETENTION

The amount of time that we retain personal data we collect on our systems varies in length based on the type of data collected but is only retained by us so long as necessary to fulfill our legitimate business needs or as required to meet legal or regulatory requirements. We may also create and retain anonymized information and continue to use this information in accordance with our privacy policy. Specifically, we retain data as follows:

Personally Identifiable Information

  • We retain account information obtained from vendors and business partners we work with indefinitely but reserve the right to delete such information at our convenience.
  • Any personal information voluntarily provided to us via email communication or through our Site is maintained indefinitely until deleted by the corporate email account owner.

Non-Personally Identifiable Information

  • We retain click-stream data (such as IP address, date/time of visit, browser type, web pages visited, etc.) for up to thirteen (13) months. After thirteen (13) months, information may be stored in aggregate for statistical and analysis purposes or is deleted.
  • We retain behavioral segment data, excluding such data of EU and UK users, for periods as short as thirty (30) days, but may retain some behavioral segment data for up to thirteen (13) months. After thirteen (13) months, information may be stored in aggregate for statistical analysis purposes or is deleted.
  • We retain demographic data for periods as short as thirty (30) days, but may retain some demographic data for periods of thirteen (13) months. After thirteen (13) months information may be stored in aggregate for statistical analysis purposes or is deleted.

PRIVACY RIGHTS NOTICE 

If you are a resident of California or located in the EEA, the UK or Switzerland, please see our Privacy Rights Notice available at https://www.beachfront.com/beachfront-media-llc-privacy-rights-notice web policy to learn more about the privacy rights available to you. If you are located in a jurisdiction with data protection laws that you believe offer you privacy rights not described in this Privacy Policy or our Privacy Rights Notice, please contact us at privacy@beachfront.com.       

International Transfers of Personal Information

Our servers are located in the United States, which may be outside the jurisdiction where personal data is collected. Also, some of the third-party service providers with which we may share personal data are located in and may transfer personal data to various jurisdictions. These other jurisdictions may have data protection laws that are different from the laws of your place of residence (and, in some cases, not as protective).  

When we transfer personal data outside of the EEA, the UK or Switzerland, we ensure that appropriate legal protections are in place. These protections may include a transfer mechanism, such as the European Commission’s Standard Contractual Clauses. In the event of any conflict between the terms of this privacy policy and such transfer mechanism, the terms of the transfer mechanism will govern.

LINKS TO WEB PUBLISHERS, ADVERTISERS, & OTHER WEBSITES

Our Services are combined with content from our Customers and other third-party advertisers. Our Services may contain links to other websites. If you choose to visit a Customer or other third-party advertiser by clicking on a banner ad or other type of advertisement, or click on another third-party link, you will be directed to that third-party’s website. Our provision of a link to a website or a banner ad or other type of advertisement is not an endorsement of that website or advertisement, nor is it an endorsement of the privacy or information security policies or practices of that website or advertiser. We are not responsible for the privacy practices or the content of Web publishers, advertisers, or other websites that may be linked to our Site. These other websites may place their own cookies or other files on your computer, collect data, or solicit personal information from you. This Privacy Policy addresses the use and disclosure of information that we collect from you through our Services. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. You are encouraged to read the privacy policies or statements of the other websites you visit.

ACCESSING YOUR PERSONALLY IDENTIFIABLE INFORMATION, MAKING CHANGES, OR REQUESTING DELETION

Where we process personally-identifiable information on our own behalf, you may request access to, correction of, or deletion of personal data held by us by filling out a Data Subject Access Request form at https://www.beachfront.com/data-subject-access-request. Because we generally process data for others, for any of that data you should make your request directly to the party collecting the information or on whose behalf it has been collected.

SECURITY

We use technical, physical and administrative safeguards intended to protect the personal information that we collect from and about you through the Services. Our safeguards are designed to provide a level of security appropriate to the risk of processing your personal information and include (as applicable) measures to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and a procedure for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of personal information. We have an internal security policy with respect to the confidentiality of customer and other data, limiting access only to those employees who we reasonably believe need to know such information for the purpose of performing their jobs. However, no company, including BFM, can fully eliminate security risks associated with personal information. 

INCIDENT MANAGEMENT

If we become aware of any accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to any personal data transmitted, stored or otherwise processed on our equipment or in our facilities (“Security Breach”), we will promptly notify our Data Controllers and respective parties of the Security Breach without undue delay, investigate the Security Breach and provide Data Controllers and respective parties with all relevant information and take all steps to mitigate the effects and to minimize any damage resulting from the Security Breach.

CHILDREN

Neither this Site nor the Services is directed to children under 13. We do not knowingly collect personally identifiable information from children under 13. No sensitive segments or segments are targeted at children. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at privacy@beachfront.com. If we become aware that a child under 13 has provided us with personally identifiable information, we will delete such information from our files.

YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits end users who are California residents to request certain information regarding BFM’s disclosure of personally identifiable information to third parties for their direct marketing purposes. To make such a request, please email privacy@beachfront.com.

CHANGES TO PRIVACY POLICY

BFM is committed to continually examining and reviewing its privacy practices, and may make changes to its Privacy Policy. In the event that any changes that we believe are material are made to the company’s privacy practices, we will post a dated revised Privacy Policy on this website.

 

LAST UPDATED MAY 8, 2024