Services Privacy Policy

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

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.

The Beeswax Services are intended primarily for use by businesses. We may also collect personal information from individuals who visit our websites, interact with our marketing messages and emails, or engage with us about career opportunities with Beeswax. For information about the privacy practices that apply to these interactions, please visit our Website Privacy Policy.

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

Privacy Practices for Our Technology

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 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 published by the Digital Advertising Alliance (DAA), the European Principles published by the European Interactive Digital Advertising Alliance (EDAA), and the Self-Regulatory Principles published by the Digital Advertising Alliance of Canada (DAAC). We honor the DAA’s, CDAA’s, and EDAA’s opt-out mechanisms for data collection and use in connection with mobile applications. To learn more about the self-regulatory principles of the DAA, CDAA, and EDAA and your choices, please visit our Cookie Policy.

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 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), 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).

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, communicate via email regarding our current and future offerings, and/or provide and receive feedback on our Services.

Analytics

Like most organizations, we rely on automatic data collection technology to collect information 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. We use this data to analyze the use of and improve our Services.

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 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 may 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.

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. If you do not want us or our service providers to place a cookie on your hard drive, you may be able to turn that feature off in your browser or device settings, and you may opt out here from our use of Beeswax cookies on your device. Detailed information about managing cookies on your devices is provided in our Cookie Policy.

Pixel Tags

We also use pixel tags, which are small, invisible 1x1 images on a web page. Pixel tags allow us to set, read and modify cookies when you visit the websites or apps of our partners.

Please click our opt out 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 opt-out cookies are necessary to fulfill your opt-out requests. If you block, delete or restrict cookies in any way, your opt-out request will not work. Also, opt-out settings are specific to each browser or device, so you will need to set your opt-out preference for each one, and if you use a different computer or Internet browser, you may need to renew your opt-out choice.

If you opt-out through this method, we will not use your personal information in our Services; however, we may continue to use your information collected for other purposes, such as our own marketing. If you wish to opt-out of such other uses of your information, see our Website Privacy Policy.

Location Tracking

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.

Information We Receive from Third Parties

We may also receive information about you from third parties when you interact with third party sites or apps. 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 services privacy policy and requirements under applicable data protection and privacy laws.

Use of Cross-Device Linking

Beeswax may offer cross-device linking services to our customers. These services attempt to identify which identifiers are associated with the same user across multiple devices, such as between a desktop computer and a mobile device. To enable these services, we may, subject to the section on Onward Transfer to Third Parties, share your pseudonymised information with contracted third parties that provide cross-device linking services. For consumers who have opted-out from the use of your personal information by Beeswax, we do not share any of your information with these third parties and do not attempt to re-identify the user in any way. We do not utilize cross-device linking services when we know the user or the ad request is subject to GDPR or otherwise not permitted. To effectively opt-out of our cross-device linking services, users must opt-out on every device and browser using our opt-out methods described in the Cookies section of this policy, including in the section on Mobile Tracking. Detailed information about managing cookies and mobile tracking on your devices is provided in our Cookie Policy.

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 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 pseudonymized (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).

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 in support of our Services and their functions are: data analytics vendors, data hosting providers, optimization vendors, and document hosting and support services providers. 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 have the right to 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 services 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.

Access to Personal Information

Upon receipt of a verifiable request to privacy@beeswax.com, we will provide you with confirmation as to whether we are processing your personal information, and where we are the controller of such data, we will have it communicated to you within a reasonable time. In cases where we are acting as a service provider to our customers, we are a data processor, and we do not directly control any personal data, so any changes or inaccuracies in the data we collect should be addressed to the businesses that are the controllers of such data. Please allow us a reasonable time to respond to your inquiries and requests. For information about the privacy practices that apply to our websites, please visit our Website Privacy Policy.

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 13 (or higher age where required by applicable law) through the platform. If you are under 13 (or higher age where required by applicable law), 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 (or higher age where applicable) has provided personal information to us, please contact us at privacy@beeswax.com, and we will act on your request as required by applicable laws.

Links to External Websites

The Beeswax technology may contain links to third party websites, content and services (“External Sites”). Where Beeswax has relationships with such third parties, we use reasonable efforts to require our customers and partners to treat the personal information we share with them in accordance with applicable laws, the terms of any contracts we may have with them, and their own privacy policies, but otherwise we cannot control their use of this information. Where we have no such relationship, we are not responsible for the privacy policies of those External Sites or their use of personal information. 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 computer servers that store personal information for our Services may be 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 and processed in the US. Your decision to provide such data to us or allow us to collect such data through our technology constitutes your consent to this data transfer and processing.

Important Notice for Residents of the European Economic Area, UK and Switzerland

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.

Where Beeswax acts as a data processor, we do so for our customers and other companies that interact with our Services for our customers, all of whom are obligated to have a lawful basis for processing personal data, such as the consumer’s consent, 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 cookies on the consumer’s devices and either consent or another lawful basis for the use of related data within Beeswax's system, and to respect opt-outs and the other obligations under the GDPR.

Where Beeswax acts as a data controller, we collect and process personal data to provide and enhance our Services for our customers. For example, we use cookies to assist our customers personalize the advertisements you are served and to compile anonymous, aggregated statistics that allow us to understand how people use the websites where our customers’ advertisements are served and react to these advertisements.

Lawful Basis for EU Data Processing

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.

Privacy Shield

The EU-US Privacy Shield Framework was invalidated by the European Court of Justice in July 2020; nevertheless, Beeswax will continue to comply with it and the Swiss-U.S. Privacy Shield Framework, in each case 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-US 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

This section of our website privacy policy applies to consumers who reside in California. If this section differs from other sections in this policy, this section governs for California consumers only.

California residents have the right to be informed about our practices regarding the collection, use, disclosure, and sale of personal information. Specifically, under the California Consumer Privacy Act (“CCPA”), California consumers have the right to request disclosure and deletion of their personal information, the right not to be discriminated against for exercising one of their California privacy rights, and the right to opt-out of the sale of their personal information by a business.

CCPA Disclosures

In the, WHAT INFORMATION WE COLLECT, THE PURPOSE OF COLLECTION AND USE section of this policy, we describe in detail the information we collect from consumers and the purposes for which we use this information, which includes the information we have collected in the twelve (12) months preceding the date of this update to our policy. The categories of personal information we collect and the business purposes for such information generally include: (1) contact information from our customers and others who have authorized access to our Services, which we use to provide and share important information about our Services, and for our marketing efforts to customers; (2) analytics information, which helps us understand and improve our and our customers’ websites, marketing activities and services; (3) identifiers, such as cookie and mobile advertising identifiers, which we use in our Services in connection with pixel tags to help our customers delivered tailored advertising to consumers; (4) location information, which we use in our Services to deliver targeted, location-based ads for our customers; (5) information we obtain from third parties, such as cross-device linking data and audience data, which we use in our Services to help our customers buy digital media and deliver targeted ads to consumers. This third party information may include 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.

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.

In the, Onward Transfer to Third Parties section of this policy, we describe in detail the information that we disclose or sell to third parties for a business purpose. The categories of such personal information generally include: (1) reports to customers about their use of our Services, such as whether their targeted ads have reached the intended consumers; (2) certain information described in the previous paragraph, which we provide to our customers and third parties who provide our customers with related services, or to publishers who sell digital advertising media to advertisers. We have no actual knowledge that we sell personal information of children under 16 years of age.

Your California Privacy Rights Under CCPA

If you are a California resident, CCPA provides you the following rights. We will honor requests to exercise these rights to the extent required by law and within the time provided by law. In doing so, where we are acting as a service provider to our customers or other businesses in our processing of your personal information, we may refer requests to access or delete personal information to those businesses.

Right To Access And Information Regarding Personal Information

You have the right to request that we disclose to you the categories and specific pieces of personal information about you that we have collected or sold, the sources for such information, and our business purpose. These disclosures are in the preceding “CCPA Disclosures” section of this policy. We will deliver personal information that we are required by law to disclose to you in the manner required by law within 45 days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law. We may deliver the personal information to you electronically or by e-mail at your option. If electronically, then we will deliver the information in a portable and readily usable format that allows you to transmit the information from one entity to another without hindrance.

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 Opt-Out from Sales of Personal Information

Our Services include the transfer of personal information to our customers and other participants in the digital advertising market that may qualify as sales of personal information under CCPA. You have the right at any time to direct us not to sell your personal information, which is known as your right to opt out. See the Requests to Exercise Your California Privacy Rights section below to opt-out.

In other cases, Beeswax collects and processes personal information as a service provider for website publishers and other service providers that they use. If they inform us that you have exercised your right to opt-out of their sale of personal information, we comply with such requests in accordance with CCPA.

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.

Requests to Exercise Your California Privacy Rights

If you are a California resident, you may request to exercise the foregoing rights by:

  • Submitting a request to privacy@beeswax.com or by calling us at +1 (866)-I-OPT-OUT (service code 1071).
  • You may also opt out here from our further use or sale of our cookie data as described in our Cookie Policy which is considered under CCPA to be part of your personal information.
  • California consumers may also authorize your 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. For example, CCPA requires us not to 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.

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. Except for the methods for managing your personal information described in this policy, 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.

You may contact us regarding these California privacy disclosures as noted in the Contacting Us section of this policy.

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 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.

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.

Updated: October 1, 2020