Last updated: December 22, 2020

This privacy policy describes how Telaria, Inc. and its affiliates (Telaria, we, us, or our) collects, uses, and shares information through both its video advertising services, including our video management platform, as well as the Telaria website, Telaria.com, and other Telaria digital properties and products that link to this privacy policy (Telaria Site or Site). For information regarding Outstream Services, please visit here.

A. Telaria Video management platform

Telaria operates a self-service software platform that helps our publisher clients (i.e., content owners or other sellers of video advertising inventory, including websites and apps) analyze, manage and monetize their video advertising inventory on internet connected devices and platforms, including mobile devices, computers and connected TVs. This section of our privacy policy explains how our platform collects, receives, uses, and shares information in providing services to our clients.

Information we collect or receive

We work with publishers as instructed by them to analyze, manage and monetize their video advertising inventory.  This video advertising inventory is made available to advertisers, agencies and other media buying platforms, which we collectively refer to as advertisers.  When an advertiser successfully purchases and serves an advertisement to a publisher’s advertising inventory, the video advertisement will be displayed to you in connection with the content that you view.

In order to do this, we receive certain information from the websites and apps where videos are displayed, pass that information to advertisers, and vice-versa. The information we receive may include IP address, location-related data, mobile application data, the web page URL or app in which an individual is viewing a video, video player size, the video title, description, or category being displayed, the date and time of video display, browser or device type, a cookie or device identifier, and other data which the publisher chooses to provide to us.

We may also receive information from third parties at the instruction or for the benefit of our clients, in particular data management platforms and services (either through a publisher or through a relationship that we have directly established) that provide user demographics and information with respect to a users’ preferences, patterns, click and video interactions, behaviors or interests, as well as advertisers and advertising platforms that provide information to us in order to match an ad opportunity offered by our clients with the right advertisement.

Once we deliver that advertisement, we may receive information about how you interact with that advertisement, such as how long you view it and whether you click through to visit the advertiser.

How Telaria uses information

We and our service providers use information for legitimate business purposes including:

• Providing the functionality of our video management platform and fulfilling requests
  • Providing the functionality of our video management platform, in particular matching video advertising inventory with the right advertisement, providing reporting regarding auctions and other transactions, cookie syncing, and frequency capping.
  • Measuring the success of an advertisement.
  • Video ad serving, including hosting an advertisement.

We will engage in these activities with your consent or where we have a legitimate interest.

• Business reporting
  • To analyze or predict service use and prepare aggregated trend reports to support internal business operations and enhance buying opportunities of digital content.
  • For trending and statistics, and to develop, market and/or improve our products and services.

We will engage in these activities where we have a legitimate interest.

• Aggregating and/or anonymizing
  • We may aggregate and/or anonymize information so that it will no longer relate to an identified or identifiable individual. We do so to generate other data for our use, which we may use and disclose for any purpose.

We will engage in these activities where we have a legitimate interest.

• Accomplishing our business purposes
  • For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
  • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
  • To prepare or execute a business transaction, such as a corporate restructuring, merger or acquisition.
  • To protect our rights and to defend against lawsuits.
  • To respond to legal duties, such as requests from public and government authorities.

We engage in these activities to comply with a legal obligation or because we have a legitimate interest.

How Telaria shares information it collects through its video management platform

We disclose information:

• To our affiliates for the purposes described in this privacy policy. You can consult the list and location of our affiliates here.
• To our publisher clients, advertisers, advertising platforms, and technological intermediaries in the digital advertising space in the context of providing our video management platform.
• To our third-party service providers. Who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, auditing and other similar services.
• To business partners in the context of a corporate transaction.
• To public authorities, such as law enforcement agencies.

Children

The Telaria video management platform is directed to, and intended for use by, adults only. We do not knowingly direct our activities to children under the age of sixteen.

Advertising technologies and other information

In order to perform the video management platform, Telaria uses cookies, device identifiers, and other similar technologies. A cookie is a small piece of text data that is stored by your browser. Cookies are commonly assigned by online services, such as websites or ad technologies, to recognize a computer or device that they have encountered before. A device identifier is an alphanumeric identifier generated by the operating system for use in advertising purposes, and it functions in a manner similar to cookies in web browsers. Other technologies that relate to cookies include pixel tags, which are small blocks of code that allow websites to read and place cookies. We may use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time.

In relation to our video management platform, Telaria may use cookies for the benefit of its publisher clients and advertisers in order for them to match an ad opportunity with the right advertisement. To do so, Telaria performs a cookie syncing between the client’s cookies, a cookie Telaria uses for its client’s benefit and the advertiser’s cookies. Telaria also uses a cookie for frequency capping, i.e., to ensure that the same user is not served the same advertisement repeatedly.

As your primary touchpoint, publishers (i.e., the website or application on which you are viewing content) should generally provide mechanisms to ensure, where applicable, that you consent to the cookies and similar technologies set out above. In addition, there are various ways in which you may signal your choices regarding such cookies and similar technologies, including as follows:

• Industry Choice Programs – Telaria supports industry self-regulatory programs for the digital advertising industry, such as the Digital Advertising Alliance (DAA). To learn more about the DAA and its Self-Regulatory Principles you can visit http://youradchoices.com/.
• Location – You may be able to limit our collection and use of precise location data by using your mobile device’s location services settings. These settings may vary from device to device.
• Advertising Identifiers – You may also be able to use the settings offered by your mobile or other Internet connected device to limit the collection of data from that device for advertising purposes. To use those settings, you should check your device’s settings menu. Note that if you use those choice settings, some data may still be collected from your device for various other purposes, and you may still see advertising on that device based on other factors. For more information regarding device settings, you can visit our device opt-out guide here.
• Browser settings – In addition to the options provided above, you may be able refuse or accept cookies by activating the settings on your browser. Information about the procedure to follow in order to enable or disable cookies can be found on your Internet browser provider’s website via your help screen. Please refer to http://www.allaboutcookies.org/manage-cookies/index.html for information on commonly used browsers. Please be aware that if cookies are disabled, not all relevant features may operate as intended.
• Software – If you want to clear all cookies left behind by the websites you have visited, here are links where you can download programs that clean out tracking cookies:
• http://www.lavasoftusa.com/products/ad-aware_se_personal.php
• http://www.spybot.info/en/download/index.html
• http://www.webroot.com/consumer/products/spysweeper/

B. Telaria Corporate Websites

www.telaria.com, and other digital Telaria properties that link to this privacy policy, are the corporate websites of Telaria. The websites (the Telaria Site or Site) provide current and prospective customers, partners, job seekers, and other visitors with information about our products and services, and give users the opportunity to contact us for further information. In addition, if you are a representative of a Telaria client, we may collect information about you in relation to or in the context of your use of our digital properties and products, including when you operate our video management platform. This section of the privacy policy describes the types of information that Telaria collects on the Site and how that information is used. Telaria reserves the right to revise this privacy policy from time to time by posting the changes on the Site. Your continued use of the Site constitutes your acceptance of the current posted privacy policy.

What information does the Telaria Site collect?

Information actively provided. This information includes name, email address, mailing address, or phone number. This is information visitors or users voluntarily provide to the Site. This information is collected on the Telaria Site in various instances including:

• Information requests. A Site user, typically a current or prospective customer, partner, or job seeker, submits an inquiry to the Site such as using the Contact Us, Request a Demo and Sign Me Up functions, and provides his or her name, address, email address, and/or telephone number so that Telaria is able to respond.
• Comment on news, blog, or other posting. A user posts a comment in the blog or news section of the Site, and submits his or her name and email address with the post.
• Subscribe to email newsletter. To subscribe to the Telaria email newsletter, a user may provide his or her name, email address, and other contact information. Newsletters will generally provide the user with the option of unsubscribing from future newsletters.
• Subscription feed. A user subscribes to the Site’s subscription function by providing his or her email address.
• Access to Telaria’s web-based client interface. A current Telaria client accesses the client/customer-only areas of the Site by submitting his or her username and password.
• Request for feedback. From time to time, the Telaria Site may ask users for voluntary feedback that will help us improve the Site. In connection with such feedback, a user may choose to provide optional name and contact information.
• Promotions, sweepstakes, or contests. From time to time, Telaria may sponsor or co-sponsor promotions, sweepstakes or contests, in response to which a user may provide information, such as his or her name, email address, or other contact information, and/or to answer certain questions on an entry form.

Usage information. Usage information includes demographic information (such as age, gender, city, or state) and a user’s clickstream information, such as where the user clicks on the Site, and in which order. The Telaria Site collects information about users and stores it in log files. This information includes usage information that your browser automatically sends whenever you visit the Site, including information about your web request, your IP address, your browser type, browser language, date, and time of the request.

How does Telaria use information collected by the Telaria Site?

• Providing the functionality of the Site and fulfilling your requests.
  • To provide the Site’s functionality to you, such as arranging access to your account, and providing you with related customer service.
  • To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Site.
  • To complete your transactions, and provide you with related customer service.
  • To send administrative information to you, such as changes to our terms, conditions and policies.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Providing you with our newsletter and/or other marketing materials and facilitating social sharing
  • To send you marketing related emails, with information about our services, new products and other news about our company.
  • To facilitate social sharing functionality that you choose to use.

We will engage in this activity with your consent or where we have a legitimate interest.

• Allowing you to participate in sweepstakes, contests or other promotions.
  • We may offer you the opportunity to participate in a sweepstakes, contest or other promotion. Some of these promotions have additional rules containing information about how we will use and disclose your information.

We use this information to manage our contractual relationship with you or where we have a legitimate interest.

• Business reporting
  • To analyze or predict service use and prepare aggregated trend reports on how our digital content is used.
  • To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
  • For trending and statistics, and to develop, market or improve our products and services.

We will engage in this activity where we have a legitimate interest.

• Aggregating and/or anonymizing
  • We may aggregate and/or anonymize information so that it will no longer relate to an identified or identifiable individual. We do so to generate other data for our use, which we may use and disclose for any purpose.

We will engage in this activity where we have a legitimate interest.

• Accomplishing our business purposes
  • For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
  • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
  • To prepare or execute a business transaction, such as a corporate restructuring, merger or acquisition.
  • To protect our rights and to defend against lawsuits.
  • To respond to legal duties, such as requests from public and government authorities.

We engage in these activities to comply with a legal obligation, and/or because we have a legitimate interest.

With whom does Telaria share information collected on the Telaria Site?

We disclose information:

• To our affiliates for the purposes described in this privacy policy. You can consult the list and location of our affiliates here.
• To our third party service providers, to facilitate services they provide to us. These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
• To our clients, advertisers, advertising platforms, and intermediaries in the digital advertising environment.
• To business partners in the context of a corporate transaction.
• To public authorities, such as law enforcement agencies.

Security

Telaria maintains safeguards designed to help protect the security, integrity and privacy of the information within our reasonable control.

Links to other websites

Telaria does not control the data collection policies of any third party website linked to the Telaria Site. If you click on a link or an advertisement, the privacy policy of the website to which you link will govern the collection and use of your information by that website’s operators. Telaria assumes no responsibility or liability for the actions of such third parties with respect to their use of your information or otherwise.

Cookies and similar technology

We and our partners may use cookies or other similar technology to better understand who visits the Site and to operate the Site. In particular, we use the following cookies and similar technologies for the following purposes:

• Site analysis – We use analytics services, such as Google Analytics to analyze traffic on the Site. For more information about how Google Analytics collects and uses data when you use our website, visit here, and to opt out of Google Analytics, visit here.
• Digital advertising – We may partner with certain third parties that collect information from the Site, as well as other non-affiliated websites and mobile apps, over time in order to deliver more relevant advertising to your browser or device, as well as on various devices that may be associated with it. This activity is called interest-based advertising.

For more information about interest-based advertising, and to exercise choice regarding companies that participate in the Digital Advertising Alliance’s (DAA) WebChoices, please visit here. After you exercise choice, you will still receive advertising but it may be less relevant to you. Also, those third parties may continue to collect information for purposes other than interest-based advertising including analytics, frequency capping, and other operational purposes. If you use other devices or browsers, or clear your cookies, you may need to make your choices again.

For more information on what cookies are and other ways to opt-out from them, please see further above in this privacy policy.

Collection of information from minors

The Telaria Site is directed to, and intended for use by, adults only. We do not knowingly direct our activities to children under the age of sixteen.

Your Choices

You may opt out from receiving electronic communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out of marketing- related emails here.  We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.

C. Notice to California Residents

This notice explains what types of Personal Information may be collected by Telaria, about our prospective, current, and former employees, temporary employees, agents, subcontractors, consultants, and vendors who are California residents and how that information may be used and disclosed.  This privacy notice also applies to California residents who are designated by our prospective, current, and former employees as emergency contacts or benefits recipients.  As used in this privacy notice, “Personal Information” means, in general, information that identifies, relates to, or describes a particular California resident and includes the categories listed below.

1. Categories of Personal Information Collected: We collected the following categories of Personal Information during the last 12 months:
   1. Identifiers, such as name, government-issued identifier (e.g., Social Security number), and unique identifiers (e.g., employee ID);
   2. Personal information, as defined in the California Records Law, such as contact and financial information;
   3. Characteristics of protected classifications under California or federal law, such as age, gender, medical conditions, and marital status;
   4. Commercial information, such as transaction information and purchase history (e.g., in connection with travel or other reimbursements);
   5. Internet or network activity information, such as browsing history and interactions with our online systems and websites;
   6. Geolocation data, such as device location;
   7. Audio, electronic, visual, and similar information, such as call and video recordings;
   8. Professional or employment-related information, such as work history and prior employer;
   9. Non-public education information; and
   10. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Depending on a particular California resident’s interactions with us, we may not have collected each of these categories of Personal Information about that person.

2. Uses of Personal Information. We may use Personal Information:

• To operate, manage, and maintain our business;
• For our employment purposes;
• To otherwise accomplish our business purposes and objectives, including, for example:
  • Conducting research, analytics, and data analysis;
  • Maintaining our facilities and infrastructure;
  • Quality and safety assurance measures;
  • Conducting risk and security controls and monitoring;
  • Detecting and preventing fraud;
  • Performing identity verification;
  • Performing accounting, audit, and other internal functions, such as internal investigations;
  • Complying with the law, legal process, and internal policies;
  • Maintaining records; and
  • Exercising and defending legal claims.

D. Miscellaneous

Updates – Telaria reserves the right to revise this privacy policy from time to time. The “last updated” legend at the top of this privacy policy indicates when this privacy policy was last revised.  Any changes will become effective when we post the revised privacy policy on the Site.

Personal information – To the extent information that we collect, receive or use relates to an identified or identifiable individual in the European Economic Area (EEA), we will treat such information as personal information as required by applicable law.

Your rights – If you would like to request to review, correct, update, suppress, restrict or delete personal information that you have previously provided to us, object to the processing of personal information, or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us by emailing privacy@telaria.com.  Please note that in relation to our video management platform, your primary touchpoint is the publisher. As such, we recommend that you contact the publisher directly rather than us.

If you are in the EEA, you may also, where applicable, lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.  A list of data protection authorities is available here.

Transfers – Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, including the United States, which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information. Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have agreed with relevant recipients to put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your personal information. You may seek to obtain a copy of these measures by contacting privacy@telaria.com.

Retention – We retain information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the video management platform and services or Site.
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them).
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Contact Us – If you have questions about this privacy policy, please email us at privacy@telaria.com or write to us at Telaria, Inc., Attention: Privacy, 222 Broadway, New York, NY 10038.