This Privacy Policy describes how Octillion Media LLC (“Company,” “we,” “our,” or “us”) collects, uses, and discloses information about you as well as your rights and choices regarding such information. It applies to any online location controlled by us that links to this Privacy Policy (the “Service”).

Data protection law makes a distinction between organizations that process information for their own purposes (known as “controllers” or “businesses”) and organizations that process information on behalf of other organizations (known as “processors” or “service providers”). This Privacy Policy applies only where we act a controller or business. It does not apply where we act as a processor or service provider on behalf of a client, which is subject to the client’s privacy policy. For further details about our processing of client data, please see the “Information We Collect in Connection with Our Platform ” section below.

Please click on the following links or visit the sections at the end of this Privacy Policy for additional jurisdiction-specific disclosures:

• California
• Nevada
• Colorado, Connecticut, and Virginia
• European Economic Area, Switzerland, and United Kingdom

If you have any questions, please contact us as set out in the “Contact Us” section.

A. Information You Provide.

We collect the following categories of information about you when you use the Service:

• Contact Data, including your first and last name, email address, postal address, and phone number.
• Billing Data, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments. This information is processed by our payment processors.
• Content, including content within any messages you send to us (such as feedback or questions to customer support) or publicly post on the Service.
• Job Applicant Data, including your employment and education history, transcript, writing samples, and references as necessary to consider your job application for open positions.

You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.

B. Information We Collect from Your Device or Browser.

In addition, we automatically collect information from your device or browser when you use the Service. The categories of information we automatically collect include:

• Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, the time of day you browse, and your referring and exiting pages.
• Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id (which is a user-resettable identifier associated with your device).
• Location Data, including non-precise location data (such as location derived from an IP address or data that indicates a city or postal code level)..

The types of tracking technologies we use to automatically collect this information include:

• Cookies, which are small data files stored on your browser that save data about your visit. Cookies often include a unique identifier (e.g., cookie #123). We use the following types of cookies: status cookies, personalization cookies, security cookies, analysis cookies and consent cookies. These cookies facilitate features such as tracking your logged-in status, remembering your preferences, securing the Service and user accounts, analyzing the performance of the Service, and facilitating advertising.
• Pixels (also known as web beacons), which is code embedded in a service that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a service that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser, or collect other information about your visit. We incorporate pixels, some of which are provided by separate entities, that allow us to bring you advertising, and provide you with additional functionality.

For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.

C. Information We Collect in Connection with Our Platform.

We collect and process data both on our own behalf as a controller or third party, and on behalf of our clients and partners as a service provider or processor (“client data”). All such data is collected and processed in order to operate our services and our business, in particular, to facilitate targeting, delivering, measuring, and reporting on, advertising. Such data includes:

• Unique cookie identifiers
• Mobile device advertising identifiers
• IP addresses
• Interest information stored and/or used on the platform by clients and partners
• Interest information we create
• Other information about browsers and devices, such as type, version and settings
• Location information based on IP address or latitude/longitude coordinates, if provided to us
• Information about ads that are shown, such as which ads are shown to a device or user, where (which web page or app) they are shown, and at what time
• Hashed email addresses and other identifying information (or information derived from such)
• JavaScript objects and installed fonts

We receive the above categories of data from the following sources:

• Advertisers and agencies may bring or collect their own information via features on our platform (for example, that they collect on their own websites) that we then store and use on their behalf to enhance their advertising campaigns.
• Bid requests, which are sets of information that describe an ad space that is available to be filled. We get these requests from the “supply” side of the advertising ecosystem, meaning websites, apps, smart TVs, and others, as well as their agents. The requests contain information about the ad space, the device, and sometimes the user, including location information. They also usually have an ID that enables us to match the request with information we may already have.
• Third-party suppliers of information used to target and optimize advertising campaigns (for example, by personalizing ads).
• Purveyors of connected TV devices and apps can send us information about the video content viewed on the device or app.
• Pixels and cookies, which allow us to recognize web browsers across sites and over time, and therefore to record information about them over time.
• Mobile device IDs, which are provided by the device operating systems, like Apple’s iOS and Google’s Android, for purposes of allowing mobile apps and their advertising partners to recognize a device over time. We use these IDs the same way we use cookies.
• Mobile SDKs are bits of code that some of our partners enable to be placed in mobile apps. This enables our partners to send us data about the mobile app and device in association with the mobile device ID.
• After an ad serves, our servers receive a network request from the device on which the ad was shown in order to confirm that the ad was delivered and provide information for us to measure the ad.

Our processing of client data is governed by the terms of our service agreements with those clients, and not this Privacy Policy. In the event we are permitted to process client data for our own purposes, we will process the client data in accordance with the practices described in this Privacy Policy. We are not responsible for how our clients treat the information we collect on their behalf, and we recommend you review their own privacy policies.

For further information on your rights and choices regarding client data, see the “Your Rights and Choices” section below.

D. Information from Other Sources.

We also collect information about you from other sources. The categories of sources from which we collect information include:

• Social media platforms with which you interact.
• Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
• Publicly-available sources, including data in the public domain.
• Data brokers from which we purchase or license data to supplement the data we collect.

We collect and use information on our own behalf in accordance with the practices described in this Privacy Policy. Our purposes for collecting and using information include:

• Providing the Service.
• Preventing and addressing fraud, breach of policies or terms, or threats or harm.
• Understanding trends, usage, and activities, including through tracking technologies or surveys, to make business and marketing decisions.
• Communicating with you about updates, security alerts, changes to policies, and other transactional messages.
• Personalizing your experience to show you content we believe you will find interesting.
• Engaging in direct marketing, promotional communications, and non-personalized advertising.
• Engaging in personalized advertising, including Interest-based Advertising.
• Fulfilling any purpose at your direction.
• With notice to you and your consent.

When we collect and process personal information on behalf of our clients, we do so for the following purposes, which are essential to providing our core services and operating our platform:

• Personalizing ads and increase advertising relevancy and effectiveness.
• Deliver advertising and measure the success of delivery.
• Measure advertising frequency and other data, such as how many times an ad was shown, as well as where and when it was shown.
• Measurement and analytics, such as to understand how well various advertising performs, whether users clicked on the advertisement, or visited a client’s website or store after viewing an advertisement.
• To measure, attribute, and report on the performance and success of campaigns.
• Measure actions taken by a user regarding a particular advertisement, such as whether they clicked on an advertisement or downloaded an app.
• Matching particular advertisement views with subsequent actions taken by a user. For example, understanding whether someone who saw an ad for a product later bought that product. This is done by matching data collected from our platform with the advertiser’s own data and data from other companies. In doing so, we don’t receive any data that allows us to identify the purchaser of the product.
• Associating devices that might be related to each other, such as devices used by the same person or in the same household.
• Preventing malicious activity or invalid advertising traffic. This may include identifying and preventing purveyors of malware or bots that try to take advertising dollars for advertisements that aren’t shown to real users or that try to harm users’ devices.

Notwithstanding the above, we may use publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) for any purpose to the extent permitted by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

We disclose the information we collect in accordance with the practices described in this Privacy Policy. The categories of persons to whom we disclose information include:

• Service Providers and Contractors. We disclose information to service providers and contractors that process information on our behalf. Service providers and contractors assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. To the extent required by law, we contractually prohibit our service providers and contractors from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) to the extent permitted by applicable law.
• Analytics and Advertising. We disclose information to vendors and other parties for analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below.
• Affiliates. We disclose information to our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
• Clients. Some of the data we process belongs to our clients, and we process it in order to operate our platform. In such instances, we disclose information to our clients in connection with the services we provide to them. Our clients are independent entities and their handling of information is subject to their own privacy policies.
• Merger or Acquisition. We disclose information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
• Security and Compelled Disclosure. We disclose information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also disclose information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.
• Facilitating Requests. We disclose information where you direct us to disclose the information.
• Consent. We disclose information with notice to you and your consent.

Notwithstanding the above, we may disclose publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) to the extent permitted by applicable law. For information on your rights and choices regarding how we disclose information about you, please see the “Your Rights and Choices” section below.

We offer parts of our Service through websites, platforms, and services operated or controlled by other parties. In addition, we integrate technologies operated or controlled by other parties into parts of our Service. Please note that when you interact with other parties, including when you leave our Service, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.

As part of this process, we may incorporate tracking technologies into our own Service (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).

We also use audience matching services (which is a type of Interest-based Advertising) to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by us providing a list of hashed email addresses to an ad partner or incorporating a pixel from an ad partner into our own Service, and the ad partner matching common factors between our data and their data.

As indicated above, vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please see the “Information Collected from Your Device or Browser” and “Your Rights and Choices” sections.

A. Jurisdictional Rights.

In addition to these rights and choices, you may have rights based on your jurisdiction. Please visit the relevant sections at the end of this Privacy Policy for details.

B. Account Management.

Representatives of our clients who have an account on our Service may access, update, or delete certain information that they have provided to us through their account by visiting their account settings. Please note that we will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

C. Tracking Technology Management.

• CookiesMost browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
• Preference Signals. Your browser or extension may allow you to automatically transmit preference signals regarding tracking technologies to online services you visit, and unless required by law or otherwise set out in this Privacy Policy, we do not respond to such signals. At this time, we do not respond to Do Not Track Signals. Note that, depending on your jurisdiction, you may exercise your right to opt-out of sales or sharing through preference signals. Please review the below sections for details

Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.

D. Analytics and Interest-Based Advertising Management.

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.

The companies we work with to provide you with Interest-based Advertising may be participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To opt out of receiving Interest-based Advertising from the participating companies, please visit https://www.aboutads.info/choices and https://www.networkadvertising.org/choices/ for website opt outs and https://www.aboutads.info/appchoices for mobile opt outs. Note that opting out through these links only means that the selected participants should no longer deliver Interest-based Advertising to you, but does not mean that the participants will not process your information for Interest-based Advertising purposes or that you will no longer receive Interest-based Advertising from other companies.

Please note that the above opt outs only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of any opt outs offered by other entities.

E. Communications.

• E-mails. You can unsubscribe from receiving promotional emails by following the unsubscribe instructions at the bottom of the email, or emailing us at legal@octillionmedia.com with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt out of transactional messages.
• Push Notifications. If you have opted-in to receive push notification on your device, you can opt-out by adjusting your device settings or uninstalling our app.

Please note that your opt out is limited to the email address, device, used and will not affect subsequent subscriptions.

The Service is not directed toward children under 13 years old, and we do not knowingly collect personal information (as that term is defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information from children, please contact us at legal@octillionmedia.com. We will delete the personal information in accordance with COPPA.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, disclosure, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy. Where required by applicable law, we will provide appropriate safeguards for data transfers, such as through use of standard contractual clauses.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address.

If you have any questions about our data practices, or experience any difficulty accessing the information in this Privacy Policy, please contact us:

By email: legal@octillionmedia.com

By mail:
M&M RA Services, LLC
3001 S.W. 3rd Avenue
Miami, FL 33129
Attention: Privacy Officer, Octillion Media LLC

California provides additional rights to California residents, including through the California Consumer Privacy Act as replaced by the California Privacy Rights Act (“CPRA”). This section addresses those rights and only applies to California residents.

We acknowledge that you may have rights under the CPRA in connection with the personal information we process on behalf of our clients. If personal information about you has been processed by us as a service provider on behalf of a client and you wish to exercise any rights you have with such personal information, please inquire with our client directly.

A. Notice of Collection.

We have collected the following categories of personal information (as described in the CPRA) in the past 12 months.

• Identifiers, including name, postal address, phone number, email address, and online identifiers (such as IP address and device ID, cookie or MAID).
• Customer records, including business contact names and phone number.
• Commercial or transactions information, including records of products or services purchased, obtained, or considered.
• Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.
• Non-precise geolocation data, including location derived from an IP address.
• Professional, employment, or education-related information.
• Inferences drawn from any of the information identified in this section.

For further details on the personal information we collect and the sources from which we obtain personal information, please review the “Information Collection” section above.

We collect and use this personal information for the business and commercial purposes set out in the “Use of Information” section above. We disclose this personal information to the categories of persons set out in the “Disclosure of Information” section above. Please visit those sections for further details.

Some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under the CPRA. A “sale” is broadly defined under the CPRA to include a disclosure for something of value, and a “share” is broadly defined under the CPRA to include a disclosure for cross-context behavioral advertising. We collect, sell, or share the following categories of personal information for commercial purposes: identifiers, characteristics, commercial or transactions information, internet activity, non-precise geolocation data, and inferences drawn. The categories of third parties to whom we sell or share your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising. For details about your rights regarding sales and shares, please see the “Right to Opt-Out of Sales and Sharing” section below.

We do not knowingly sell or share the personal information of minors under 16 years old who are California residents.

B. Sensitive Personal Information

In addition, we may obtain your precise geolocation data from third parties for our permissible business purposes, as well as to engage in cross-context behavioral advertising. This data may be considered sensitive personal information under applicable law. If you would like to opt out of this use of your precise location data, please see the “Right to Limit the Use of Sensitive Personal Data” section below.

C. Retention

We retain each category of personal information, including sensitive personal information, for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

D. Right to Know, Correct, and Delete.

You have the right to know certain details about our data practices. In particular, you may request the following from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold or shared;
• The categories of persons to whom the personal information was disclosed for a business purpose or sold or shared;
• The business or commercial purpose for collecting or selling or sharing the personal information; and
• The specific pieces of personal information we have collected about you.

You have the right to know certain details about our data practices. In particular, you may request the following from us:

To exercise any of these rights, please submit a request thought our Data Rights form, or call our toll free number at +1 (833) 282-8320

If you have an account with us, we may require you to use the account to submit the request. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 business days and respond to your request within 45 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.

E. Right to Opt-Out of Sales and Sharing.

To the extent we sell or share your personal information to third parties as those terms are defined under CPRA, you have a right to opt-out of that sale or sharing, which you can exercise through this Your Privacy Choices link, or the “Your Privacy Choices” link in the footer of our website.

In addition, you may exercise your right to opt-out of sales and sharing by using a recognized opt-out preference signal, such as Global Privacy Control (“GPC”), in a compatible browser or extension. Note that opt-outs via GPC can only be effected with respect to the data we receive from your web browser that transmits the GPC signal, i.e., your pseudonymized IP address. If you want your GPC opt-out request to apply to other personal information we have about you (such as your name, email or other contact information), please use this link and provide the information as requested.

As described above, we receive personal information from our clients in order to provide our services. If you submit an opt-out request to one of our clients, and that client transmits that opt-out request to us, we will opt you out of the sale or sharing of your personal information for that specific client. Note that we may still continue to sell or share your personal information that we receive from other clients to which you did not submit an opt-out request. If you would like to opt out of the sale or sharing of your personal information more generally from our databases, submit a request via this form.

F. Right to Limit the Use of Sensitive Personal Information

To the extent we use or disclose your sensitive personal information for purposes other than those specified as permissible business purposes under the CPRA, you have the right to limit the use or disclosure of your sensitive personal information. You may exercise this right through our form at Your Privacy Choices or by calling +1 (833) 282-8320.

G. Authorized Agent.

You can designate an authorized agent to submit requests on your behalf. Requests must be submitted through the methods listed above. Except for opt-out requests, we will require written proof of the agent’s permission to do so and may verify your identity directly.

H. Right to Non-Discrimination.

You have the right not to receive discriminatory treatment by us for the exercise of any your rights.

I. Shine the Light.

Customers who are residents of California may request (i) a list of the categories of personal information (as that term is defined by Shine the Light) disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

These additional rights and disclosures apply only to residents of Colorado, Connecticut, and Virginia. Terms have the meaning ascribed to them in the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), and the Virginia Consumer Data Protection Act (“VCDPA”), as applicable.

In your region, you have the following rights under applicable law:

• To confirm whether or not we are processing your personal data
• To access your personal data
• To correct inaccuracies in your personal data
• To delete your personal data
• To obtain a copy of your personal data that you previously provided to us in a portable and readily usable format

To exercise any of these rights, please submit a request through our Data Rights form or call our toll free number at +1 (833) 282-8320. We will respond to your request within 45 days. If you have an account with us, we may require you to use the account to submit the request. We may require specific information from you to help us confirm your identity and process your request.

You also have the right to opt out of the processing of personal data for purposes of targeted advertising, or the sale of personal data. You can exercise your rights through this Your Privacy Choices link, or the “Your Privacy Choices” link in the footer of our website.

In addition, you may exercise your right to opt out by using a recognized opt-out preference signal, such as Global Privacy Control (“GPC”), in a compatible browser or extension. Note that opt-outs via GPC can only be effected with respect to the data we receive from your web browser that transmits the GPC signal, i.e., your pseudonymized IP address. If you want your GPC opt-out request to apply to other personal information we have about you (such as your name, email or other contact information), please use this link and provide the information as requested.

As described above, we receive personal information from our clients in order to provide our services. If you submit an opt-out request to one of our clients, and that client transmits that opt-out request to us, we will opt you out of the sale of your personal information for that specific client. Note that we may still continue to sell your personal information that we receive from other clients to which you did not submit an opt-out request. If you would like to opt out of the sale of your personal information for all clients, submit a request via this form.

You can designate an authorized agent to submit requests on your behalf. Requests must be submitted through the designated methods listed above. Except for opt-out requests, we will require written proof of the agent’s permission to do so and may verify your identity directly.

If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at legal@octillionmedia.com and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows:

• For Colorado residents, to the Colorado AG at https://coag.gov/file-complaint/
• For Connecticut residents, to the Connecticut AG at https://www.dir.ct.gov/ag/complaint/
• For Virginia residents, to the AG at https://www.oag.state.va.us/consumercomplaintform

If you are a Nevada consumer, you have the right to direct us not to sell certain information that we have collected or will collect about you. To exercise this right, email us at legal@octillionmedia.com.