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Privacy Policy

Updated October 2024

1. Introduction

This privacy policy (“Privacy Policy”) explains the data protection practices of Publisher First, Inc. dba Freestar (collectively, “Freestar“, “we” and “us”) when you visit or use freestar.com, any of the Freestar Publisher Websites, mobile-optimized version of such websites, and digital applications that integrate certain Freestar technology or onto which Freestar serves advertisements (collectively, “Publisher Websites”). For the purposes of data protection laws, Freestar is a data controller.

If you do not agree to this Privacy Policy, you must discontinue using the Publisher Websites and all services and features therein. By using the Publisher Websites, you acknowledge you have read and understand this Privacy Policy.

Introduction

Applicability

Information We Collect

How We Use Your Information

How We Share Your Information

Legal Grounds for Processing Your Information

Third Party Advertising Partners

Your Choices About Ads and Analytics

Data Subject Rights & Your Choices

Retention of Your Information

Cookies & Other Tracking Technologies

Third Party Sites

Security

Transfer Information to the United States

Changes to This Privacy Policy

Disputes

Contact Us

California Residents Privacy Notice

2. Applicability

(a) This Privacy Policy applies to Freestar’s and its third party ad service vendors’ and advertisers’ (collectively, “Freestar Entities”) delivery of advertisements on the Publisher Websites, and applies whenever and however you access or use the Publisher Websites, whether via personal computers, mobile devices or other devices (each a “Device”). “Publisher Websites” includes all subdomains of Publisher Websites.

(b) The Publisher Websites are also subject to additional or different privacy policies, which are posted on the Publisher Website. Please visit each Publisher Website for additional privacy policies and terms and conditions related to your privacy. Freestar is not the data controller

3. Information We Collect

(a) Information Automatically Collected As You Access and Use the Publisher Websites.

To provide you with advertisements that are more customized to your interests, the Freestar Entities may use a variety of technologies (including cookies, Flash cookies, web beacons and embedded scripts) (“Cookies”) that automatically or passively collect information when you visit or interact with the Publisher Websites and the advertisements we serve on the Publisher Websites.

We, and our partners or vendors, may collect this information the first time you interact with a Publisher Website that uses our ad services, and we may combine and associate this information with information we (or our partners) may collect about your interactions with other ads we serve.

The information we collect includes:

Browser and Device information such as the type of web browser, computer, platform, related software; device type and model, manufacturer, operating system type and version, inferred from IP address, and identifiers assigned to a device, such as its iOS Identifier for Advertisers (IDFA), Android/Google Advertising ID (AAID or GAID), or other unique device identifier (typically an alphanumeric string allocated to a device by the device manufacturer, identifiers stored in a our cookie, ETag, or browser or web cache). Your IP address is usually associated with the place from which you enter the Internet, like your Internet Service Provider, your company or your library. We use your IP address and other identifiers for a variety of purposes, including to help diagnose problems with our servers, gather broad demographic information, and other purposes as allowed or required by law.

Information about your interactions on the Publisher Websites such as information about the activities or actions on those Publisher Websites, the content viewed on the Publisher Websites, the URL that referred you to the Publisher Websites and all of the areas within the Publisher Websites that you visit, the web sites you visit after the Publisher Website;

Freestar ad information, such as the content of the ad (what the ad is about, e.g. entertainment, news); the ad type (e.g. text, image, or video); where the ad is served (e.g. the website on which the ad appears); whether you clicked on the ad, the number of times you have seen the ad, and information about your interaction with the ad.

We may combine information gathered from your use of the Publisher Websites with information from third party sources to identify your location by state and region.

For more information, see “Cookies” below.

Geolocation Information. With your informed consent, Freestar may collect and use your geolocation to provide you with information about goods and services within your geographic location or implement other functionality such as to serve targeted advertising. By using such service, you hereby consent to our collection, use and disclosure of your geolocation information as described.

(b) Information We Collect From Third Parties.

We may acquire information from other trusted sources to update or supplement the information that you provided or we collected automatically, such as information to validate or update your demographic information and lifestyle information. We use this information to help us maintain the accuracy of the information we collect, to target our communications so that we can inform you of products, services and offers that may be of interest, and for internal business analysis or other business purposes. We may also acquire information from other sources about your visits over time and across other third party websites, in order to serve more targeted advertising to you on the Publisher Website(s). Those third parties have privacy policies that differ from this Privacy Policy.

4. How We Use Your Information

We use the information we collect for a variety of purposes. For example, we use the information we collect for:

(a) Serving and Customizing Advertising: We use the information in connection with serving advertising on the Publisher Websites, including to provide ads that are targeted to your inferred interests based on your activities across Publisher Websites. This may include creating interest-based advertising segments or audiences, as well as to supplement the information we collect with additional information we receive from third parties to allow us to tailor the ads we display.

(b) Ad Reporting, Conversions, Analytics, and Frequency Capping: To create and provide information regarding ad activity, including whether ads are clicked on, tracking views of ads, as well as click-through rates, to prevent you from seeing the same ad too many times, and to measure and improve our ad serving services.

(c) Fraud Detection and Prevention and Security: To identify invalid ad impressions, clicks, installs, or ad queries, protect us and our Publisher Websites from fraud, and protect our services.

(d) Service Support and Improvement: To improve our ad services, to improve navigation and display, and to ensure that our services function properly.

(e) Marketing: Subject to applicable law, we may combine and use any and all information we collect on you either online or otherwise, including from third parties, for marketing purposes. Unless we expressly notify you otherwise at the time of collection, we also may disclose information that we receive from you and from third party sources to third parties whose practices are not covered by this privacy statement (e.g. other marketers, retailers, and participatory databases) that want to market products or services to you. This includes licensing information about your interests and activities and marketing segments created with such data to third parties for their marketing purposes.

(f) Anonymous Information: To create aggregated, anonymized information about you and other users of the Publisher Websites by excluding information (such as your name) that relate to an identifiable individual (“Anonymous Information”). We may use this Anonymous Information for any purpose permitted under the law and disclose Anonymous Information to third parties in our sole discretion.

(g) Cross-Device Tracking: We may use cookies in combination with the information we collect — for instance, IP addresses and unique mobile device identifiers — to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with service providers that do this, in order to save your preferences across devices and analyze usage of the Publisher Websites.

5. How We Share Your Information

In addition to the other disclosures described in this Privacy Policy, Freestar may (and you authorize us to) share or disclose information collected from and about you on the Publisher Websites to other companies or individuals as set forth below. We may provide access to information to vendors that are performing services on our behalf, in order to carry out such services (the “Service Provider Use”).

(a) Administrative and Legal Reasons: Notwithstanding anything herein to the contrary, we may at all times and in any manner access, use, preserve, transfer and disclose your information, including disclosure to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process, or in connection with a legal investigation, if in our good faith opinion such is required or permitted by law; (iii) to protect the safety, rights, property or security of the Freestar Entities, their products or services; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use identifiers and other information to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion (the “Legal Use”). Such disclosures may be carried out without notice to you.

(b) Sales or Transfer of Business or Assets: In connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock, or otherwise, including via bankruptcy) of all or a portion of the business conducted by Freestar, in which case the company will possess the information collected by us and will assume the rights and obligations regarding your information as described in this Privacy Policy (the “Acquisition Use”).

6. Legal Grounds for Using (Processing) Your Information

If you are a visitor from the European Economic Area, our legal basis for collecting and using the information described above will depend on the information concerned and the context in which we collect it.

We collect information from you:

where we need it to perform our contract with you;

where the processing is in our legitimate interests, provided that these aren’t overridden by your interests or rights (such as personalizing our services and marketing for example); or

if we otherwise have your consent.

If you have questions about or need further information concerning the legal basis on which we collect and use your information, please contact us using the contact details provided under the “Contact Us” section below.

7. Third Party Advertising Partners

In addition to ads that we serve you directly, Freestar may use third party advertising companies and to serve ads when you visit the Publisher Websites and elsewhere on the internet and in other media. We also use analytics services supported by third party companies to perform analytics and track trends. Those third party companies may use tracking technologies to collect and store usage information about you and may combine this information with information they collect from other sources.

To provide ads on the Publisher Websites, we use a variety of third party advertising service providers, including networks, data exchanges, ad servers, analytics providers and others. The list of third party providers is found in the Section below entitled “Third Party Cookies.” This list may be updated from time to time. These third parties may use technology to send, directly to your Device, the advertisements and links that appear on the Publisher Websites. They may automatically receive your IP address, web browser, operating system, and time and location information, geodevice type and device ID when this happens. Freestar, the third party service providers, as well as the advertisers themselves, may collect and use information about your visits over time and across the Publisher Websites and other third party web sites, as well as information received from other sources, in order to serve more targeted advertising to you on the Publisher Websites. Third parties may also use information gathered from your usage of the Publisher Websites to serve targeted advertisements to you on third party websites and applications. Google is one of the companies that we use to serve advertising and perform analytics on some of the Websites. We and third party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to help implement the above uses of your information.

We use Google Analytics along with audience data (such as age, gender and interests of users) to help understand users’ visits to the Publisher Websites and to optimize the content that we serve to users.

LiveRamp’s Authenticated Traffic Solution (ATS) provides people-based advertising. ATS enhances addressability for publishers while providing visibility and control for individuals. ATS allows publishers to match user data with a LiveRamp RampID in real-time, enabling people-based advertising on authenticated inventory across the internet.

When you use our website and enter your email address on our website (either to log in, or to sign up to a newsletter, or similar), we may share with LiveRamp and its group companies information that we collect from you, such as your email (in hashed, pseudonymous form), IP address, or information about your browser or operating system, with any of the following, acting as “joint controllers” (as applicable and defined in the GDPR).

LiveRamp uses this information to create an online identification code that we may store in our first-party cookie for our use in online, in-app, and cross-channel advertising. This may be shared with advertising companies to enable interest-based and targeted advertising. LiveRamp uses this information to create an online identification code for the purpose of recognising you on your devices. This code does not contain any of your directly identifiable personal data and will not be used by LiveRamp to re-identify you.

For ATS in Spanish-speaking countries:

When you enter your email address on our website (whether to log in, subscribe to a newsletter, or similar) or when you use our application, we may share the personal or other information we collect, such as your email (pseudonymized in hashed form), mobile advertising identifier, the IP address or information about your browser or operating system, with our partner LiveRamp and its group companies acting as joint controller (applicable to GDPR countries). LiveRamp’s privacy policy and options to object to this activity are available here. LiveRamp uses this information to create an online identification code to recognize you on your devices. This code does not contain personal data that identifies you and will not be used by LiveRamp to re-identify you. We include this code in our cookie or use a LiveRamp cookie to be used for online and multi-channel advertising. It may be shared with our advertising partners and other third-party advertising companies globally in order to enable interest-based content or targeted advertising across your entire online experience (e.g. web, email, connected devices and apps, etc.) They may, in turn, use this code to link to demographic or interest-based information that you have provided in your interactions with them. You have the right to decide whether to authorize our use of LiveRamp cookies and our sharing of this data with LiveRamp for the aforementioned purposes.

Detailed information on LiveRamp’s data processing activities is available in LiveRamp’s privacy policy. You have the right to withdraw your consent or opt-out to the processing of your personal data at any time using this link.

8. Your Choices about Ads and Analytics

To learn more about how to manage your preferences regarding our cookie-based advertising, please see the “Cookie Management” section in our Cookie Notice.

Please note that you may still receive advertisements from third parties within the Publisher Websites even if you opt out of tailored advertising but they will not be based on your activity across unrelated web sites or apps.

Do Not Track. Freestar does not act on “do not track” requests from your browser because, this way, we are able to personalize your experiences on the Publisher Websites. For more information, go to http://www.networkadvertising.org or http://www.aboutads.info.

9. Data Subject Rights & Your Choices

Subject to certain local laws, you have certain rights with respect to your information as further described in this section.

(a) International Users: If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Contact Us” section below at any time. Your local laws may permit you to request that we:

provide access to and/or a copy of certain information we have about you;

prevent the processing of your information for direct-marketing purposes;

update information which is out of date or incorrect;

delete certain information which we have about you;

restrict the way that we process and disclose certain of your information;

transfer your information to a third party provider of services; and/or

revoke your consent for the processing of your information.

We will consider all requests and provide our response within the time period stated by applicable law. Certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

(b) Privacy Information for California residents. If you are a California resident, California law requires us to provide you with some additional information regarding your rights with respect to your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). We describe the categories of personal information we collect, the sources and uses of such information and the entities to which we share such information in our California Privacy Notice, below.

California Data Access & Deletion Rights. If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.

Provide access to and/or a copy of certain personal information we hold about you.

Delete certain personal information we have about you.

Provide you with information about the financial incentives that we offer to you, if any.

Please note that certain information may be exempt from such req