Privacy Policy

Effective Date: March 31, 2022

This Privacy Policy explains how West Seven Media (“WSM”) collect, use, and disclose information, and your choices for managing your information preferences.

What This Policy Covers

This Privacy Policy describes WSM’s data practices associated with our corporate website (www.westseven.media) and WSM services (“Services”), and the choices that WSM provides in connection with our collection and use of your information. This Privacy Policy is intended for both website publisher customers (“Publishers”) and individual users of websites and apps. For Publishers, this Policy explains how WSM may collect, use and disclose information associated with your company and with your company’s websites and apps that use WSM Services. For individual website and app users, this Privacy Policy explains how WSM may collect, use, and disclose information when you visit our website or when you use any website or app that uses WSM Services.

WSM Services include our Ad Network, where we work with Publishers to buy and sell digital and mobile advertising and ad inventory. In this case, Publishers and other clients may also have their own policies that govern how they collect, use, and share data. These policies may differ from WSM’s policies described in this Privacy Policy. Please consult the privacy policies of the websites you visit and apps you use to become familiar with their privacy practices and to learn about any choices that these companies may offer with respect to their information practices.

Finally, the WSM website may contain links to websites or content operated and maintained by third parties, over which we have no control. We encourage you to review the privacy policy of a third-party website before disclosing any information to the website.

Information Collection and Use

WSM collects contact information through our website when you choose to provide it, such as your name, username, or email address. For example, you may be asked to provide us with contact information when you register with the WSM website and when you purchase the Services. The decision to provide this information is optional; however, if you elect not to register or provide such information, you may not be able to access certain content, features, or services available on or through the WSM website. In order to make payments owed to Publishers, WSM may also request additional information from Publishers such as other contact information and billing account information.

WSM uses this contact and billing information to operate and improve our website and Services, such as to provide notices about your Service, to fulfill your service requests, or to request your feedback or conduct research. WSM also uses contact information to send you information about new products or Services; where WSM needs your permission to do this, we only send such information in accordance with any permissions granted.

We may also collect additional information through our website and Services, such as the following:

·        ‘Free form’ demographic information (e.g. age, gender, marital status)

·        Browser information (e.g. URL, browser type, ‘click through’ data)

·        Ad reporting or delivery data (e.g. size/type of ad, ad impressions, location/format of ad, data about interactions with the ad)

·        Device-type information (e.g. screen dimensions, device brand and model)

·        Unique identification numbers (e.g. IP address and mobile/cell phone device ID)

·        Location data (as derived from IP address or GPS (for mobile))

·        Interest segments (i.e. inferred information on the behavior or likely interests associated with a de-vice)

·        Retargeting data (i.e. data revealing previous interest in a product or website)

·        Information about the possible relationships among different browsers and devices

·        Information about your activities on our website and Services

With respect to data collected via the WSM Ad Network, we may combine information that does not directly identify an individual with data collected from other sources and disclose the combined information to participating publishers, advertisers and ad networks so that they can determine whether to bid on ad inventory and in order to improve the relevance of the advertising presented to users. We also use the information we collect to host, operate, maintain, secure, and further develop and improve our Services, such as to keep track of advertising delivery and to measure the effectiveness of advertising delivered through our Services, and investigate compliance with WSM’s policies and terms and conditions.

WSM does not engage in activities that require parental notice or consent under the Children’s Online Privacy Protection Act (COPPA). If you believe that WSM has inadvertently collected information from a child under 13 that is subject to parental notice and consent under COPPA, please contact WSM using the contact information below to request deletion of the information.

Cookies and Other Similar Technologies. We use cookies (a small file containing a string of characters that uniquely identifies your Web browser), Web beacons (an electronic file placed within a Web site that monitors usage), pixels, etags, and similar technologies to operate and improve our website and Services, including for interest-based advertising as described below. Some of our Service Providers (defined below) may also use such technologies in connection with the services they perform on our behalf.

We use the following categories of cookies for our website and Services:

Strictly Necessary Cookies

These cookies are essential in order to enable you to navigate our website and use its features. Without these cookies, Services you have asked for such as remembering your login details cannot be provided.

Performance Cookies

These cookies collect anonymous information on how people use our website. For example, we use these cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve, such as navigation and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.

Functionality Cookies

These cookies remember choices you make such as the country from which you visit our website, language and search parameters such as size, color or product line. These cookies can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and relevant. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.

Targeting Cookies or Advertising Cookies

These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies remember the websites you visit and that information is shared with other parties such as advertisers. Please see our Interest-Based Advertising section below for information about your choices regarding our use of these technologies for interest-based advertising.

Publishers, advertisers and third-party ad networks that participate in the WSM Ad Network may also utilize cookies or similar technologies to deliver ads and monitor the performance of such ads. The collection of information through cookies or similar technologies by such third parties will be governed by their own privacy policies and principles, which WSM does not control.

Your browser may offer tools to enable or disable cookies by modifying the settings in your browser. How-ever, please note that certain features of the WSM website may not work if you delete or disable cookies. Moreover, if you delete cookies after previously opting out of WSM’s Ad Exchange practices, you may need to renew your opt-out choice. To read about your choices with regard to WSM’s use of cookies in our services, please see below.

Cookie Alternative Technology

We use third parties to serve advertisements on our Ad Network.  In order to do this, we share pseudonymized information, including a hashed version of information that we collect from you directly (such as email or phone number), third party IDs (such as mobile advertising IDs or other IDs assigned by third parties), IP addresses, and/or information about your browser or operating system with these third party providers.  Neustar Information Services and its affiliated companies (NIS) may match this pseudonymized information with information in their data repositories and issue another pseudonymous ID, which is changed on a weekly basis, for our use in connection with real-time bidding for digital advertising.  NIS and other third parties may also link demographic or interest based information to your browser via Cookies.  To opt out of the use of this data by NIS for this purpose, click here: Neustar Privacy Choices or here: Network Advertising Initiative Consumer Choice.

 

Our Ad Network may allow third-party companies, including advertisers, ad networks, and advertising services providers, to serve advertisements, provide other advertising services, and/or collect information when you visit our Publisher’s websites.

Third -party companies may use pseudonymous personal information (e.g., hashed email addresses, proprietary IDs, device identifiers, etc.) and other information (e.g., IP addresses, click stream information, browser type, statistical identifiers calculated from data shared by a browser or device, time and date stamps, the subject of advertisements clicked or scrolled over, etc.) collected during your visit to this site in order to provide advertisements about goods and services like to be of interest to you.

Third party companies may use technologies other than cookies to recognize your computer or device and/or to collect information about you your activities on this website.  Please keep in mind that your web browser may not permit you to block the use of these technologies, and those browser settings that block cookies may have no effect on such technologies.

Third party companies may link two or more devices or browsers believed to belong to the same user or household for advertising-related purposes.

To opt-out of this use of data for tailored advertising, please visit: https://optout.networkadvertising.org/?c=1

To learn more tailored advertising or opt-out of this type of advertising by third parties that are members of self-regulatory programs such as the Network Advertising Initiative, please visit the NAI’s website (www. Networkadvertising.org), which will allow you to opt out of tailored advertising by one, or all, NAI members.

Information Sharing

We will disclose contact and billing information to third parties only as described in this Privacy Policy:

·       with your express permission;

·       with our affiliates, which include entities controlling, controlled by, or under common control with WSM;

·       where we contract with third parties to provide certain services, such as advertising, analytics, data management services, web hosting, and web development (“Service Providers”). We ask Service Providers to confirm that their privacy and security practices are consistent with ours, we provide our Service Providers with only the information necessary for them to perform the services we re-quest, and Service Providers are prohibited from using such information for purposes other than as specified by WSM;

·       in the event that WSM is merged, sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, we may disclose or transfer information in connection with such transaction; and

·       where we believe it is necessary to protect WSM or our users; to enforce our terms or the legal rights of WSM or others; or to comply with a request from governmental authorities, legal process, or other legal obligations.

We may also share and disclose other information that we collect, including aggregate information, as we consider necessary to develop and provide our Services, including in the ways described above.

WSM may also be required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Legal Basis for Processing Personal Information of European Economic Area (“EEA”)

Individuals On certain occasions, WSM relies on the consent of the individual to process personal information (for example, when the user inputs personal information into the WSM website). On other occasions, WSM may process personal information when WSM needs to do this to fulfill a contract or where WSM is required to do so by law.

WSM may also process data when it is in WSM’s or its customer’s legitimate interests to do this and when these interests are not overridden by the individual’s data protection rights (which may vary based on an individual’s jurisdiction). Those legitimate interests include improving WSM’s Services.

Interest-Based Advertising and Opting Out

WSM adheres to the Digital Advertising Alliance (DAA) Self-Regulatory Principles in the US and to the European Digital Advertising Alliance (EDAA) Principles in the European Union (“EU”) and the IAB Europe OBA Framework.

As discussed above, the WSM Ad Network uses cookies, Web beacons, pixels, etags, and similar technologies to give Publishers the possibility to offer, and Ad Exchange advertisers the ability to show, targeted ads on the device on which you are viewing this policy or a different device. These ads are more likely to be relevant to you because they are based on inferences drawn from location data, web viewing data collected across non-affiliated sites over time, and/or application use data collected across non-affiliated apps over time. This is called “interest-based advertising.” In addition, certain third parties may collect data on the WSM website and combine this data with information collected from other websites over time for purposes that include interest-based advertising.

Opting Out for Cookie-Based Services: If you would like to learn more about this type of advertising, or would prefer to opt out of website interest-based advertising enabled by WSM’s Ad Exchange, please visit our opt-out page

Opting Out for Certain Non-Cookie Services (in applicable countries): To help identify your browser and/or possible relationships between different browsers and devices, WSM or our partners may use the local storage or cache in your browser. Using the browser cache or local storage helps WSM or our partners deliver interest-based advertising to a browser without the use of third-party cookies. To opt out of WSM’s use of local storage or the browser cache to provide its services, please (1) use any tools provided by your browser to clear local storage and the browser cache, and (2) turn on any “Do Not Track” header setting offered by your browser, and (3) use our opt-out page to opt out of interest based advertising. As long as these steps are completed and maintained on a browser, WSM will not use local storage or the cache on that browser to identify and sync browsers and devices.

Effect of Opting Out: If you use a different device or browser, or erase cookies from your browser, you will need to renew your opt-out choice.

If you opt out of WSM’s practices, you may continue to receive interest-based advertising through other companies. Third-party advertisers and ad networks that participate in the WSM Ad Network may also use their own cookies and other ad service technologies to display and track their ads. We do not control and are not responsible for such third-party advertisers’ and ad networks’ information practices or their use of cookies and other ad service technologies. To learn more about the practices of these companies, please read their privacy policies.

Even if you opt-out, WSM may continue to collect data for other purposes and you still will receive advertising from the WSM Ad Network when you visit websites of a Publisher who uses our Services – but such advertising will not be targeted to you.

Reviewing and Updating Information

WSM takes reasonable steps to ensure that information is accurate, complete, current, and reliable for its intended use. For contact or billing information submitted through our website, you may review, correct, update, or change your information, request that we deactivate your account, or remove your information from our direct marketing efforts, at any time by e-mailing us at [email protected].

International Information Transfers

Please be aware that the information we collect, including contact and billing information, may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. If you are located outside of the United States, please be advised that we process and store information in the United States and your consent to this Privacy Policy or use of WSM Services represents your agreement to this processing.

WSM is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Retention of personal information of EEA individuals will be handled in accordance with WSM’s data retention policy. Where WSM processes personal data of EEA individuals as a data controller, such individuals: (i) may have the right to request access to and rectification or erasure of personal information; (ii) may restrict the processing of personal information, object to processing, and/or exercise the right of data portability; and (iii) may have certain rights to withdraw consent without affecting the lawfulness of processing and the right to lodge a complaint with a supervisory authority. For any requests or information regarding the rights set out above, please contact us by e-mailing us at [email protected]

Security

Information that we collect is stored using procedures and practices reasonably designed to help protect information from unauthorized access, destruction, use, modification, or disclosure.

Policy Updates

From time to time, we may change this Privacy Policy. If we decide to change this Privacy Policy, in whole or in part, we will inform you by posting the revised Privacy Policy on the WSM website. Those changes will go into effect on the effective date disclosed in the revised Privacy Policy.

Contact Us

If you have any questions or concerns regarding this WSM Privacy Policy, please contact us by e-mailing us at [email protected]