Privacy Policy

FOR VISITORS, PLATFORM USERS, AND END USERS
Last Updated: August 23rd, 2019

We at Frequency, Inc. (“Frequency,” “we,” “us,” or “our”) have created this privacy policy (this “Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Policy relates to the information collection and use practices of Frequency in connection with our website located at www.frequencyads.com (the “Website”), our ad-serving capabilities, and provision of the dashboard whereby performance metrics are provided (the “Platform,” and together with the Website, the “Services”).  

Description of Users and Acceptance of Terms
This Privacy Policy applies to (i) visitors to the Website (“Visitors,”), (ii) registered users of the Services, which may be advertisers, advertising agencies, publishers, creative agencies and vendors, and/or their agents (“Customers”), and (iii) end users of the advertisements (“Advertisements”) generated through the Services (“End Users”).By accessing our Services, you are agreeing to the terms of this Privacy Policy.

The Information We Collect and How We Use It
In the course of operating the Services, Frequency collects or receives the following types of information (which may be considered “personal information” in certain instances) and uses such information as described herein:

Contact Information
We collect contact information through our Services; the contact information collected varies depending on the webpage or area of the Platform, but typically includes some combination of your name, email address, company information, and any information you provide in messages to us.  We use such contact information for purposes such as registering Customers for an account, responding to, and following up regarding, your inquiries, providing you with requested information, sending you email alerts (including marketing emails), or engaging in a business relationship for the provision of the Services.

Billing Information
In order for us to process Customer payments for use of the Services, Customers will be required to provide certain billing information, such credit card number, expiration date, bank account information, billing address, activation code, and similar information.  

Server Logs
Like most websites today, we automatically collect certain information when Visitors visit the Website and when Customers use the Platform. The log files contain data about the nature of such access, including the device’s IP address, user agent string (e.g., operating system and browser type/version), and referral URL (i.e., the external source used to access the Services and sections of the Website viewed). We may use these log files for purposes such as assisting in monitoring and troubleshooting errors and incidents, analyzing web traffic, or optimizing the user experience.

Cookies
We use cookies on our Services, as well as on Advertisements we serve on behalf of Customers (more on that below). Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer will “remember” information about your visit. We use both 1st and 3rd-party session cookies and persistent cookies. Below is a general primer on session and persistent cookies; information collected by cookies depends on its particular purpose. For more information, please see the information regarding analytics providers discussed further below.
• Session Cookies: We use session cookies to make it easier for you to navigate our Services. A session ID cookie expires when you close your browser.
• Persistent Cookies: A persistent cookie remains on your hard drive for an extended period of time or until you delete them. You can remove persistent cookies by following directions provided in your web browser’s “help” file. To the extent we provide a log-in portal or related feature on our Services, persistent cookies can be used to store your passwords so that you don’t have to enter it more than once. Persistent cookies also enable us to track and target your interest to personalize your experience using the Services.In some cases, we may associate information that you have provided to us (e.g., email address) with the cookies that we use. In addition to facilitating the purposes described above, this is useful in understanding your engagement with other content related to our Services (e.g., email open rates, URL clickthroughs, etc.).If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, certain aspects of the Services may not function properly or as intended.

Analytics
We use one or more third-party analytics services to evaluate use of the Services by compiling reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Services you visit, number of links clicked, search terms, and other similar usage data) and analyzing performance metrics. These third parties use cookies and other similar technologies to help collect, analyze, and provide us reports or other data. By accessing the Services, you consent to the processing of data about you by analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection (where provided by such third parties), please visit the sites below. Please note that this list may be subject to change.

Website
For Google Analytics, please visit: https://www.google.com/analytics    

Platform
For Mixpanel, please visit:  https://mixpanel.com/

Ad Interaction Data
On behalf of our Customers, we obtain End User information regarding their interactions with Advertisements through cookies, ad tags and similar technologies. Such information may include ad ID (such as Android Adv. ID or iOS IDFA), timestamps, device type, device ID, latitude/longitude and/or IP address, and event data, such as how long an End User listened to the Advertisement and whether the End User clicked on the Advertisement. This information is aggregated and anonymized and shared with Customers to provide analytics, ad serving, ad optimization, and targeting insights.Our Customers may request that we use third party analytics providers (explained in more detail in the Analytics section above) or third-party advertising and re-marketing providers with respect to their Advertisements to help serve appropriate ads to End Users and to help track results or measure effectiveness of those ads. Third-party advertising and re-marketing providers collect information through cookies, pixel tags, and other similar technologies for the purposes of personalizing or otherwise understanding how End Users engage with ads or other content, including helping to tailor, target (i.e., behavioral, contextual, retargeting, and remarketing), analyze, report on, and/or manage advertising campaigns or other initiatives. For example, when a browser visits a site, pixel tags enable us and these third-parties to recognize certain cookies stored within the browser to learn which ads or other content bring a user to a given site. Third-party cookies placed by Frequency’s Customers in connection with the Services will be subject to the respective Customer’s privacy policy.    

Geolocational Information
Certain features and functionalities of our Services are based on your location. In order to provide these features and functionalities, we may, with your consent, automatically collect geolocation information from your device via your browser’s location services. This consent may be provided by you on the device level (e.g., you have consented to location services generally through your browser’s settings) or by accepting our request for geolocation access on the Services. Please consult your browser’s documentation regarding how to turn off location services. If you disable location services, you may not be able to use the full array of features and functionalities available through our Services.

Aggregate Data
In an ongoing effort to better understand interactions with the Services, we might analyze Visitor and Customer information in aggregate form to carry out, maintain, manage, and improve operations in connection with the Services. This aggregate information does not identify any individual, including you, personally. We may share this aggregate data with our affiliates, agents, and business partners and/or commercialize it in a variety of ways. We may also disclose aggregated user statistics in order to describe the Services to current and prospective business partners and to other third parties for other lawful purposes.

Business Transfers
In the event of a merger, dissolution, reorganization, or similar corporate event, or the sale of all or substantially all of our stock or assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy. This policy shall be binding upon Frequency and its legal successors-in-interest.

Disclosure to Public Authorities
We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

Sharing with Third Parties
We may also engage other companies and individuals to perform certain business-related functions on our behalf in connection with our Services. Examples may include cloud hosting providers, technical assistance and security, database management/back-up services, analytics, digital marketing (e.g., marketing automation), customer relationship management, and customer service. These other companies will have access to your information only as necessary to perform their functions and to the extent permitted by law. We may also share your information with any of our parent companies, subsidiaries, affiliates, or other companies under common control with us in order to support (i) the marketing, sale, and delivery of any products or services; and (ii) the other purposes described herein.

Opt-Out for Email Marketing and Certain Other Communications
You may also manage your receipt of marketing communications by clicking on the "Unsubscribe" link located on the bottom of an applicable Frequency marketing email and following the instructions found on any page to which the link may take you, or by contacting us at privacy@frequencyads.com.  In all such cases, please allow us a reasonable time to process your request.You cannot opt out of receiving administrative, support, or transactional e-mails.

How We Protect Your Information
We take commercially reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet.

Retention of Personal Information
We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, subsequently authorized, or as allowed under applicable law.

Children
We do not knowingly collect personal information from children under the age of 13 through the Services. If you are under 13, please do not give us any personal information.  We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information to us.  If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at privacy@frequencyads.com and we will endeavor to delete that information from our databases.

Important Notice to All Non-US Residents
Our servers are located in the US. If you are located outside of the US, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the US. Your decision to provide such data to us, or allow us to collect such data through our Services, constitutes your consent to this data transfer.

Your California Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact Frequency via email at privacy@frequencyads.com.

Do Not Track
Frequency does not respond to "Do Not Track" settings or other related mechanisms at this time.

Links to External Websites
The Services may contain links to third-party websites (“External Sites”). Frequency has no control over the privacy practices or the content of any such External Sites.  As such, we are not responsible for the content or the privacy policies of such External Sites. You should check the applicable privacy policy and terms of use when visiting or submitting any information through such External Sites.

Changes to This Privacy Policy
This Privacy Policy is effective as of the ‘Last Updated’ date stated at the top of this Privacy Policy.  We may change this Privacy Policy from time to time with or without notice to you. By visiting the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes.  Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your information is governed by the Privacy Policy in current effect.  Please refer back to this Privacy Policy on a regular basis.

How to Contact Us
If you have questions about this Privacy Policy, please e-mail us at privacy@frequencyads.com with “Privacy Policy” in the subject line.