Publica, LLC

Privacy Policy

Date of last revision: December 14th, 2020

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This Privacy Policy explains how we collect, use, disclose, and otherwise process personal information in connection with our services. This Privacy Policy is not a contract and does not create any legal rights or obligations.

Region-Specific Disclosure

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

• If you are a resident of the State of California in the United States, please click here for additional California-specific privacy disclosures.

What is personal information?

When we use the term “personal information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to you.

Our Collection of Personal Information

From the first moment you interact with us, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our services and sometimes we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties, even before our first direct interaction.

Personal Information Automatically Collected

As is true of most digital platforms, we collect certain personal information automatically through your connected TV device, including:

• Log File Data, including your internet protocol (IP) address, operating system, browser type, browser id, device id, date/time of visit, and pages visited.
• Analytics Data, including the electronic path you take to our services, through our services and when exiting our services, as well as your usage and activity on our services, such as the links and object you view, click or otherwise interact with (also known as “Clickstream Data”).
• Location Data, including your general geographic location based on your IP address or more precise location when accessing our online services through a mobile device.

For information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, and any choices you may have in relation to its collection, please visit our Cookie Notice.

Personal Information from Other Sources and Third Parties

We also obtain personal information from other sources, which we often combine with personal information we collect either automatically or directly from you.

We receive the same categories of personal information as described above from the following sources and third parties:

• We use Maxmind to refine your IP address to a general location.

Our Use of Personal Information

We disclose personal information in the following ways:

- Within Publica, LLC - We enable 3rd party CTV programmers to offer free programming in return for targeted advertising. Publica, LLC entities disclose personal information to other of our entities for purposes and uses that are consistent with this Privacy Policy.

- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.

- Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:

• in connection with the establishment, exercise, or defense of legal claims;
• to comply with laws or to respond to lawful requests and legal process;
• to protect the rights and property of us, our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
• to detect, suppress, or prevent fraud;
• to reduce credit risk and collect debts owed to us;
• to protect the health and safety of us, our customers, or any person; or
• as otherwise required by applicable law.

- Consent: We may disclose personal information about you to certain other third parties with your consent.

Children’s Personal Information

Our websites and services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you are under the age of 13, please do not use our websites or online services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.

Third-Party Websites

Our websites and online services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy policies.

Contact Us

If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to privacy@publica-project.com

Alternatively, inquiries may be addressed to:

Publica, LLC
76 Roosevelt Circle,
Palo Alto, CA, 94306