Full Privacy and Cookies Policy
1. WHAT PERSONAL DATA DO WE COLLECT?
In this Privacy Policy your “personal data” means information or pieces of information that could allow you to be personally identified. Throughout the Sites you may wish to request information about our Services or our companies. You may also apply for a career with us. You will therefore be asked to provide personal data to identify you personally so that we can provide further information and/or Services to you or process your employment application. We may also ask for additional non-identifiable information, such as how you anticipate you will make use of our products and services.
Our Careers Page also allows you to apply for a role using LinkedIn or by entering your details directly. These services will authenticate your identity, provide you the option to share certain personal data (such as your name and email address) with us, and enable you to pre-populate the sign-up form.
When you provide us with personal data and provide your consent, where necessary, or enter into a contract with us, you are authorising us to use that data in accordance with the terms of this Privacy Policy, which includes your right to limit or withdraw your consent for our use of the personal data (see “Your Rights and our Contact Information”). We will process your personal data on the basis that your personal data is required for us to provide the Services to you under the relevant contract between us.
Types of information we collect from you directly:
The types of information you may give us directly include:
- your name;
- your username and password to access our Services;
- employer;
- job title;
- telephone number;
- e-mail address;
- employment information;
- address;
- academic information;
- how you anticipate you will make use of our products and services; and
- how you heard about us.
Types of information we collect when you visit our Sites:
You can visit and navigate our Site to find information about our companies and Services without stating who you are. We use “cookies” in connection with a Site analytics service that helps us better understand how you use the Site and how you navigate through the Site, helps us learn what content is being reviewed, and helps us administer the Site. We do not link data collected from these cookies to personally identifiable information (direct identifiers) we collect from you.
Here are examples of the types of information we may collect from you when you visit the Sites:
- information about the type of browser and operating system you use;
- your internet service provider;
- details of the web pages and advertisements you have viewed;
- your IP address;
- log on time;
- the hyperlinks you have clicked; and
- the websites you visited before arriving at our Site.
2. HOW WE USE YOUR INFORMATION
Collecting your personal data enables us to provide our services to you. This personal data is provided either by you directly, or by a representative of your organisation. It also helps us to better understand what you need from us so that we can provide it. When you provide your personal data and related information about your interests, we can learn more about what types of products and services you might be most interested in so that we can present the right information to you and improve your experience of our Sites. We will hold your personal data for as long as we need it to provide information, products and services to you, or until you withdraw your consent for us to process your personal data, whichever is earlier (see “Your Rights and our Contact Information”).
We use personal data that we collect about you for the following purposes:
- to contact you to further discuss your interest in our companies and our Services;
- to better understand what products or services may be of interest to you;
- to enable the use of our services
- to improve our Sites and the Services we provide by presenting the information that is most interesting to users of the Sites;
- to send you information regarding our companies or partners (such as marketing promotions and events);
- to evaluate our Sites, your experience as a visitor, and our offerings to our clients; and
- to track where our visitors may be coming from and what type of software they are using so we can continuously improve our visitors’ online experience and improve the Sites.
When you express interest in purchasing our services, we also use personal data that we collect about you for the following additional purposes:
- to take necessary steps at your request prior to entering into a contract with you for our Services; and
- to provide you with Services in accordance with a contract we agree with you.
3. COOKIES
We use “cookies” which are files or pieces of information that may be stored on your computer (or other internet enabled devices, such as a smartphone or tablet) when you visit our Sites. We use cookies to make our Sites easier to use and to better tailor the Sites and our products to your interests and needs. Cookies may also be used to help speed up your future activities and experience on our Sites. For example, a Site can recognise that you have provided your personal data and will not request the same information a second time.
We partner with third parties to provide certain services on our Site. We and our third-party partners use cookies or similar technologies in order to analyse your behaviour across our Sites.
We may also use cookies to collect information about the device you are using to view the Site or the type of Internet browser or operating system you are using, and link this to your personal data. This is to ensure that our Sites present the best web experience for you and are effective information resources.
When you click “Accept” on our cookie banner, you agree to the placement of cookies on your device by us and our analytics providers. If you do not click accept, we will place an opt-out cookie on your browser instead of our tracking cookie. You may change your preferences or withdraw your consent at any time. Most internet browsers are initially set to accept cookies, however it is possible to change the settings to block the cookies in order to opt out of the cookies we use on our Sites or to alert you when cookies are being sent to your device. You can refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. But please remember, if you disable the cookies that we use, or you do not accept our cookies, you may not be able to visit certain areas of our Site or you may not receive personalised information when you visit the Site. If you would like more information about the types of cookies we use and how we use them, please click here.
What does a cookie look like?
A cookie will usually contain the name of the website from which the cookie has come from, the “lifetime” of the cookie (i.e. how long the cookie will remain on your device), and a value, which is usually a randomly generated unique number.
What types of cookies do we use and how can you opt out?
Strictly necessary cookies
These cookies enable services you have specifically asked for. For those types of cookies that are strictly necessary, no consent is required. These cookies are essential in order to enable you to move around our Sites and use its features, such as accessing secure areas of our Sites. Without these cookies services you have asked for, like maintaining an account and being able to log-in cannot be provided.
Online Behavioural Advertising
FreeWheel does not collect data, nor set cookies, to build profiles for Online Behavioural Advertising. You should check http://www.youronlinechoices.com/ and http://www.networkadvertising.org/choices/ to understand which companies use this data and opt out if you wish to.
Web Analytics Tools
The Sites uses web analytics tools, specifically Google Analytics to track your interactions with a Site and to store information, such as your IP address, what time you visited, whether you’ve visited before and what Site referred you to our Site. Site measurement statistics may be used to personalise your website experience, as well as to evaluate (anonymously and in the aggregate) statistics on website activity. We use this information to measure the effectiveness of our web presence and to compile statistical reports.
Where we use Google Analytics, we share this information with Google to help Google improve its capabilities for analyzing sites. For more information about Google Analytics, go to: http://www.google.com/intl/en/analytics/privacyoverview.html.
When do our cookies expire?
Except for essential cookies, most of the cookies on our Site expire at the end of your current session on our Site.
4. HOW WE MAY CONTACT YOU
We use an opt-in standard for sending you marketing communications, which means we will only do so with your express consent. If you wish to opt out of receiving emails from us (such as FreeWheel’s Video Monetization Reports), please follow the unsubscribe instructions in any emails you receive from us or contact us as provided below.
5. RETENTION OF YOUR DATA
We will keep the data we hold about you for as long as we believe is necessary to provide you the information you requested or as reasonably useful for commercial purposes unless you tell us you would like us to stop holding your data.
6. SHARING INFORMATION
We may share your personal data with third parties as described below:
- other companies that form part of the FreeWheel group so that they can understand which products and services are more likely to be suited to you;
- third party analytics companies such as Google Analytics to track your interactions with a Site and to store information, as well as personalise your web experience;
- a product experience platform to track your user journey with our product so that they can assist us in improving your experience with our product;
- recruitment management providers managing your employment application to us;
- customer service providers; and
- we will also disclose your personal data if we are required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- if at any time in the future we (or our assets) are purchased by another company we can share your data with them as one of those assets.
Any such third parties are not authorised by us to use your personal data in any other way and will be required by us to implement measures to protect your personal data. Please note that we may need to disclose your personal data if we are required to do so by law including to meet national security or law enforcement requirements.
7. INTERNATIONAL TRANSFER OF INFORMATION
Our primary data centres are located in Europe and the USA. These data centres are used to store data that we receive from end-users. We comply with all applicable laws to protect the security of data during international transfer.
8. SECURITY
We take reasonable precautions to keep your personal data secure and where we share your data with third parties we require them to do the same. The information is collected and stored in a manner that is appropriate for the nature of the data that we collect and the need to fulfil your request. Access to your personal data is restricted to prevent unauthorised access, loss, modification or misuse and is only permitted among our staff on a need-to-know basis. If you have any questions about the security of your personal information, you can contact us at legalnotices@freewheel.tv.
9. UPDATES
This Policy is effective as of the date set out above. We encourage you to check this Policy from time to time. If we change this Privacy Policy, we will notify you by posting the updated version of the privacy policy here. If, however, we intend to use personal data in a manner different from that stated at the time of collection we will notify visitors by posting a notice on our Sites for thirty (30) days in advance of such use and we will give you the opportunity to opt out.
10. YOUR RIGHTS AND OUR CONTACT INFORMATION
We collect and process your personal data on the basis that your personal data is required for us to provide our Services to you under our contract with you or for the legitimate purposes set out in this Privacy Policy. See here for a list of the personal data we will collect about you.
Please note that you always have the right to request that we:
- provide you information about how we use your data;
- give you access to, and a copy of your personal data we hold in our systems;
- stop contacting you;
- correct, update or delete your personal data in our records;
- stop using, and ensure that all third parties stop using, some or all of your personal data; or
- note any violations of the Privacy Policy.
If you would like us to change how we deal with your personal data, you can send us an email at legalnotices@freewheel.tv or write to us at: Adazzle Limited, Aldywch House, 71-81 Aldwych, London WC2B 4HN, Attn: Legal Counsel. We will respond to your request within a reasonable timeframe. Please note that we will require that you validate your identity prior to processing your request. If we are unable to accept your request, we will provide you with our reasons.
Please do not hesitate to contact us if you have any questions, comments or concerns about this Privacy Policy. To assist us in dealing with your request, please provide your full name and details of your query.
In addition, if you are located in the EU, you have the right to lodge a complaint with your local data protection authority about our use of your personal data.
11. DO NOT TRACK
When we collect tracking information on our Sites, we do not respond to Users’ Do Not Track settings in browsers. You may choose to decline cookies in your browser settings on a desktop computer, or by declining tracking on a mobile device.
12. CHILDREN
This Site is not intended for, nor does it seek to receive information from, children under the age of 13.
13. OUR SERVICES TO CUSTOMERS
We are an application services provider, and host a software application that our customers access online. Our application does not process personal data except that of the users of the application, which we process as a data controller.
14. RELATIONSHIP TO COMCAST
None of the principles in this Policy were affect by FreeWheel’s acquisition by Comcast Cable Communications, LLC (“Comcast”). All of FreeWheel’s contractual obligations with respect to each customer’s information have remained intact. Also, post-acquisition, FreeWheel has continued to operate as a wholly-owned subsidiary of Comcast, meaning the two companies are separate legal entities. As such, FreeWheel cannot per the terms of its agreement with each customer allow Comcast (or any of Comcast’s other affiliates) to access FreeWheel customer data for any purpose. Maintaining FreeWheel’s status as a trusted partner is critical to the continued success of our business. Comcast and FreeWheel have been careful to organise the corporate structure so as not to disrupt that trust.
