Privacy Policy

Your Privacy at Optimum Media

Effective: June 26, 2024

Here at Optimum Media, LLC (“Optimum Media”), and with our wholly-owned subsidiaries like Juice Media, Inc. (together, “us,” “we,” or “our”), we provide innovative, data-driven multiscreen advertising solutions to our clients.  We know you care about how your personal information[1] is used.  We provide this privacy policy (the “Privacy Policy”) because we take our responsibility to be transparent about how we use and protect your information seriously.  

You can also find information about the rights and choices you may have when it comes to your personal information here.  We’ve organized this Privacy Policy depending on what sort of relationship you have with Optimum Media. 

If you have any questions, please reach out to us at Privacy@Optimum.Media.

[1] We use the term “personal information” to mean information that identifies a specific person or is reasonably linkable to a specific person.

Our General Privacy Practices

We are an advanced advertising, technology, and data analytics group of companies based in the United States.  We help our clients reach, grow, and/or understand desired audiences.  To do this, we use data sets compiled from publicly available information, data we have licensed or purchased from affiliates or third-party providers, as well as data directly supplied by our clients and/or, in certain limited cases, by individuals directly.  Cookie-based audiences are created by interfacing with our cookie match partners to onboard and match our data sets with pseudonymized identifiers. 

All the data we use to create audience segments undergoes a rigorous process in a clean room, maintained by an Affiliate, where consumer-specific personal information is stripped away, and aggregated sets of pseudonymized and/or de-identified identifiers linked to specific audience segments are created.  We process this data in such a manner that any information can no longer be reasonably attributed to a specific individual without the use of additional information.  This additional information is kept separately, and we have adopted technical and organizational measures to ensure that personal information is not attributed to any individual.  To the extent that we possess any personal information that has been de-identified or pseudonymized, we maintain and use such personal information without re-identifying it, and contractually require third parties and service providers to do the same.

We strive to provide transparency and individual control to individuals over the use of their personal information in online advertising.  To that end, we comply with all applicable laws and applicable industry self-regulatory guidelines (which collectively we call “Laws” throughout this Policy), including those of:

·         the Digital Advertising Alliance (“DAA”);

·         the Interactive Advertising Bureau (“IAB”); and

·         The Network Advertising Initiative (“NAI").

These agencies provide various tools that can help you manage your privacy preferences.  

To update your AdChoices Opt Out settings in the United States, click here. 

To manage all NAI member sites’ settings, click here. 

Our Privacy Policy

This Privacy Policy is designed to provide you with information about how we collect, disclose, use, and protect the information that we collect through our websites, such as Optimum.Media or JuiceMedia.io (the “Websites”), any website, app, resource, or tool displaying or linking to this Privacy Policy (together with the Websites, our “Sites”), and our content discovery platforms, feeds, widgets, analytics tools, pixels, and/or other technical applications that we provide on third-party websites (collectively, our “Services”). 

Optimum Media is a member of the Optimum family, which includes brands and businesses such as Optimum, Juice Media, News12 and i24News (the “Affiliates”).  We may use information collected through the Sites and Services in various ways, depending on whether you are:

·         a visitor to the Websites (a “Visitor”), which may include Clients and Users, as defined below;

·         a publisher, advertiser, or other content provider that has or may have a contractual relationship with us (a “Client”); or

·         a user, i.e., a person that interacts with our Services and/or our Sites, or on our Clients’ websites and digital properties (a “User”).

Because this Privacy Policy describes the privacy practices for all of our Sites and Services, some parts may not apply to you.  We outline specific provisions for each of these categories and then general provisions for all collected information thereafter.

To jump to any specific section of the Privacy Policy, use the hyperlinked table of contents below.  

1. Visitors to Our Websites

Please note that this Privacy Policy is distinct from our Terms of Use, which is a separate document. 

As explained above, we consider anyone who visits the Websites a Visitor.  Visitors may also be Clients and Users, depending on the circumstances and their use of the Sites.   

1.1  Information We Collect About Visitors to Our Websites (“Visitor Information”)

We collect Visitor Information either directly from you or from service providers that collect this information during your use of our Websites.  We may combine all the Visitor Information that we collect from various sources. 

Further, we don’t intend to collect sensitive information about Visitors to our Websites.  Sensitive information is defined differently in state privacy laws across the country, but may include personal data revealing your race, ethnic origin, religious beliefs, health, sexual orientation, citizenship, or immigration status.  If you provide that information to us in connection with your visit to our Websites, you affirmatively consent to us processing it.  If you think you may have accidentally provided us with sensitive information and you want to revoke your consent for us to process it, please contact us at  Privacy@Optimum.Media.

Here are the types of Visitor Information we may collect:

  • Information You Provide To Us: We are business-to-business (“B2B”) companies and do not intend to collect or process personal information about non-business Visitors. Nevertheless, we may collect personal information about a Visitor if you voluntarily provide it to us (e.g., by completing our “Contact Us” form or when making a payment online).  Visitor Information may include information that identifies or is reasonably capable of being associated with you personally, i.e., your personal information, including your first and last name, your mailing address, your email address, your telephone number, and your payment card information.  Information that Visitors provide directly to us is not processed through our Affiliate’s privacy-safe clean room.

  • Information We Collect Automatically: When you visit our Websites (whether navigating there directly or indirectly, e.g., via link) we (and/or our service providers) may collect and log information automatically, such as your Internet Protocol (“IP”) address, device, device MAC ID, your Internet browser, your Internet service provider, the duration of your visit, and your domain type, among other things.  Logging this information does not by itself provide us with your name, email address, or home or work address. 

  • Information Collected via Cookies, Pixels, Web Beacons, and Similar Technologies: We may also collect Visitor information in the following ways:

  • Cookies.  Like most website operators, we (and/or our service providers) use cookies to collect information about your visit to our Websites and to manage information concerning your preferences.  A cookie is a small piece of text sent to your browser by a website you visit.  It does not collect or provide your name or any other personal information about you.  It can, however, be used by a website, including our Websites, to note information about your visit, such as your type of web browser, operating system and IP address, to better tailor the site for you.  It can also be used to recognize you when you return as a repeat visitor to our Websites. You can control what cookies are accepted by your computer through the settings on your web browser or by deleting the cookies from your computer. Doing so, however, may limit the personalization available to you.

  • Clear GIFs. Like many websites, we (and/or our service providers) may use clear GIFs (also known as web beacons, Internet tags, or pixel tags).  Clear GIFs are lines of code that allow websites to summarize overall visitor usage patterns and to provide personalized services.  We may use clear GIFs, for instance, to track visitor preferences or to gather aggregated information about visitor usage patterns. 

1.2  How We Use Visitor Information

We use Visitor Information for several important purposes, including:

  • to help us fulfill requests for information or communication;

  • to protect the security of Visitors and the Sites;

  • to facilitate payment transactions for Services;

  • to help prevent fraud;

  • to inform you about new products and services from us, our Affiliates, or other companies we work with, as well as promotional offers;

  • to provide personalized advertisements based on your interests and/or activity across browsers and devices, including through retargeting;

  • to provide you with Sites and Services of enhanced value to you; and

  • to market and promote our products, Services and Sites.

We may also use it to improve our Websites’ services, to gauge the effectiveness of the Websites, and to improve and enhance Visitors’ experiences on the Websites.

1.3  How We Disclose Visitor Information

We only disclose Visitor Information as described in this Privacy Policy.  We may share Visitor Information with the following types of parties:

  • Service Providers.  We may share Visitor Information, including Visitors’ personal information, with our service providers.  For example, we may use analytics services to collect data about Visitors to our Websites.  These service providers are authorized to use any personal information collected only as necessary to provide these services on our behalf, and we contractually require our service providers to maintain at least the same level of confidentiality for the personal information we may provide to them as we maintain for such information.

  • Lawful Disclosures.  You acknowledge and agree that we may disclose any Visitor Information, including your personal information, if we are required to do so by law or if we have a good faith belief that such disclosure is reasonably necessary:

  • to comply with applicable Law, a subpoena, court order or other legal process;

  • to investigate violations of this Privacy Policy, our Terms of Use, or other contracts we or our service providers may have with you;

  • to respond to claims that any content violates the rights of third parties;

  • to respond to your requests for customer service; and

  • to protect the rights, property, or personal safety of the public, Optimum, and/or any Affiliates and/or their respective employees, agents and subscribers. 

  • For Emergencies.  We may also disclose your personal information to law enforcement agencies in emergency circumstances, where the disclosure of such information is consistent with the types of emergency disclosures permitted or required by law. 

  • Mergers.  We may also share Visitor Information, including personal information, in the event of a merger, acquisition or sale of all, or components of, our business.  When we do this, those employees, agents and Affiliates will use and protect Visitor Information in a manner that is consistent with this Privacy Policy.

1.4  Your Choices as a Visitor

If you wish to opt-out of marketing or promotional email communications from us, you may opt-out via the unsubscribe link included in such emails.  We will try to comply with your request(s) as soon as reasonably practicable. 

Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our services.

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2.  Clients

Please note that this Privacy Policy is distinct from our Standard Order Terms and Conditions, which is a separate document. 

As explained above, “Clients” is the term we use to refer to a publisher, advertiser, or other content provider that has or may have a contractual relationship with us. 

2.1  Information We Collect from Our Clients (“Client Information”)

We collect Client Information directly from our Clients.  For example, if a Client contacts about entering into a business relationship, we collect the Client’s business contact information, and we will collect a username and password if a Client creates an account on any of our Sites. 

We also collect information when a Client provides it to us, like by sending us an email, subscribing to our email newsletter, or filling out a form on one of our Sites.  We may also collect information about Clients through publicly available sources, or through social media (e.g. Facebook, LinkedIn, Google).

2.2  How We Use Client Information

We use Client Information to communicate about the Client’s account, to respond to requests, inquiries, and complaints, and to provide product updates, news, and best practices.  

For any information collected via a social media contact form, or other third-party website contact form, we’ll use the information you provide to us, including your name, email, and phone number, to contact you about our Sites and Services, and add you to our email newsletter and other marketing materials, which you can unsubscribe from at any time. 

We don’t intend to collect sensitive information about our Clients.  Sensitive information is defined differently in state privacy laws across the country, but may include personal data revealing your race, ethnic origin, religious beliefs, health, sexual orientation, citizenship, or immigration status. If you provide that information to us you consent to us processing it. If you think you may have accidentally provided us with sensitive information and you want that information to be deleted, please contact us at Privacy@Optimum.Media.

2.3  How We Disclose Client Information

We may disclose Client Information as follows:

  • Affiliates. We may disclose Client Information to any of our employees and agents at our Affiliates.  We may also share Client Information in the event of a merger, acquisition or sale of all, or components of, our business.  When or if we do this, those employees, agents and Affiliates will use and protect Client Information in a manner that is consistent with this Privacy Policy.

  • Service Providers. We may disclose Client Information to vendors, service providers, agents, contractors, or others who perform functions (e.g., maintenance, data analysis, customer relationship management, email marketing, surveys, data hosting, fraud detection) on our behalf.

  • Other Clients. We may disclose Client Information to other Clients where relevant to the Services we provide. For example, we may provide publishers with information about what advertisers may appear on their network or advertisers with information about which publisher websites their campaigns have appeared on.

2.4  Your Choices as a Client

Clients may access, correct, or update the information that they have provided to us by either updating the information in their account, by emailing their dedicated account manager, or by emailing us at Privacy@Optimum.Media.  We may send periodic promotional or informational emails in accordance with our Clients’ communications preferences.

You may opt out of such communications by following the opt-out instructions contained in any email received.  Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving marketing and advertising emails, we will still send you emails about your account and any Services that you have requested or received from us.

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3. Users

3.1  Information We Collect about Users (“User Information”)

As described above in the section titled “Our General Privacy Practices,” we collect User Information to help our Clients target unique audiences across a range of devices.  We call a person that interacts with our Services and/or our Sites, or on our Clients’ websites and digital properties a “User.”

All User Information undergoes a rigorous process in our Affiliate’s clean room where consumer-specific personal information is stripped away before it is integrated into our systems.  Because we are not able to tie any personal information collected to a specific User after this process, we do not consider User Information to be personal information.

More information about how we collect User Information is below:

  • From Our Clients.  We do not accept personal information from our Clients directly and we require our Clients to agree not to disclose any personal information to us. From time to time, our Clients have certain information, including personal information, that they have collected and want us to use on their behalf to target particular data segments. To protect consumer privacy, we require our Clients to use an independent third-party platform to transmit the information to an Affiliate’s clean room. There, the Affiliate strips away personal information about any consumer before sending the information to us. We further require our Clients to represent and warrant that they have necessary rights to provide the information to us, i.e., that they collected the information in compliance with all applicable Laws.

  • Publicly Available Information.  To enhance our ability to provide relevant marketing, offers and services, we also obtain publicly available information about consumers, such as postal and email addresses, from other sources including public databases, joint marketing partners, and data providers.  All such information is routed through our Affiliate’s clean room to ensure that the information is no longer reasonably linkable to any consumer before we receive the information. 

  • Survey Information.  We may gather information from Users from time to time via surveys (“Survey Information”).  These surveys may ask the User to provide information that is considered sensitive under some state privacy laws (e.g., a survey may ask you about your political leanings or ethnicity) or to provide other personal information.  The Survey Information that is provided, if any, will be aggregated and de-identified such that it is not linkable to a particular User.  All surveys are voluntary.  If you choose to share Survey Information with us as a User, you consent to our use as outlined in this Privacy Policy. 

  • Clear Gifs. When Users interact with our Services that appear on our Clients’ websites and digital properties, we (and/or our service providers) may use clear GIFs (also known as web beacons, Internet tags, or pixel tags).  Clear GIFs are lines of code that allow websites to summarize overall User usage patterns and to provide personalized services.  We may use clear GIFs, for instance, to track User preferences or to gather aggregated information about usage patterns.  Before we place any GIFs on our Clients’ websites, we require the Clients to represent and warrant that any website on which pixels are placed have all necessary privacy disclosures and opt-out mechanisms, and that all needed consents have been obtained, as required by all applicable Laws and industry best practices.

  • From Our Ad Serving Partners. From time to time, in the course of performing our Services, we may receive “Performance Data”—i.e., information that allows us or our Clients to measure how well an advertising campaign performed, such as how many times an ad was shown or a clicked on—from our ad-serving partners.

  • Passive Automatic Electronic Collection. Like operators of most other websites, we (and/or our service providers) may collect and log information automatically, either directly or through a third party service provider.  For example, we may collect your IP address, the name and location of your Internet service provider, the type and version of your browser, the length of time you visit the Sites, your search queries, and the average number of pages you viewed.  Logging your IP address does not by itself provide us with your name, email address, or home or work address.  We use this log information for systems administration purposes and for technical troubleshooting.  We may also use it to gather general demographic information about you, such as your general location.

3.2  How We Use User Information

We may use User Information for the following purposes:

  • To Provide our Services.  We may use User Information to provide our Services to Users and our Clients.

  • To Tailor Content. We may use User Information to tailor the content and information that we may send or display to Users; to retarget content to Users through our Services and elsewhere; and to otherwise personalize your experiences while using our Services.  We do this across multiple browsers and/or devices like smartphones, computers, tablets, and televisions. 

  • To Create Data Segments for our Clients.  We may use User Information to create data segments for our Clients in connection with Tailored Advertising.

  • What is Tailored Advertising?  “Tailored Advertising,” also known as targeted advertising or personalized advertising, refers to the practice of delivering advertisements to specific individuals or groups based on their demographics, interests, behaviors, or other criteria, which then aims to make the ads more relevant and appealing to the targeted audience. 

  • What is a Data Segment?  A data segment is a grouping where members share one or more attributes (e.g., travel enthusiasts).  As an example, we work with our Clients to provide Tailored Advertising to those who are more likely to be interested in our Cliaents’ content and advertisements. Data segments are aggregated and do not include individual identities. If you do not want to be included in a data segment, you have some options.

To update your AdChoices Opt Out settings in the United States, click here. 

To manage all NAI member sites’ settings, click here. 

We do not knowingly create segments that are based upon what we consider to be sensitive information (for example, personal data that reveals an individual’s racial or ethnic origin, religious affiliations, citizenship, or that concerns sensitive health information, sex life or sexual orientation, or genetic or biometric data) without appropriate consent, as determined by state law.  Our Clients may use standard health-related segments about non-sensitive conditions, such as an inferred interest in health and wellness or over-the-counter medicine.  We also offer some Clients standard political-related segments that may indicate general political sentiment, interest in specific political issues, and political party affiliation.

3.3  How We Disclose User Information

We may disclose User Information to the following parties:

  • Affiliates.  We may disclose User Information to any of our current or future Affiliates, parent companies, or subsidiaries.  We may also share User Information in the event of a merger, acquisition or sale of all, or components of, our business.  

  • Service Providers.  We may disclose User Information to our service providers to provide services on our behalf, and we contractually require such service providers to comply with all applicable Laws.

  • Our Clients.  We may disclose User Information in an aggregated and anonymized basis to Clients if relevant to those Clients.  For example, we may provide publishers with information about the viewing and click-through patterns of the content they publish and may provide advertisers with information about conversion rates for analytics purposes.

3.4  Your Choices as a User

As described in this Privacy Policy, we do not consider User Information to be personal information because it has been purposefully de-identified and/or pseudonymized and is not reasonably linkable to a specific person or household.  Because of this, we may not be able to verify what information we have about any User to properly respond to a request to access, correct, or delete your personal information.  If you have questions about this, please email us at Privacy@Optimum.Media.

Applicable state laws require data controllers to give consumers the right to opt out of the processing of any personal information.  Because our Services facilitate the delivery of advertising and we generally do not interact directly with consumers, we ask our Clients to collect and pass information regarding a consumer’s opt out, which we then honor when performing our Services.  If you wish to limit the amount of User Information about you that may exist, you may take the following steps:

  • Offline Data Sources. Opting out of telemarking and direct mail lists will help prevent your information from being included in lists we license from third parties in connection with our  Data.  You can visit the following site to learn more about those opt-outs: https://dmachoice.thedma.org/.

  • Tailored Advertising. If you would like to opt out of Tailored Advertising (i.e., advertising that is tailored to your interests as gauged by your online activity) generally, the most effective way to do so is via the opt-out mechanisms made available by advertising industry groups, in particular those offered by the Network Advertising Initiative (“NAI“) and the Digital Advertising Alliance (“DAA“).  To implement your opt-out choices under the NAI and DAA programs, please visit the NAI Opt Out Page and the DAA Opt Out Page.

  • Authenticated IP Address Audiences. Review your cable/internet service provider’s privacy policies to learn how to opt out of IP address-based targeted advertising.

If you have questions about our collection and use of data for interest-based advertising purposes, or if you would like to revoke an opt-in consent you gave us, please contact us at: Privacy@Optimum.Media. 

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4.  General Provisions Applicable to Clients, Users, and Visitors

4.1  Third-Party Links

Our Sites and Services may contain links to our third-party partners’ websites.  Any access to and use of such linked websites is not governed by this Privacy Policy but instead is governed by the privacy policies of those third-party websites.  We are not responsible for the information security nor privacy practices of such third-party websites.

4.2  How Long We Will Keep Information

We may retain Client Information, User Information, and Visitor Information for as long as is reasonable for the purposes for which it was collected, unless a longer retention period is required or permitted by law.

4.3  No Re-Identification

As discussed herein, we take steps to de-identify or pseudonymize data we ingest into our systems.  To the extent we collect de-identified data, we do not attempt to re-identify such data.  We contractually require our partners with whom we share this information to do the same.

4.4  Rights of California Residents

The California Consumer Privacy Act, as augmented and amended by the California Privacy Rights Act, California Civil Code Section 1798.100 et seq. (the “CCPA”), applies to the collection, use, and disclosure of personal information collected from California residents (“California PII”), as those terms are defined by the CCPA. 

California PII is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or households, and excludes information that has been de-identified and/or is publicly available, among other things.  As described herein, we take steps to ensure that we do not collect, sell or share California PII of California Consumers. 

Individuals who reside in California and who believe that they may have provided their California PII to the Sites may request information regarding disclosures of this information to third parties for direct marketing purposes.  You have the right to access, correct, or delete your California PII. 

Such requests may be submitted to us at the following address or at  Privacy@Optimum.Media:

Optimum Media, LLC
Attn: Privacy Policy Inquiries
One Court Square, 47th Floor
Long Island City, NY 11120

Such requests may be made only once each calendar year.  We may not respond to requests sent to addresses other than those shown above.

If an authorized agent submits a request on your behalf, we may require that the authorized agent provide written proof of their authority and we may separately verify your identity and confirm your request with you. 

If you have any questions about your rights or our disclosures, please contact our privacy officer per the details listed in the section titled “Contact Us” below. We will never discriminate against you because you have exercised these rights.

4.5  Rights of Consumers in Other U.S. States. 

As explained above, we work with our Affiliate to ensure that we do not have personal information that is reasonably linkable or linkable to any consumer. We may not be able to verify your identity to process your request.

Depending on the rights extended by your state, you may have the right to:

·         Confirm whether or not we are processing your personal information;

·         Access your personal information;

·         Correct inaccuracies in your personal information and the purposes for which we are processing it;

·         Delete your personal information; and/or

·         Obtain a copy of personal information you have previously provided to us.

We will never discriminate against you because you have exercised these rights. You can email us at  Privacy@Optimum.Media to exercise these rights. 

4.6  Notice to Visitors From Outside the U.S.

We do not knowingly collect personal information or other data from individuals outside of the United States.  The Sites are published in the United States. By visiting any of our Sites, by using services offered through the Site or by providing personal information to us or to our service providers, you agree that we may collect, use, and disclose your information as described in this Privacy Policy, including by transferring such information from the country where you live to the United States.

4.7  How We Protect Children’s Online Privacy

We do not direct our Sites or Services to children under the age of 17.  We do not knowingly collect personal information from children under the age of 17.  If we become aware that we have received personal information of a child under 17, we will delete the information from our records.

4.8  Changes to this Privacy Policy

We may change this Privacy Policy at any time.  We will notify you of material changes by posting the revised Privacy Policy on the Websites. We encourage you to periodically review the Privacy Policy to inform yourself of any changes.  The revised Privacy Policy will be effective on the date it is posted unless it states otherwise.  If you use the Sites after the effective date of the revised Privacy Policy, we will conclude that you accept the revised Privacy Policy.

4.9  Questions about this Privacy Policy

Please contact us if you have any questions about this Privacy Policy:

Optimum Media, LLC
Attn: Privacy Policy Inquiries
One Court Square, 47th Floor
Long Island City, NY 11120

 Privacy@Optimum.Media

 

Last updated June 26, 2024

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