Unruly Group Limited, and its affiliates including but not limited to Unruly Media Inc., Unruly Media Limited, Unruly Media SARL, Unruly Media GmBH and Unruly Media AB, Unruly Media AS, Unruly Media Pte Ltd will be referred to herein, both individually and collectively, as “Unruly Media,” “we,” “us,” and “our.”
Unruly Media serves and distributes video and non-video content online. Our clients are mostly advertisers that ask us to display their content through banners and other advertising units on web sites that participate in our network of publisher sites. On rare occasions, we also serve and distribute non-advertising content for third party content providers for which we are not paid.
By using any Unruly Media Site, you are consenting to the transfer of your personal data to countries outside the EEA. This is explained in more detail below.
By using any Unruly Media Site, you are consenting to the placing of cookies and other telecommunications tools on your devices which allow Unruly Media to collect certain information. We provide more detail on this below.
If you have any queries about how we collect or use your personal data, please contact us at email@example.com
Technologies Used by Unruly Media to Collect Information
Unruly Media reserves the right to use one or more varieties of technologies to collect information at Participant Sites and Unruly Media Sites. These are listed and described below.
Pixels. A tracking “pixel” is a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a web page and allows for the collection of information regarding the use of the web page that contains the tracking pixel. Unruly Media collects technical and usage information (see below) through the use of tracking pixels.
Clients. Some advertisers or other clients (and their third-party service or technology providers) may use pixels, cookies, flash cookies, web beacons and/or similar technologies which are activated when their Distributed Content is viewed by users across our network of Participant Sites or at Unruly Media Sites. We may request and receive aggregate, non-personal information from our clients from time to time but we do not actively seek from our clients (or their service providers) any information about any individual users.
Opt-Out. Unruly Media is a member of the Digital Advertising Alliance (DAA), a cooperative of companies committed to building responsible advertising policies across the Internet, and adheres to the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. Our opt-out tool can be found here. To learn more about interest based or online behavioral advertising, and other advertising companies’ privacy practices and opt-out from each or any of them (including Unruly Media), you may also go directly to the DAA website at http://www.aboutads.info/choices/.
Information collection on participant sites
When you visit a participant site in our advertising network and view distributed content placed by us, we collect information about your activities as follows:
Technical Information. When we serve distributed content, we log and analyze technical information that is openly available to our servers such as information about the kind of browser being used (e.g., Safari, Internet Explorer), the type of operating system it’s running on (e.g., Windows, Mac OS, mobile OSes), the speed and type of Internet connection (e.g., narrowband, broadband, mobile), and other technical information. This information is anonymous and generally non-personally identifiable but does include “internet protocol addresses” or “IP addresses” which can be used to identify a user and may be considered to be “personally identifiable information” (see below). Unruly Media archives all technical information (including any such IP addresses) in raw log format.
IP Addresses: Unruly Media analyzes “internet protocol addresses” or “IP addresses” in order to determine an approximate geographic location so that we can serve a client’s Distributed Content that is more relevant to that location and/or perform other analyses based on information that may be collected about the history of interactions with our video player (see below) or clients’ Distributed Content that are common to any single or range of IP addresses. We may also collect or use IP address information for fraud detection or prevention. We archive IP address data as part of the raw log files of technical information maintained by our systems (see above). Unless you use a static IP address, an IP address typically relates to multiple businesses, households or larger communities. For example, if you use an Internet Service Provider (ISP) to access the Internet, your IP address may be assigned from a range of IP addresses. Unruly Media has no influence or control over how any IP address is assigned. An assigned IP address may also change from time to time within that range of IP addresses. While not impossible, especially if a user has been assigned an IP address permanently or for a period of time, it is difficult to identify an individual user based on an IP address and we do not actively associate IP addresses with any other information in order to identify any individual user on a personally identifiable basis.
Interaction with Video Player and Other Usage Information. Unruly Media uses a proprietary video player to serve our clients’ Distributed Content. This video player can be hosted on a web page, be featured as part of an application or widget, or be embedded within an advertising unit. Unruly Media collects data about a user’s interactions with the player, such as what Distributed Content has been featured, played or clicked, whether playback is paused or stopped, and information collected in relation to the serving and display of Distributed Content, etc. Additionally, we may also collect information about the pages you visited at a Participant Site if our video player or Distributed Content are present on the pages, including what site or page you came from, how long you spent on the page, your click activity on the page, etc. The usage and interaction data helps us understand and report to our clients about whether and how often an item of Distributed Content is watched, whether partially or fully, and in what context, by users across our network of Participant Sites. It may also be used to target or re-target relevant advertising or other content to you through involvement of contracted third parties and/or on other sites you visit. Unruly Media may also use this information to determine what Distributed Content to show in the video player by matching usage with historical data that Unruly Media may have collected and stored using cookie or other technology. (See above section entitled “Third party suppliers or services”).
Unruly Media uses the information it collects to operate and improve the functionality, presentation, distribution and appeal of the Distributed Content we place for our clients on Unruly Media’s network of Participant Sites. On occasion, this involves sharing raw logs with a client if we ascertain that the information being shared is the same information that such advertising or publisher client was in a position to have collected themselves. The information may also be used to improve the relevance of the Distributed Content served to you and other users visiting a Participant Site. We also use and share aggregated technical and usage data with our publishers and advertisers in order to provide measurement and analytics on the effectiveness of their ad campaigns and content distribution programs, and to conduct research and analysis, including to test different ways, to improve the experience of users who encounter our clients’ Distributed Content on our network of Participant Sites.
Unruly Media uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of the information it collects. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to protect our clients’ and users’ information, please be advised that Unruly Media assumes no responsibility or liability for disclosure of your information due to errors in transmission, unauthorized third-party access or other causes beyond Unruly Media’s reasonable control.
Personal Data Collection on Unruly Media Sites
Personal Data is collected on the Unruly Media Sites in various instances including, without limitation:
Registration and Use of Unruly Media’s Services. If you register to participate in the Unruly Media network as a publisher or an advertiser, we will require you to provide, and we will store, information that identifies you personally such as your name, contact information, and payment method. We use this information for business purposes such as account maintenance, billing, and to operate and provide the Unruly Media services.
Requested information. If you submit an inquiry to or respond to a request by Unruly Media through any “Request a Proposal,” “General Enquiry,” “Credit Account Application Form” or similar function on an Unruly Media Site, any information you provide, including any contact name, address, email address, telephone number, financial information, etc., will be used by Unruly Media in order to respond to such inquiry or request and may be archived by us indefinitely for future reference.
Comment on blog posting. If you post a comment in an area where comments can be posted on an Unruly Media Site, you may be electing or be required to submit your name and email address in connection with the posting.
Subscriptions. You may provide an email address or other contact information or otherwise interact with our Unruly Media Sites in order to commence receiving a subscription-based function or service, such as a newsletter or mailing.
Social Media, etc. You may provide an email address or other unique identifier or be requested to provide log-in information in order to use a social media or sharing feature. Where the feature is branded according to a branded social network or social media service, then Unruly Media could, in fact, not be provided visibility or access to such log-in or other identifier you use, and thus we shall have no responsibility over the privacy and use of such log-in information or the use, storage or disclosure of any information about you by such service.
Access to web-based client interface or console. A current client in good standing may be required to provide his or her user name and password, which may include or feature personally-identifiable information, in order to access the console, account areas and/or other areas that are accessible only by clients. We use user IDs and passwords, in part, to protect your privacy and security. You are responsible for maintaining the secrecy of your unique password and account information at all times.
You may, of course, decline to share any or certain items of personally-identifiable information with Unruly Media, in which case we may be unable to provide you with the services or pay you any monies that might otherwise be payable to you. Unruly Media archives any and all information, including personally identifiable information, that may be input in any registration process even if the user refuses or is declined or fails to use or abandons the services provided by Unruly Media.
Note about Childrens’ Privacy: Unruly Media is very sensitive to the issue of children’s privacy. Our websites, products, and services are neither developed for, nor directed at, children, and we do not knowingly collect personal information about children under 13. If you believe your child has provided Unruly Media with personally identifiable data by registering or using any offerings at any of our Unruly Media Sites (i.e., sites owned and operated by Unruly Media, as opposed to a Participant Site over which we have no control), and you would like to have us look into removing the data from our servers, please contact us at firstname.lastname@example.org
Where Unruly Media stores Personal Data
If you are using an Unruly Media Site and providing personal data to Unruly Media you are consenting to the transfer of this data to a destination outside the EEA.
Use of Information that Clients Provide
Unruly Media uses the personal data you provide to respond to your inquiries and requests, and to keep accurate records concerning the services you are requesting through any Unruly Media Site. We generally use non-personally identifiable information in aggregated form to help measure the performance and effectiveness of our Unruly Media Sites, and to improve their usefulness. Additionally, you should be aware of the following:
Unruly Media does not share personally-identifiable information of any clients with other organizations for their marketing or promotional uses without your express consent. From time to time, we may use this information to send you samples or other promotions that Unruly Media decides may be of interest to you. To provide web site hosting, maintenance and security, fulfill orders, offer certain functionality, improve our site, and create new site features, we may disclose one or more clients’ information to affiliated companies or other businesses or persons, such as, for example, credit card service providers or cloud or data storage providers. Any personally identifiable information a client provides may be associated with technical and usage information that may be collected at Unruly Media Sites in same manner as we may collect such information at Participant Sites (see above). We may also combine it with information collected from other sources, particularly in cases where we and our third party partners or contractors may be vetting or investigating a new, existing or prospective client for potential of fraud or other undesirable activities.
Other Information Sharing
Unruly Media may disclose one or more clients’ and/or individual users’ information if required to do so by law (or in a good-faith belief that such action is necessary or advisable in order to comply with any laws of any country or region which may assert jurisdiction) or in order to respond to a judicial or other governmental action, order, subpoena, request, demand or warrant. We may make such disclosures without providing notice to you.
Unruly Media also reserves the right to disclose one or more clients’ and/or individual users’ information if it is appropriate or necessary in Unruly Media’s discretion in order to: take precautions against liability; protect against fraudulent, abusive, or unlawful uses; investigate or defend against any third-party actions or allegations (including assisting a client or third party to do so); assist government enforcement agencies; or protect the security, integrity, rights, property, or personal safety of Unruly Media, its systems and services, as well as its employees, clients or others. Unruly Media may in the future, and shall have the right to implement technology to, collect or share any information, including any client’s or individual user’s information, that we determine to be necessary or advisable in order to comply with a judicial order or to cooperate with government and law enforcement officials.
There is the possibility that Unruly Media, or parts of the company or its affiliates, may one day be purchased by, or merged with, another company or otherwise disclosed or transferred as part of a merger, acquisition, debt financing or sale of assets, including in the event of an insolvency, bankruptcy or receivership. In that the case, the acquiring (or merging) company will have access to your information.
Changes to this Policy
Questions, concerns and comments
In the United Kingdom:
Unruly Group Limited, 42-46 Princelet Street, London, E1 5LP, United Kingdom
Unruly Media SARL, 44 Rue La Fayette, 75009 Paris, France
Unruly Media GmBH, Großer Burstah 36-38, D·20457 Hamburg
Unruly Media AB, Brunogallerian, Götgatan 36, 118 46 Stockholm, Sweden
Unruly Media AS, Fredensborgveien 24D, Oslo, Norway
In the United States and Canada:
Unruly Media Inc, 41 West 25th Street, 4th Floor, New York, NY 10010, USA
Unruly Media Pte Ltd, 18A Gemmill Lane, Singapore 069255, Singapore
Unruly Group Limited, 42-46 Princelet Street, London, E1 5LP, United Kingdom