Privacy Policy

H Code Media, Inc. (“H Code Media”) is a technology-enabled media services company whose clients and customers include both online advertisers (“Advertisers”) and digital content providers (“Digital Content Providers”). We deliver innovative products and services designed to:

  • enable Advertisers to better reach their target audiences; and
  • enable Digital Content Providers to support, grow and monetize their properties through the sale of advertisements.

Our product offerings and services allow digital advertisers to more efficiently reach their desired audience (together, referred to herein as our “Services”). For a full description of these Services please see our website at www.hcodemedia.com.

 

At H Code Media we believe that safe, secure and respectful practices regarding the use of consumer information are fundamental to our business success and to the growth and vitality of the Internet as a whole.

 

This Privacy Policy is intended to provide consumers with clear and complete information about the consumer data we collect in connection with our Services and the way that data is stored and used by our company, our clients and partners.

 

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY USING H CODE MEDIA’S SERVICE, VISITING THE DIGITAL CONTENT PROVIDERS’S WEBSITES AND APPLICATIONS OR OUR WEBSITE, INTERACTING WITH AN ADVERTISEMENT, OR DOWNLOADING AN APPLICATION YOU ACCEPT THIS PRIVACY POLICY. IF YOU DO NOT ACCEPT, PLEASE DO NOT USE OUR SERVICE, VISIT A DIGITAL CONTENT PROVIDER OR APPLICATION, OR INTERACT WITH ANY ADVERTISEMENT.

 

Information We Collect and How We Use It

H Code Media may use data collected across different Web sites and downloadable applications over time to make inferences about the preferences of users of those Web sites and downloadable applications in order to provide advertising or content relevant to those inferred preferences. This form of advertising is known as interest-based advertising (“IBA”). H Code Media also delivers advertising relevant to the content of web pages or applications also known as contextual advertising. In connection with Services, H Code Media and our third-party partners may gather information including location, gender or other demographic information or based upon ads or other content you have viewed in the past. H Code Media may also collect information about your visits to Web sites and downloadable applications, such as number of times you have viewed an ad and where geographically the ad is served (but not your name, address, or other personal information).

 

We may use also this information for non-targeting reasons such as frequency capping, compliance, fraud prevention, billing, service fulfilment, ad reporting or delivery, market research or product development within industry standards such as the NAI/DAA.

 

Non-Personal Information Collected by our Services

Non-PII collected by H Code Media may include download history, geographic location, demographic information, customer generated content and/or information about your interests in and use of various products; programs, and services; the web pages or sites visited, interactions with ads; and identifiers associated with a mobile device or tablet, or your use of an application. We may gather this information via cookies, statistical identifiers and similar functioning technology as well as when you download an application, access our website via an ISP, wifi or carrier network.

 

Geographic Location Information.  H Code Media may from time to time ask you to provide geographic location information. By voluntarily providing such information, you consent to its use in interactive forums, polls and elsewhere. Additionally, H Code Media may obtain geographic location information via programming interfaces supplied by your mobile device service provider or from IP lookup services. Such information may also be used for targeted advertising purposes.

 

Personally Identifiable Information

Personally Identifiable Information (“PII”). The types of PII that H Code Media may collect include without limitation: name, address, e-mail address, and mobile phone number. We may combine PII and other information (e.g., demographic information like gender and age) about you that we have with information we obtain from our business partners or third party data providers. We may collect PII when you register with H Code Media, when you enter a sweepstakes, voluntarily provide such information, or by other customary means.

 

Cookies & Server Log Files

Like most websites, we may use cookies and other technologies as well as server log files. We may use cookies and other technologies in a number of ways, including keeping track of user return visits to the Digital Content Providers or our advertisers’ or business partners’ websites; accumulating and reporting aggregate; statistical information in connection with user visits; and to deliver to our users content and advertising specific to their interests; to save Users ID, passwords, subscriber I.D. and international mobile equipment identity number (“IMEI”) or other information. Advertisements displayed on Digital Content Providers, and links to other websites may also contain cookies.

 

Cookies, by themselves, do not tell us your e-mail address or other PII unless you choose to provide this information to us by, for example, registering for a service.

 

You may adjust your browser to reject or block cookies. Please consult the “Help” section of your browser for more information. However, certain areas of our site can be accessed only in conjunction with cookies or similar devices and you should be aware that disabling cookies or similar devices might prevent you from accessing some of our content. Please note that blocking cookies will not prevent advertising from being displayed in your browser or apps, but it may make such advertising less relevant to you.

 

Server log files contain information such as Internet Protocol (IP) addresses, browser types, Internet Service Provider (ISP), referring/exit pages, platform types, date/time stamps, the number of clicks to analyze trends, administer the site, track the user’s movement in the aggregate, and gather demographic information for aggregate use, such as device type, carrier, subscriber I.D. and the IMEI. We may collect certain non-PII when you complete a transaction, use our services, download our applications or visit many of our web pages or those of certain business partners.

 

Information Sharing

H Code Media may share non-PII obtained via performance of Services:

  • With service providers or other companies to perform some operation or function on behalf of H Code Media;
  • For content delivery and advertising purposes, including but not limited to IBA;
  • With other parties as aggregated, user statistics;
  • If required to do so by law or we believe that such action is necessary to comply with a legal process served on H Code Media or its affiliates, subsidiaries or affiliate by a governmental agency, court or other entity (e.g., to respond to subpoenas, court orders or other legal process);
  • If we believe a user’s actions violate any law, regulation, our “Terms of Service” or any of our guidelines for promotions, product offerings or any other features of H Code Media, or if a user threatens the rights, property or safety of H Code Media, its advertisers, other users, themselves or any other party;
  • As and when we, in our sole discretion believe that such disclosure is necessary or appropriate to investigate or resolve possible problems or inquiries, to protect our business and assets, to defend our interests, rights or property and/or to comply with our legal and regulatory obligations; or
  • In the event of a bankruptcy, or a merger, acquisition, joint venture or other business combination involving H Code Media.

You may also opt out of H Code Media’s collection of data from applications through your device settings. For some version iOS, you may limit “ad tracking” in the Settings menu on your device. For some versions of Android, you may opt out of collection of data for IBA by selecting the “Opt out of interest-based advertising” in the Settings menu.

 

Exclusions. Our privacy policy does not cover use of information by your mobile device service provider or its partner and subcontractor companies.

 

International Users. Please be advised that because we operate internationally, and certain of our computer systems are currently based in the United States, your personal data may be processed by us in the U.S. where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union.

 

Children and Age Restrictions. Children under age 13 are not permitted to register for the services. H Code Media does not knowingly collect personal information from children under the age of 13.

 

Your Privacy Rights and Rights to Opt Out.

Users can prevent future disclosures by H Code Media of their PII, at no charge, by exercising their “opt out” rights using the “opt out” procedures described below:

  • You can send email to: privacy@hcodemedia.com.
  • You can send mail to the following postal address:
    • H Code Media
    • 312 Arizona Ave, 2nd Floor
    • Santa Monica, CA 90401
    • Attn: Legal
  • If you prefer not to see targeted ads via IBA from our platform, you may visit our data management platform, Krux’s, opt-out page: http://www.krux.com/privacy/consumer-choice/ and click Opt Out at the bottom of the page. We will no longer deliver ads targeted to your preferences and usage patterns.

H Code Media follows generally accepted industry standards to protect against unauthorized access to, destruction or disclosure of data. This includes undertaking physical, electronic and management activities to protect data integrity, access and use. Any data that is stored on our servers is treated as confidential and is not made generally available to the public.

Our servers are protected by firewalls and are located in secure data facilities to further increase security. Please keep in mind, however, that despite these reasonable efforts to protect data on our servers no method of transmission over the Internet is guaranteed to be secure. Therefore, while we strive to protect your personal data at all times, we cannot guarantee its absolute security and shall not be liable for any breach of security by an outside party.

 

Transfer of Data Upon Change of Control

In the event that another company acquires all or substantially all of the assets of our business through a consolidation, merger, asset purchase or other transaction, we reserve the right to transfer all data that is in our possession or under our control to such acquiring party.

 

Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy by posting an updated version on this page. The date on which the current Privacy Policy was posted will always be noted at the bottom of this page. Any change we make to our Privacy Policy will be made in compliance with applicable law.

 

Correspondence

If you contact us, we may keep a record of that correspondence, including your email address. This relates to your correspondence with us only – we do not gather users’ email addresses as part of our online advertising business.

 

If you feel we are breaching privacy principles, you should contact us at privacy@hcodemedia.com.

 

Questions and Comments

Questions and comments regarding this Privacy Policy should be directed to privacy@hcodemedia.com

 

Effective Date. This notice was updated on or about 6/1/16