Frequence Privacy Policy

Updated and last reviewed as of: August 2, 2023

Frequence, Inc. operates an online media buying service and workflow technology that (a) targets and delivers advertising campaigns over the Internet to advertising placements displayed on various media (for example, websites and mobile applications), then measures the performance of these advertising campaigns and provides reporting information to the media buying clients and their advertisers, and (b) provides creative design services for creating customized advertisements that include rich-media features such as video and interactivity. Our services are available to our users subject to this privacy policy and ourTerms of Use.

California, Virginia, Colorado, Connecticut, and Utah Users:

If you are a resident of California, Virginia, Colorado, Connecticut, or Utah, see the Additional US Notice for additional information about our data practices and your rights.

Canadian Users:

If you are a resident of Canada, see the Additional Canada Notice for additional information about our data practices and your rights.

California Employees, Job Applicants, Owners, Directors, Officers, and Contractors:

If you are a resident of California and you are an employee, job applicant, controlling owner, director, officer, independent contractor, or medical staff of ours, see the Privacy Notice for California Company Workforce.

WHAT IS THE SCOPE OF THIS PRIVACY POLICY?

This privacy policy applies to your personal information that we may collect or receive:

directly from you on www.frequence.com, our user interfaces and mobile applications (the “Frequence Properties”) (for example, when you fill out your contact information on the “Contact” page of our site or when you register to use our platform on behalf of a client or advertiser of Frequence in our user interface),
directly from you when you send electronic messages to us (e.g., emails) or when you otherwise communicate with us,
from our media buying clients,
through our platform that is used by our media buying clients and their advertisers, and third parties that we use to provide services on our behalf,
through our platform when we use tracking technology on our media buying clients’ advertisers’ websites, and
when you use our social media pages such as Twitter and LinkedIn (all of the services above, including the platform and the Frequence Properties, are defined as the “Services”).

‍User Consent: By accessing or using our Services, you represent that you are at least 18 years old and you consent to our data practices as described in this privacy policy.

This privacy policy describes how we may collect, use, and disclose your personal information, as well as options available to you and your rights. If you do not want information about you to be used in the manner described in this privacy policy, please do not use the Service.

This privacy policy does not cover and we are not responsible for the privacy, data or other practices of any of our media buying customers and their advertiser clients or any other third parties (except as required by applicable law). See Third Parties below for more information.

CHOICE AND RIGHTS

See How to Opt-Out and Your Choices for information about opting out of certain data practices and see User Rights for information about exercising your rights as a user.

CHANGES TO OUR PRIVACY POLICY

We may change this policy at any time. Any changes will be updated directly on this page. We encourage you to visit this page periodically to review our current privacy policy. Where required by law, we will notify you or obtain your consent to make these changes. Your continued use of or access to the Service constitutes your agreement to this privacy policy and any updates.

CONTACTING US

If there are any questions regarding this privacy policy you may contact us using the information below.

155 E Dana Street
Mountain View, California 94041
‍privacy@frequence.com

Privacy Officer—Canada:
Privacy Officer
privacyofficer@frequence.com

Frequence, Inc.
Attn: Privacy Officer
155 E Dana Street
Mountain View, California 94041

UNITED STATES AND CANADIAN USERS ONLY

Our Services (including our website) are intended for individuals located in the United States and Canada only. You are not authorized to use the Service (including our website) if you are located outside the United States and Canada.

INTERNATIONAL DATA TRANSFERS

We are based in the United States and any information collected through the Services may be stored and processed in the United States and India. If you are located outside the United States, you understand that in using the Services (including our website) your personal information will be transferred to, stored, and processed in the United States and India and other countries where we and our service providers and third party partners operate. These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective. This serves as notification to you of the cross-border transfer of data.

Your consent to this privacy policy represents your consent to such transfer, storage, and processing outside of your country of residence, which countries may have different data protection rules than those of your country of residence.

PERSONAL INFORMATION

Personal information, when used in this privacy policy, means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual or household. It does not include de-identified information that is maintained in a form that is not capable of being associated with or reasonably linked to an individual.

WHAT INFORMATION DO WE COLLECT?

Information Provided Directly by You. When you register and log in to the Frequence Property, you provide your name, email address and if on our website, also your telephone number. When you apply for a job via our Careers page, you provide your name, email address, telephone number, physical address, social media account information and other job-related information. You also provide us information when you send us emails, and other electronic messages through our Services. You may also provide information to us in your capacity as a business professional (e.g., an employee of one of our media buying customers, business partners, or vendors).
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Every time you enter information into a web form or other data field available on the Services or you send us an electronic message, we collect and store that information for our business use. Please do not include any sensitive information in these forms and fields.

Some of the information you provide is optional. However, if you decide not to provide certain information, you may not be able to access the information you had requested to access or use, or you may not be able to use part or any of the Services.

Automatically Collected Information.
‍When you access our Frequence Properties or platform, open one of our HTML emails, interact with advertisements served by us, or interact with our social media pages, then we may collect certain information automatically from your browser, mobile device or identifier, IP address, cookie or email. The technologies we may use for this collection include pixels, web beacons and cookies. See How do we use Cookies and other Similar Technologies below. This automatically collected information may include the following:

cookie identifiers, including our media buying customers’ unique cookie identifiers and Frequence’s ad server cookie identifier,
location data derived from IP address or as supplied by publishers (for example, owners or operators of websites and mobile applications that you access may provide your location data),
IP address (Internet Protocol address),
device information such as mobile device identifier, mobile device type, and operating system,
browser information such as browser type and browsing information such as the web pages visited, the site that you visited just before visiting our site, the date and time that you used the site, and the date and time an advertisement was shown to you, and
information about your interactions with our emails such as clicking on links and date and time viewed.

When you access the websites and mobile applications of our media buying clients’ advertisers, we also use a retargeting and performance reporting tracking pixel on your computer or other device.

We also allow analytics companies to use tracking technologies to collect information automatically about the computers and mobile devices of our users. We have enabled restricted processing for Google Analytics and limited data use for Facebook Pixel so that Google and Facebook Pixel may only use your information as our service provider when you use our website.

Information Provided by Media Buying Customers. Our media buying customers may provide us with additional information about you. For example, a media buying customer may provide us with a list of their customers identified by IP address, mobile device IDs, or third party cookie ID. Through our media buying customers’ user IDs, we have access to additional information about such users, including demographic information and web browsing history.

Information from Interactions with our Ads. We advertise our Services on other websites and applications. When you interact with our advertisements (for example, you view or click on one of our ads), we receive information about that interaction to help us provide our Services to you.

Information Collected When You Log in with Single Sign-On. You may be given the option to access or register for the Service through the use of a single sign-on feature provided by a third party. By authorizing us to connect with these third parties, you authorize us to access and store the information that these third parties make available to us, and to use and disclose any such information in accordance with this privacy policy. You should check your privacy settings in these third party accounts to understand and change the information that they can send to us.

Information from Other Sources. We may also receive data from other sources. For example, we may buy access to certain data (such as gender, military status, job type or profession, and whether you are in the market for buying a product or service) which we may be able to associate with an IP address or user ID.

If we combine or associate non-personal information with personal information, we will treat the combined information as personal information in accordance with this privacy policy.

WHAT ARE OUR USES OF YOUR INFORMATION?

Frequence uses your personal information for the following business purposes:
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Providing and Improving the Service. We use the information to provide and improve our Service, including serving advertisements, providing technology that allows our media buying customers to manage advertising campaigns, facilitating navigation on the Service, ensuring our technologies are functioning property, personalizing the user experience while using our Service, analyzing advertising and website performance and campaigns, personalizing communications with you, and developing new services.

Personalizing Ads. We use information (for example, previous websites visited and location) to allow our media buying customers and their advertisers to deliver advertisements that they believe may be of interest to you. We attempt to restrict the activities of all of our service providers by selecting restricted or limited data processing so that these companies cannot send targeted advertising to you. See How do we use Cookies and other Similar Technologies?

Marketing the Service. Where permitted by applicable law, the Company may use your email address or other personal contact information to send you marketing messages relating to the Service, which you can opt-out of. We also use your information to monitor the effectiveness of these marketing campaigns.

Detecting Fraud. We use IP addresses and browser cookies to detect suspicious patterns which may represent advertising fraud. We may also use the information to identify invalid advertising impressions and queries. We also use the last logged IP address to detect fraud.Exploring a Combination. We may use the information as part of exploring a potential merger, acquisition, debt financing, or sale of our assets, as well as in the event of an insolvency, bankruptcy or receivership.

Exploring a Combination. We may use the inforamtion as part of exploring a potential merger, acquisition, debt financing, or sale of our assets, as well as in the event of an insolvency, bankruptcy or receivership.
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Legal and Other Uses. We may use your information if we believe it is required or appropriate: (a) to prevent or stop activity that we may think is, or is at risk of being, illegal, unethical or legally actionable activity; (b) to protect our rights, privacy, safety or property, and that of you and others; (c) to protect our operations and the security of our Services; (d) under applicable law; (e) to comply with legal process and our legal obligations; (f) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (g) to enforce our terms and conditions; and (h) to allow us to pursue available remedies or limit potential damages.

With Consent. We may also use your personal information in other ways with your consent or at your direction.

WHO DO WE DISCLOSE YOUR INFORMATION TO?

Frequence may disclose your personal information to:

Our affiliates. We may disclose your information to our affiliates (for example, subsidiaries) for the purposes described in this privacy policy.
Our service providers. We may disclose your information with our third-party service providers who perform functions required for the operation of our business. Examples include, to provide data storage and processing services, hosting services, campaign management, email management, engineering services, marketing services, technical support, and fraud detection and prevention. We provide our service providers with only the information necessary for them to perform the services we request, and we ask our service providers not to use such information for any purpose other than as specified by us.
A buyer of our business. We may disclose your information to a third party as part of a merger, acquisition, debt financing, or sale of our assets, as well as in the event of an insolvency, bankruptcy or receivership.
The public voluntarily by you. Individuals may choose to disclose information on message boards, chat, profile pages and blogs and other services that allow visitors to post information and materials. Please note that any information posted or disclosed through these services and forums will become public information, and may be available to users of the Frequence Properties and to the general public. We urge you to be very careful when deciding to disclose your personal information, or any other information, on the Frequence Properties.
Legal and Other Disclosures. We may also disclose your information if we believe it is required or appropriate: (a) to prevent or stop activity that we may think is, or is at risk of being, illegal, unethical or legally actionable activity; (b) to protect our rights, privacy, safety or property, and that of you and others; (c) to protect our operations and the security of our Services; (d) under applicable law; (e) to comply with legal process and our legal obligations; (f) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (g) to enforce our terms and conditions; and (h) to allow us to pursue available remedies or limit potential damages.
With Consent. We may also disclose your personal information in other ways with your consent or at your direction.

HOW DO WE USE COOKIES AND OTHER SIMILAR TECHNOLOGIES?

If you would like to change your cookie settings with us at any time (e.g., decline cookies), please see the Cookie Settings link on the bottom left side of the footer on www.frequence.com.

We use cookies in connection with our Services. A cookie is a small data file that is stored on your computer’s or mobile device’s memory. Some cookies help you navigate our Frequence Properties, including setting a cookie to remember your login details when you log in to our user interface. Cookies also collect information about how you use our Frequence Properties, which allows us to monitor website performance and identify ways to make the website easier to use and more effective. We also use an interest-based retargeting cookie which allows us to send you advertising about Frequence’s products and services after you leave the Frequence Properties and visit other websites. We may also work with service providers who place cookies on users of the Frequence Properties for the purpose of finding audiences who may not currently be users of the Frequence Properties or Services. These service providers drop cookies and identify the places of business where such cookies originated from. We then display advertising on other websites (such as LinkedIn) about Frequence’s products and services and display those advertisements to users whose places of business are from the same identified places of business. In addition, we help our media buying customers place cookies on visitors of their customers’ websites to serve interest-based advertisements to such visitors when they visit other websites and mobile applications. Our media buying customers’ customers may also place our cookie on those same users to analyze the effectiveness of our Services (for example, by tracking the way in which you respond to, select, and interact with our media buying customers’ and their customers’ advertisements to help us measure the success of advertising campaigns). The collection of information through cookies or similar technologies by our media buying customers and their customers is governed by such businesses’ own privacy policies, which Frequence does not control.

If you submit an inquiry through the Frequence Properties (e.g., by filling out a web form on the “Contact” page) and provide your name and email and similar information, that personal information will not be tied back to you for interest-based advertising purposes across websites and applications, however, you may receive email marketing communications from us. To opt out of marketing communications see How to Opt- Out and your Choices. We and our service providers may also use “pixel tags,” “web beacons”, “clear GIFs” or similar means to analyze usage patterns of users. These technologies are electronic images that are placed on a web page or in a mobile application and may be associated with cookies on your hard drive. Some of these technologies are used to drop cookies on users’ devices. These technologies allow us to count users who have visited certain websites and applications of our media buying customers and their customers, and pages within such websites and applications, and to help determine the effectiveness of advertising campaigns. Some pixels are used by third parties for interest-based advertising.

We may place the “Facebook Pixel” of the social network Facebook on our media buying customers’ and their customers’ websites. The Facebook Pixel allows our media buying customers and their customers to deliver targeted advertising to their users. The Facebook Pixel also allows Facebook to collect data of users and retarget those users with interest-based advertising when those users visit Facebook properties. If we use the Facebook Pixel, we will enable limited data use so that Facebook may only use your information as our service provider. The Facebook Pixel allows us and Facebook to determine whether advertisements were effective and satisfactory for users by being able to comprehend users’ actions before and after they were on a website. Facebook may connect the data with your user profile within its network. We do not control and we are not responsible for the Facebook Pixel or any of Facebook’s tracking technologies or how they may be used. If you have any questions about the privacy and data practices of Facebook, you should contact Facebook directly.

Other third parties (for example, Google Analytics) may use cookies or similar technologies on visitors of our Frequence Properties to provide us with analytical information regarding the Frequence Properties. We attempt to restrict the activities of all of these service providers by selecting restricted or limited data processing so that these companies cannot send targeted advertising to you. The collection of information through cookies or similar technologies by such third parties is governed by such third parties’ own privacy policies and principles, which Frequence does not control. We have enabled restricted processing for Google Analytics so that Google may only use your information as our service provider.

‍Managing Cookie Preferences
For more information about cookies, including how to see what cookies have been set on your device and how to delete them, visit www.allaboutcookies.org.

To read about how to manage your cookie preferences (including information about our Cookie Settings solution which allows you to decline cookies), see How to Opt-Out and Your Choices.

HOW TO OPT-OUT YOU CHOICES

Opting Out of Marketing from Frequence

You may opt-out from receiving electronic marketing communications from us (or opt in, if required by applicable law). If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing related emails by contacting us at privacy@frequence.com or by clicking on the opt-out link within the email message that you receive from us.

Please also note that if you do opt-out of receiving marketing-related emails from us, we may still be required to send you administrative messages relating to the Services from time to time.

Managing Website Cookie Preferences
You can manage the use of cookies on our website by clicking the Cookie Settings link in the footer of every page of our website. These Cookie Settings allow you to withdraw your consent to placing cookies at any time. When you “decline” cookies the only cookie we drop is the cookie that is necessary to honor your preference.
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Opting Out of Frequence’s Cookies Generally
In addition to declining cookies through our Cookie Settings (see above), you may also disable cookies, including all of our cookies, by modifying the settings in your browser. However, please note that certain features of the Frequence Properties may not work if you delete or disable cookies. Also, if you delete all cookies after previously “declining” all cookies (see above) or opting out of third parties’ interest-based advertising cookies (see below), you will need to renew your preference to “decline” cookies and your opt-out choice with respect to interest-based advertising because opt-outs are usually managed by cookies, meaning that a cookie is needed to honor your decision to decline cookies.

For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

Opting Out of Interest-Based Advertising by Frequence from Frequence Properties
To opt out of receiving interest-based advertising (including retargeting) from the Frequence Properties through the use of cookies, please select “decline” within the Cookie Settings located in the bottom footer of our website.

Opting Out of Interest-Based Advertising by Third Parties from Cookies
Some third parties (including media buying customers and their customers who use cookies when you use our Services), have opt out mechanisms either directly on their website or through an industry-developed web page. The following web pages provide information on how to exercise choice regarding the collection of information about your online activities over time and across multiple third-party websites, online services, devices, and applications for interest-based advertising purposes:
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www.aboutads.info/choices
http://optout.aboutads.info/
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When you opt out of receiving interest-based advertising from third parties, note that the opt out only applies to the applicable browser in which you set it.

Note also that most opt-out tools are cookie-based. This means that, if you have cookies blocked, you will not be able to use the opt-out tool. If you delete cookies entirely, then you will need to opt out from interest-based advertising again.

Once the opt-out has been completed, you will still receive advertisements on properties that you visit, but such advertisements will not be interest-based ads targeted by the third parties whose cookies you opted out of.

To opt out of Google DoubleClick click here: Google Double Click Opt-Out
For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
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Opting Out of Third Party Interest-Based Advertising in Mobile Applications
To opt out of third party interest-based advertising that takes place through mobile applications, go to the opt-out settings on your mobile device.

Opting Out of Third Party Cross-Device Targeting
Third parties (including our media buying customers and their customers) may combine and use information from websites or applications on your current browser or device with information from your other browsers or other devices for advertising purposes. To opt out of such practices (i.e., cross device advertising), please follow the instructions above for opting out on each of your browsers and on each of your devices, including: “Opting Out of Interest-Based Advertising by Third Parties from Cookies” and “Opting Out of Third Party Interest-Based Advertising in Mobile Applications.”

Please note that you will need to opt out separately on (1) each of your browsers and (2) each of your mobile devices to ensure that information collected on a particular browser or device is not used on another browser or device.

Opting Out of Use of Precise Location
To disable the collection of precise location information from your mobile device through mobile applications, you can access your mobile device settings and choose to limit that collection.

See the Additional US Notice below for additional rights regarding your precise location.‍

USER RIGHTS

You may send us an email at privacy@frequence.com to request access to, correct or delete any personal information that you have provided to us.

California, Virginia, Colorado, Connecticut, and Utah Users: If you are a resident of California, Virginia, Colorado, Connecticut, or Utah, see the Additional US Notice below.

Canadian Users: If you are a resident of Canada, see the Additional Canada Notice below.

If you delete any information that you posted publicly on the Frequence Properties, copies of this information may remain viewable in cached and archived pages or might have been copied or stored by users.‍

HOW DO WE PROTECT YOUR INFORMATION?

The security of your information is important to us. Frequence has implemented reasonable physical, organizational, administrative, and technical security measures appropriate to the nature or sensitivity of the personal information processed, the purpose of the processing, the quantity and distribution of the personal information processed, and the medium on which personal information is stored, in order to protect the personal information from unauthorized or illegal access, destruction, use, modification, copying, or disclosure and to protect the confidentiality, integrity, and accessibility of personal information

THIRD PARTIES AND THIRD PARTY LINKS

This privacy policy does not cover and we are not responsible for the privacy, data or other practices of any third parties (except as required by applicable law), including any third parties operating any site or service to which our Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. For example, when you click on the Facebook, LinkedIn, Instagram, Twitter, or YouTube buttons on our website, you will be redirected to those third parties’ websites. These third parties have their own data practices and privacy policies.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose to us, any sensitive information on or through the Services or otherwise to us, except where such information is legally required.

If you are a California or Virginia resident, please see the “Additional US Notice” below for additional information regarding our use of sensitive information.

HOW LONG DO WE RETAIN YOUR INFORMATION

We will retain your personal information for the period reasonably necessary to fulfill the purposes outlined in this Privacy Policy or until an individual requests deletion in accordance with applicable law and this privacy policy, unless a longer retention period is required by law. When required by law, we destroy or anonymize personal information once it is no longer needed. When determining how long we retain your information, we consider the nature, sensitivity, and amount of the personal information, the potential risk of harm from unauthorized disclosure or use, and our legal, regulatory, tax, accounting and other obligations.

CHILDREN

We do not knowingly collect any information from anyone under 18 years of age. Our Services are all directed to and intended for people who are at least 18 years old or older. If you think that we maintain any personal information of your child, please contact us so that we may remove the information.

CALIFORNIA’S “SHINE THE LIGHT” LAW

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Frequence Properties that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@frequence.com or write us at: 155 E Dana Street, Mountain View, California 94041.

ADDITIONAL CANADA NOTICE

This Additional Canada Notice applies to residents of Canada (including its provinces) whose personal information we collect (“consumers” or “you”). This Additional Canada Notice is in addition to the information in our general privacy policy above.Note that not all personal information of Canadian residents is covered by this Additional Canada Notice (e.g., certain publicly available information).

Consent for Uses
Our general privacy policy above outlines our uses of your personal information. Please see "What are our uses of your information?" You consent to such uses.

Categories of Frequence Workforce with Access
The following categories of Frequence’s workforce will have access to your personal information:‍‍

Marketing team
Engineering team
Product team

Storage Locations
Your personal information will be stored digitally in the United States and India.

Technologies Used
We use the following technologies that function to identify you: cookies, pixel tags, and device graphs for advertisers.

Your Rights and Choices
Canadian residents (depending on whether federal or provincial law applies) may have the following specific rights about their personal information:‍‍

Right to know
Right to access
Right to data portability
Right to rectification/correction
Right to erasure/deletion, right to de-identification, or right to require personal information to cease to be disseminated and require de-indexing
Right to object or opt out of processing or withdraw consent
Right to know names of Frequence’s subprocessors
Right to submit a complaint or right to apply for reviewof any disagreement
Right to know information regarding automated decision-making*

*Frequence does not engage in automated decision-making.

To exercise your rights above, please submit your request to us by either:‍‍

Emailing us at privacy@frequence.com and providing your full name and email address and the request that you are making.
Submitting a web form located here: https://frequence-data-request.adservices.brandcdn.com/data_request and providing your full name and email address and the request that you are making

If we received your information from a media buying customer, you will need to make the request directly with the media buying customer unless they have authorized us (as their service provider) to respond directly to you. Depending on where you reside, you may also submit a complaint to your governmental authority.‍‍

ADDITIONAL US NOTICE

This Additional US Notice applies to California, Virginia, Colorado, Connecticut and Utah residents whose personal information we collect (“consumers” or “you”). This Additional US Notice is in addition to the information in our general privacy policy above.

Note that not all personal information may be covered by this Additional US Notice (e.g., personal information protected under certain sector specific laws, and certain publicly available information). This notice does not apply to workforce personal information (e.g., your information in your capacity as an employee of Frequence). Other than California residents, this notice also does not apply to individual business information (e.g., information in your capacity as an employee of any of our media buying customers or vendors).

Workforce Policy: If you are part of our California workforce (e.g., employees, job applicants, contractors, owners, directors, and officers of Frequence who reside in California), please see the Privacy Notice for California Company Workforce below.

What Personal Information Do We Collect?
We collect the following categories of personal information:

Examples of items collected by Frequence

For example, name, email, physical address, cookie ID, IP address, and user account information

For example, name and phone number
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For example, age and gender

For example, consuming tendencies and histories

Internet or other electronic network activity information, including browsing history, search history, and information regarding a consumer’s interaction with an internet website application or advertisement.

For example, electronic communications over email, and when we record our virtual meetings with representatives of our media buying customers, business partners, and vendors.

For example, job title, employer, and profession.

For example, profiles reflecting preferences and behavior.

For example, precise geolocation and Frequence user account information

Sensitive information
We collect the following categories of sensitive personal information from consumers:

Precise geolocation
Frequence user account information

We use this sensitive information for the purposes set forth in “How Do We Use Personal Information” below. We do not use sensitive information for the purpose of inferring characteristics about you. We do not sell your sensitive information, and we do not process or otherwise disclose sensitive information for the purpose of behavioral advertising.

Regarding precise geolocation, our media buying customers may provide us with your location data in which case we rely on them or mobile apps to have obtained your consent or to have provided you with an opportunity to opt out.

To learn how to opt out of the use of your precise geolocation generally, see “How to Opt-Out and Your Choices” in the general privacy policy above.

To request that we delete your precise location that we receive from our advertiser clients, we will need either your IP address or device identifier in order to locate your particular precise location in our log files. You may email us your request at privacy@frequence.com.

Regarding the Frequence user account information, our media buyer customers’ employees can create user accounts in order to use our Services. We collect and use that information at your specific request and to perform the Services for our media buyer customers.

Categories of Sources:
We obtain the above categories of personal information from the following categories of sources:

Directly from you,
Automatically collected information,
Our media buying customers,
Information from interactions with our ads,
Information when you log in with a third party’s single sign-in, and
Information from other sources (for example when we buy access to certain data).

How do we Use Personal Information?
We may use the personal information for one or more of the following purposes:

Providing and improving the Service.
Personalizing ads.
Marketing the Service.
Detecting fraud.
Exploring a combination.
Legal and other uses.
As described to you when collecting your personal information or as otherwise permitted in the CCPA.

How Do We Use Personal Information?
We commit to maintain and use deidentified information in deidentified form only and we will not attempt to reidentify the information, except we may attempt to reidentify the information solely for the purpose of determining whether our deidentification process satisfies our commitment above.
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Commitment Regarding Deidentified Information
We commit to maintain and use deidentified information in deidentified form only and we will not attempt to reidentify the information, except we may attempt to reidentify the information solely for the purpose of determining whether our deidentification process satisfies our commitment above.
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Who do we Disclose your Personal Information to?
We disclose the categories listed above to the following categories of third parties:

Our affiliates
Our service providers
A buyer of our business
The public (e.g., voluntarily by you when you post in public places of our site)
For legal disclosures
Otherwise with your consent

No Selling or Sharing of Personal Information for Targeted Advertising
We do not sell your personal information. We do not share your information or disclose it for targeted advertising.

No Profiling
We do not profile you in furtherance of decisions that produce legal or similarly significant effects concerning you.

Your Rights and Choices
California, Virginia, Colorado, Connecticut, and Utah residents have specific rights about their personal information, including the right to know, right to access, right to data portability, right to correction, right to deletion, and, as applicable, right not to receive retaliatory or discriminatory treatment for exercising these rights, and right to appeal.

If we received your information from a media buying customer, you will need to make the request directly with the media buying customer unless they have authorized us (as their service provider) to respond directly to you.

Know, Access and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request (see Exercising Rights), we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
The categories of third parties to whom we disclose that personal information.
The specific pieces of personal information we collected about you—allowing you to data port.

Correction
You have the right to request that we correct any of your personal information that we maintain about you. Once we receive and confirm your verifiable consumer request, we will correct your personal information. You must contact the applicable media buying customers directly to correct your information that they have in their systems.

Deletion Request
You have the right to request that we delete any of your personal information that we collected from you and still retain, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Right of No Discrimination and No Retaliation
We will not discriminate or retaliate against you for exercising any of your rights under applicable law. You have the right not to receive discriminatory treatment for the exercise of any of your privacy rights under applicable law.

Appeal Right – Virginia, Colorado, and Connecticut Residents
If we decline to take action regarding your request, we will inform you of that decision and the justification for declining to take action. If we decline to take action at the direction of our media buying customer, you must contact the applicable media buying customer directly to appeal the decision.

For Virginia residents, you have the right appeal our decision no later than 30 days after we inform you of our decision. Send your appeal to us via email at privacy@frequence.com with “Appeal Right” in the subject line of your email. Within 60 days after we receive your appeal, we will inform you of any action taken or not taken in response to the appeal. If the appeal is denied, you may contact Virginia’s Attorney General to submit a complaint at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.

For Colorado residents, you have the right appeal our decision no later than 30 days after we inform you of our decision. Send your appeal to us via email at privacy@frequence.com with “Appeal Right” in the subject line of your email. Within 45 days after we receive your appeal, we will inform you of any action taken or not taken in response to the appeal. We may extend this period by 60 additional days where reasonably necessary. If the appeal is denied, you may contact Colorado’s Attorney General to submit a complaint at https://coag.gov/file-complaint/.

For Connecticut residents, you have the right appeal our decision no later than 30 days after we inform you of our decision. Send your appeal to us via email at privacy@frequence.com with “Appeal Right” in the subject line of your email. Within 60 days after we receive your appeal, we will inform you of any action taken or not taken in response to the appeal. If the appeal is denied, you may contact Connecticut’s Attorney General to submit a complaint at https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page.

Exercising Rights
To exercise your rights above, please submit a verifiable consumer request to us by either:

Emailing us at privacy@frequence.com and providing your full name and email address and the request that you are making (e.g., right to access, portability or deletion).
Submitting a web form located here: https://frequence-data-request.adservices.brandcdn.com/data_request and providing your full name and email address and the request that you are making.

California Individuals Acting in Business Capacity:
If you are a California resident and acting in a business capacity (e.g., as an employee or other representative of one of our media buying customers or vendors), you may submit a verifiable consumer request by emailing us at privacy@frequence.com and including your full name and email address (including your business email address) and the type of request you are making. As a website user, you should also submit a request via the web form above to cover your personal information as a website user.
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Making a verifiable consumer request does not require you to create an account with us. We do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We may require you to make your request through your account if you have an account with us.

PRIVACY NOTICE FOR CALIFORNIA COMPANY WORKFORCE

This Privacy Notice for California Company Workforce (“California Workforce Notice”) applies solely to employees, job applicants, controlling owners, directors, officers, independent contractors, and medical staff of Frequence (if any) who are California residents (“you” or the “Company Workforce”).

We have adopted this California Workforce Notice to comply with the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA) with respect to certain Company Workforce. Any terms defined in the CCPA have the same meaning when used in this California Workforce Notice.

Information We Collect from Company Workforce
We collect the following categories of personal information from our Company Workforce:

Examples of items collected

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, visa information, or other similar identifiers.

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.Some personal information included in this category may overlap with other categories.

Age (40 years or older), race, national origin, medical condition, disability, gender, sexual orientation, veteran or military status.

Browsing history, search history, information on a consumer’s interaction with a website or application.

Physical location.

Recordings of virtual meetings, electronic communications, and recordings from security cameras on office premises.
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Current or past job history, resume information, or performance evaluations.

Profile reflecting a person’s intelligence, abilities, and aptitudes.

Social security number, driver’s license, passport number, Frequence account login, financial account information, precise geolocation, race or ethnic origin, citizenship, immigration status, contents of emails

Sensitive Information
We collect the above examples of sensitive personal information from our Company Workforce.

We use this sensitive information for the purposes set forth in “Use of Personal Information” below. We do not use sensitive information for the purpose of inferring characteristics about you. We do not sell your sensitive information, and we do not process or otherwise disclose sensitive information for the purpose of behavioral advertising.

Sources of Collection
These are the categories of sources of your personal information that we collect:

Directly from you
Automatically
From service providers (e.g., third party recruiters, background check service providers, etc.)

Use of Personal Information
We may use the personal information of the Company Workforce for the following purposes:

Employees, directors and officers: We may use your information for the following purposes: identifying you, verifying work authorization, administering taxes and health, medical and other benefit plans, keeping track of your records, contacting you, facilitating payment to bank accounts, contributing to and administering 401(k) plans, garnishing wages required by law, evaluating performance, tracking efficiency and productivity, protecting against disclosure of confidential information and trade secrets, and ensuring compliance with applicable laws and company policies.
Job applicants: We may use your information for the following purposes: identifying you, keeping track of records, contacting you, evaluating your candidacy, performing background and reference checks, and onboarding you.
Independent contractors: We may use your information for the following purposes: identifying you, administering taxes, keeping track of your records, contacting you, facilitating payment to bank accounts, evaluating performance, tracking efficiency and productivity, protecting against disclosure of confidential information and trade secrets, and ensuring compliance with applicable laws and company policies.
Legal and Other Uses. We may also use your information if we believe it is required or appropriate: (a) to prevent or stop activity that we may think is, or is at risk of being, illegal, unethical or legally actionable activity; (b) to protect our rights, privacy, safety or property, and that of you and others; (c) to protect our operations and the security of our Services; (d) under applicable law; (e) to comply with legal process and our legal obligations; (f) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties;(g) to enforce our terms and conditions; and (h) to allow us to pursue available remedies or limit potential damages.
We may use your information as described to you when collecting your personal information or as otherwise set forth in the CCPA.

Disclosing Personal Information
We disclose the above categories of personal information to the following categories of third parties:

Affiliates.
Service Providers.
Buyer of our Business.
Public (voluntarily by you).
Legal and other Disclosures.
Other third parties with your consent.

No Sale of Personal Information
We do not sell personal information. “Sell” is defined under the CCPA.

No Sharing Personal Information for Cross-Context Behavioral Advertising
We do not share personal information to other companies for their cross-context behavioral advertising purposes. “Share” is defined under the CCPA.

Your Rights
Your rights include the following:

Right to know
Right to access
Right to data portability
Right to correction
Right to deletion
Right not to receive retaliatory or discriminatory treatment

Know, Access and Data Portability
‍You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of third parties to whom we disclosed that personal information.
The specific pieces of personal information we collected about you – you can then copy and port that information.

Correction
You have the right to request that the Company correct any of your personal information that the Company collected from you and retained. Once we receive and confirm your verifiable consumer request, we will correct your personal information.

Deletion
You have the right to request that the Company delete any of your personal information that the Company collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies under applicable law.

Right of No Discrimination and No Retaliation
We will not retaliate or discriminate against you for exercising any of your rights under the CCPA. You have the right not to receive discriminatory treatment for the exercise of any of your privacy rights under the CCPA.

Exercising Your California Rights
To exercise the rights described above, please submit a verifiable consumer request as follows:

emailing us at Peopleteam.dataprivacy@frequence.com and including your full name and email address and the type of request you are making (e.g., right to know, access, portability, correction, or deletion), or
calling us at (650) 209-0557‬.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format
We attempt to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver our response to you either via email or mail.

The response we provide will explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.