PRIVACY POLICY

Brilig offers an online technology platform known as the Brilig Data Exchange ("BDE"). Brilig's mission is to enable our clients (exchange "Members") to leverage the BDE to enhance the relevance of the content and advertisements that consumers see on the websites they visit.

This Privacy Policy describes the BDE and to the services that Brilig provides to BDE Members. The Policy also outlines the process by which Brilig obtains data for use on the DBE from our data partners ("Data Partners"). For a copy of the Privacy Policy regarding our corporate website, www.Brilig.com, please click here.

If you'd like to opt-out from having your information used by Members on the BDE, please click here. When you opt out of the BDE, we will place an opt-out cookie onto your computer that tells our servers not to collect any information about you and/or place it on the BDE. Be advised that if you change computers, use a different browser on the same computer, use multiple computers or browsers or delete your cookies, you will need to repeat this process for each computer and browser.

Overview of the Brilig Data Exchange (BDE)

The BDE is a technology platform that enables Members of the exchange to find online audiences and analyze their online advertising campaigns. We also provide data analysis tools and audience segmentation services based on the anonymous audience data and ad campaign data that our Data Partners place onto the BDE. Exchange Members create anonymous audience data segments ("Segments") of Internet Users based upon those Users' Internet usage and other preferences, and use those segments to increase the relevance of the online advertisements and content that Internet Users see. Segments are unique groups of Users that are dynamically created using criteria selected and defined by BDE Members. None of these segments may be used to identify a unique individual. Exchange Members may also be Data Partners.

Brilig's role is analogous to that of a stock exchange, in that we operate the BDE as a trusted 3rd party in order to help ensure that:

Generally accepted Privacy and Security standards are being adhered to by Members and Data Partners;
The individual Terms and Conditions of each Member and Data Partner are followed;
No PII (defined below) is transferred by any Data Partner or exchange Member onto the BDE Brilig; and
Accurate usage reporting is provided (by Brilig) to exchange Members and Data Partners to certify licensing transactions conducted through the BDE.

For more information on the privacy requirements Brilig imposes on exchange Members and Data Partners, please see the section below entitled "Privacy Practices of BDE Members and Data Partners."

What Information is collected by the BDE?

Personally Identifiable Information ("PII")

Brilig does not collect or store PII via the BDE. For more information about exchange Member privacy practices, please see the section of this privacy policy entitled "Privacy Practices of BDE Members and Data Partners."

Non-Personally Identifiable Information ("Non-PII")

Data Partners transfer Non-PII into the BDE, and our Members use that Non-PII to build consumer interest Segments. The BDE contains primarily five classes of data: behavioral, commercial, contextual, profile and search data. For example, a BDE Member may merge information about child seat types that a customer researched on Google with the fact that the customer read an article about minivans to deduce that the customer is in the Segment of “families with young children.” The BDE Member may then offer this customer a discount at an E-commerce site that sells toys. BDE Data Partners make both offline and online data available over the BDE. Using that data, a BDE Member may, for example, combine survey information used to estimate a consumer's income range Segment (say between $30,000 and $50,000 annually) with the fact that the consumer visited a real estate site looking for apartment rentals to find people possibly interested in renter's insurance.

BDE Members use a great variety of consumer interest Segments, which may include:

Automotive
Consumer Packaged Goods > Beauty and Personal Care
Consumer Packaged Goods > Food and Nutrition
Consumer Packaged Goods > Pets and Animals
Entertainment
Entertainment > Games
Entertainment > Movies
Finance
Finance > Credit Cards
Finance > Consumer Credit Info
Finance > Insurance > Life
Finance > Insurance > Medical and Dental
General Health
General Health > Bones Joints and Muscles
General Health > Dental
General Health > Digestive System > Heartburn
General Health > Foot
General Health > Headaches
General Health > Hearing
General Health > Respiratory > Allergies
General Health > Vision
General Health > Wellness > Exercise and Fitness
General Health > Wellness > Smoking Cessation
General Health > Wellness > Weight Loss
General Health > Womens General Health
Interests -> Disabled/Handicapped
Issues and Causes > Green
Life Stages > Education
Life Stages > Moving
Life Stages > Parenting and Children
Sports > Outdoors
Technology
Telecommunications
Travel

Non-PII is information that cannot by itself be used to identify a particular person or entity, and may include your IP host address, website pages viewed, browser type, Internet browsing and usage habits, Internet Service Provider, domain name and your computer's operating system.

Cookies and Web Beacons

We use cookies and web beacons in connection with the BDE. Cookies are small text files that web servers typically store on an Internet User's computer through their web browser when they visit a website. Cookies can be accessed by web servers when the User returns to a website or goes to another website. Web beacons are small strings of code that provide a method for delivering a graphic image to a web page for the purpose of transferring data. The server providing this web beacon may be controlled by the same party as the website being visited or by another party that has been given permission to place the web beacon on the site. For more information about cookies and web beacons please visit http://www.allaboutcookies.org/cookies/.

Brilig, our exchange Members, and our Data Partners use cookies, web beacons and similar tracking technologies to collect and store Segments in order to increase the relevance of the advertising and content that consumers see while online, and for delivery and reporting purposes. All exchange Members and Data Partners also use Brilig cookies that allow Brilig to provide consumers with a universal opt-out of all data collection and ad serving associated with the BDE.

You are always free to decline cookies (keep your web browser from writing them to your computer), but by doing so you may not be able to use certain features or take full advantage of all the website offerings of the websites you frequent and the advertising you see will not be as closely targeted to your desires. You can configure your browser to accept all cookies, reject all cookies, erase cookies, or notify you when a cookie is set. (Each browser is different, so check the "help" menu of your browser to learn how to change your cookie preferences.)

Consumer Opt-Out

Information Sharing and Disclosure

Brilig may also disclose information in our possession when we have a good-faith belief that disclosure of such information is reasonably necessary to; satisfy any applicable law, regulation, legal process, or governmental request, detect, prevent, or otherwise address fraud, security, or technical issue, or protect against imminent harm to an individual's safety or rights.

We may share information in our possession with third-party agents who provide administrative services or to law enforcement or government officials, pursuant to a court order, as we deem necessary or appropriate. If Brilig becomes involved in a merger, acquisition, or any form of sale of a majority or all of its assets, any data we have in our possession will be part of the assets transferred.

Brilig adheres to self regularly principles for online behavioral advertising.

How long is information stored via the BDE?

The BDE stores information for up to three years, and then it is rendered anonymous and stored for up to an additional five years.

How is information secured and protected?

We maintain physical, electronic, and administrative safeguards to protect all our data from accidental, unauthorized or unlawful access, use, modification, disclosure, loss, or destruction. The data is kept on a secure server and we restrict access to the data solely to authorized users. No security measures, however thorough, are perfect and there can be no absolute assurance of security and therefore, we cannot and do not offer an absolute guarantee or warrant the security of the information we possess.

Privacy Practices of BDE Members and Data Partners

In order to ensure consumer privacy and security, all BDE Members and Data Partners must comply with Brilig's internal privacy & data security guidelines and agree to utilize Brilig's universal opt-out tool referenced above. In addition, Brilig takes reasonable steps to ensure that BDE members and Data Partners adopt responsible privacy practices when they use the BDE, including contractual provisions and periodic evaluations of Member and Data Partner practices. However, the BDE operates as a platform, and Brilig cannot be responsible for the privacy practices of any BDE Member or Data Partner.

Children under the age of 13

Brilig's products and services are not intended for or directed at children under 13 years of age. We do not knowingly solicit or collect any PII including not from children under the age of 13, we prohibit exchange Members and Data Providers from creating Segments of children under 13 via the BDE, and we do not market our products or services to children under the age of 13. If you believe that the PII of someone under 13 is being stored on the BDE, please contact us at privacy@brilig.com and we'll make reasonable attempts to purge the information from our systems.

Changes to This Policy

If Brilig decides to change our privacy practices, we will post those changes to this privacy statement. We reserve the right to modify this privacy statement at any time, so please review it frequently.

Contacting Brilig

Brilig's offices are located in New York City. You can reach us by sending an email to privacy@brilig.com .

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