Privacy Policy

Here at Broadstream, we take your privacy seriously. Please read the following to learn how we treat your Personal Data.  By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

Remember that your use of the Services of Broadstream Inc., its affiliates and its subsidiaries (collectively “Broadstream,” “us,” or “we”)  is at all times subject to the Terms of Service , which incorporates this Privacy Policy.  Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service. 

TABLE OF CONTENTS
1.     WHAT THIS PRIVACY POLICY COVERS
2.     WHAT INFORMATION WE COLLECT
3.     PURPOSES FOR WHICH WE COLLECT AND USE YOUR PERSONAL DATA
4.     HOW WE MAY SHARE YOUR PERSONAL DATA
5.     YOUR CHOICES ABOUT HOW WE USE YOUR PERSONAL DATA
6.     YOUR EUROPEAN PRIVACY RIGHTS
7.     DATA SECURITY AND RETENTION
8.     CHILDREN’S PERSONAL DATA
9.     ADDITIONAL DETAILS
10.  UPDATES TO THIS PRIVACY POLICY
11.  CONTACT US 

1. WHAT THIS PRIVACY POLICY COVERS

This Privacy Policy covers how we treat Personal Data that we gather about you anywhere this Privacy Policy is posted, including when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage, and this Privacy Policy does not apply to Personal Data that we collect from our employees or contractors.

2. WHAT PERSONAL DATA WE COLLECT

We may collect information about you (and the computer or device you use to access our Sites) in a variety of ways:

• You may directly provide information to us
• You may choose to allow social media platforms to share information with us
• We may gather other information from your device when you visit our Site or other services, or when you view our online ads
•  We may obtain additional information about you from other sources where permitted by law

More detail on each of these is immediately below.

Information you directly provide
When you register for an account, participate in our offers, surveys, or Site features, interact with us on social media, apply for a job with us, or otherwise communicate with us, you may directly provide us with information, including (but not limited to) the following:

• Identifiers, such as name, email address, phone number, title, and postal address or zip code
• Username and password for a Broadstream account
• Demographic information, such as your age, gender, or birthdate
• Commercial information, such as payment and billing information
• Other information about you, your household, your family, or others, such as commercial information like interests or viewing preferences)
• Other information you affirmatively allow a third-party service (such as Facebook or Twitter) to provide to us
• Employment-related information as part of a job application, such as work history, education background, resume, and cover letter.

Information from social media platforms
If you choose to access or make use of third-party social media platforms (such as Facebook or Twitter), we may receive personal information about you that you have made available to those services, including information about your contacts on those services. For example, some social media platforms allow you to push content from our Site to your contacts. Some social media platforms also will facilitate your registration or log-in for our Site or enhance or personalize your experience on our Site. Your decision to use a social media platform will always be voluntary. However, you should make sure you are comfortable with the information social media platforms may make available to our Site by carefully reading and reviewing those platforms’ privacy policies.

Information we gather from your device when you visit our Sites or when you view our online ads
When you visit or use our Site, when you view our online ads elsewhere, or when you open our emails, we may use cookies or other technologies (including pixels, tags, and web beacons) to automatically collect information about your computer or device, and your internet or other electronic network activity.  The following are examples of the types of information we may collect in this way:

• System information such as device, browser and operating system type and version, screen resolution and preferred language
•  IP address, device ID, mobile device advertising identifier or similar information
• Geolocation information
• Websites or online services you visit before or after our Site
• Your interaction with our Site (such as the links you click, the time of your visit, the content you view and how long you view the content, and the search terms you submit)
• Whether you open or forward our emails or click on elements within these emails

Information we may obtain from other sources
In some jurisdictions, we may obtain information about you from other sources., so we can better understand you and customize the content and advertisements that are shown to you. From example, we may collect information from public databases, co-branded partners and websites, third-party interactive applications, television streaming or multichannel video programming distributors, data aggregators, and other commercially available sources. This information may include:

• Identifiers, such as name, email address, phone numbers, and postal address
• Social media user IDs
• Demographic information such as age or gender
• Interests, hobbies, and product preferences
• Interactions with media or advertising
• Publicly observable activities (such as blogs and online postings)

Please note that parts or all of the information we collect or obtain may be combined or linked (by us or by third parties providing services to us) for any of the purposes described in this Privacy Policy, including to help us customize how we communicate with you and to improve our content, services, and marketing efforts.

3. PURPOSES FOR WHICH WE COLLECT AND USE YOUR PERSONAL DATA

We use the information we collect (in combination with other information we or third-party service providers may have) to operate our business, to communicate with you regarding our content, services, and promotions, to provide you with other information, services, products, or other materials you request, to customize your interactive experience (including by providing you with relevant advertising on our Site and elsewhere), and/or to manage and improve our sites, content, and service offerings.

Some specific examples of how we may use this information are as follows:

• To register you to receive emails or other information or materials you request
• To create and manage your account as a user or member of our Site
•  To provide you with services or content you have requested
• To respond if you contact one of our Consumer Services Representatives
• To process your payment for purchases or other services or your redemption of loyalty program points
• To better understand the audience for our Sites and services
• To conduct analytics services regarding how our products, services, and Sites are accessed and used
•  To help us develop new content and services
• To provide advertising and marketing services, including by developing and delivering advertising and other communications more tailored to your interests
•  To help us improve our advertising
• To detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; and to prosecute those responsible for that activity
• To enforce our Terms of Use or other legal rights
• To verify your identity in connection with responding to certain requests you may make pursuant to this Privacy Policy
• Even if the primary function for collecting the information may be for a specific purpose, such as creating your account or registering you for a promotion, we may use the information for any of the other ways described in this section as well, including by sharing the information as permitted by law for the use of any of our affiliates or subsidiaries

4. HOW WE MAY SHARE INFORMATION WITH OTHERS

We may share the information we collect with the following types of entities for business purposes:

• Affiliates. As permitted by law, we may share information freely within any affiliates, subsidiaries, or commonly branded companies.
• Service providers. We may share information – including information that personally identifies you – with companies that provide services on our behalf. Some service providers may be involved in administering or supplementing our databases and will need to have access to your information in order to do so. For example, we may retain a third party to deliver videos to you or verify the accuracy of information within our databases or to gather additional information about individuals within our databases from commercially available sources. As another example, we may provide information from our databases to third parties who help us direct specific advertising communications to you when you visit other sites.
• Third parties who deploy cookies and similar technologies. As described in detail below (under the “Cookie Policy” section of this Privacy Policy ), third parties use a variety of cookies and similar technologies to collect information on our Site for the business purposes described above, including providing analytics services to us and providing advertising on our Site and elsewhere based on users’ online activities over time and across different sites, services, and devices (so-called “online behavioral advertising”).
• Other parties when required by law or as necessary to protect our users and services. We also may disclose information – including information that personally identifies you – to third parties in order to:
• Protect our legal rights, as well as the rights of the users of our Site or others
• Protect the safety and security of the Site, its users, or others
• Prevent fraud
•  Comply with the law or respond to legal process or a request for cooperation by a government entity, whether or not legally required.
• Other parties in connection with a corporate transaction. We reserve the right to transfer any information we have about you during negotiations for, any purchase, sale, lease, merger, or any other type of acquisition, disposal, or financing
• Otherwise with your consent. In addition to the sharing described or permitted by this Privacy Policy, we may share information about you with third parties whenever you affirmatively consent to such sharing.

When we disclose data for business purposes as discussed above, we may disclose all categories of data listed in Section 1  above.

5. Your Choices About How We Use Your Personal Data

You may opt out of receiving promotional communications from us by following the instructions in those messages or emailing us at the following form: [] . If you opt out, we may still send you non-promotional communications, such as emails about your account.

You can control certain cookies and tracking tools. Your browser can help you manage cookies. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings on each browser and device that you use. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. Since flash cookies do not reside in your browser, your browser settings will not affect them. To control flash cookies, you thus need to click here. If you turn cookies off, you may not have access to many features that make our Services more efficient, and some of our Services will not function properly. We also use Google Analytics to better understand how our users interact with our websites. You can learn about Google Analytics’ currently available opt-outs at https://tools.google.com/dlpage/gaoptout/.

You can control tracking for the purpose of serving interest-based advertising. We and third party advertising networks, social media companies, and other services may collect information about your use of our websites over time and across devices, using cookies or other tracking tools, for the purpose of displaying interest-based advertising. To opt out of such tracking for interest-based advertising purposes, please visit www.aboutads.info/choices (United States). Your opt-outs are browser- and device-specific, so you should make these selections on each device and each browser you use. If you clear your cookies or your browser’s cache, you will need to set your preferences again.

Our Do Not Track Policy. Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our website may not work. If you block or reject cookies, not all of the tracking described here will stop.

6. Your EU Privacy Rights

As detailed below, to the extent provided by the law of your jurisdiction, you may have legal rights in relation to the personal information about you that Broadstream holds. We may require you to prove your identity with approved identification if you request this information.

Lawful basis for processing your personal data.

We process on the following legal bases:

Contract: It is necessary for our performance of the contract you have agreed to enter with us. If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms of the contract.

Legitimate Interests: We are permitted to process your personal data if it is based on our legitimate interests. In relation to general inquiry and complaints you send us, our legitimate interest is to provide you with information you have requested and to provide customer support. You can object to the processing that we carry out on the grounds of legitimate interests. See the section “Rights of data subjects” below to find out how.

Consent: Where you have given us consent to do so, we provide you, or permit third parties to provide you, with information about goods or services which we feel may interest you. You have the right to withdraw your consent. Please see the section “Rights of data subjects” below to find out how.

Legal Claims: We need to process your personal data to defend or establish a legal claim (for example, claims relating to the sale of our goods and services under contract law).

Rights of data subjects

You have the following rights, where provided under applicable law, regarding your information (each of which are subject to various exceptions and limitations):

1. The right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Privacy Policy.
2. The right of access: You have the right to obtain access to your information (if we are processing it), and certain other information (similar to that  provided in this Privacy Policy). This is so you are aware and can check that we are using your information in accordance with data protection law.
3. The right to rectification: You are entitled to have your information corrected if it is inaccurate or incomplete.
4. The right to erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5. The right to restrict processing: You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability: You have rights to obtain and reuse your personal data for your own purposes across different services and platforms.
7. The right to object: You have the right to object to certain types of processing, in particular processing based on our legitimate interests. You also can object at any time to your information being used for direct marketing purposes (including profiling related to such direct marketing). Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
8. The right to refuse or withdraw consent: You have the right to refuse to provide and withdraw your consent to processing of your personal information at any time with effect for future processing.

If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the supervisory authority in your EU member state.

Please note your rights in relation to your personal data are not absolute. We may, for example, deny you access to your personal data when required or authorized by law, or if granting access would have an unreasonable impact on another individual’s privacy. We will retain and use your personal information as described in this Privacy Policy, including as necessary to comply with our legal and business obligations, resolve disputes, and enforce our agreements.

7. Data Security and Retention

We use a variety of technical, administrative, and organizational security measures designed to maintain the safety of your personal data. Please note, however, that we cannot absolutely guarantee the security of any information you provide online; you provide it at your own risk. You can help keep your data safe by taking reasonable steps to protect your personal data against unauthorized disclosure or misuse.

We retain Personal Data about you for as long as necessary to provide you with our Services and for the purposes described in this Privacy Policy. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

8. Personal Data of Children

As noted in the Terms of Service, we do not knowingly collect personal information from children under the age of thirteen (13). If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with personal information without COPPA-required consent, please contact us at the email address listed in the Contact Us section below.

9. ADDITIONAL DETAILS

Links to other sites
Our Site may contain links to the sites of our affiliates, and to sites that are owned and operated by third parties. These other sites may have their own privacy policies and are not governed by this Privacy Policy. We are not responsible for the privacy practices, security protections, or the content of sites owned and operated by third parties. Other sites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy for each site you visit.

Share-with-a-friend tools
This Site may, from time to time, include a share-with-a-friend application that makes it easy for you to forward information or materials from our Site to friends or family by email. In order to address your email message, the application may ask you to input the recipient’s email address and/or similar information (including your email address). This information is used by the application to address your message so that it can be properly sent. We may temporarily maintain a log of this information for troubleshooting and fraud-prevention purposes. In the event that we are offering you some form of referral award for encouraging an action on the part of the recipient (for example, if you are to earn a reward if the recipient chooses to register for one of our offerings after receiving the email from you), we may also retain the information as necessary to establish that the referral award was earned.

10. Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well. Those changes will go into effect on the Effective Date shown in the revised Privacy Policy. If you use the Services after any changes to the Privacy Policy have been posted, that means you consent to all of the changes relating to our data processing. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

11. Contact Us

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, please do not hesitate to contact us at [] .

Cookie Policy

We (and third parties that provide content, advertising, or functionality on our Site) may use cookies and other technologies to facilitate Site administration and navigation, to better understand and improve our Site, to determine and improve the advertising shown to you here or elsewhere, and to provide you with a rich online experience. We provide more details about these technologies below.

1. Cookies

A cookie is a tiny file that is stored on your device. It contains a unique identifier, as well as the address and other information about the site you are visiting. Some cookies are essential in order to enable you to move around our Site and use its features, such as accessing secured areas. Other cookies collect information about how visitors use the Site (for instance, which pages visitors go to most often, and if they get error messages from web pages). When combined with information collected when you register on a website, cookies allow us to welcome you back to the site or otherwise provide enhanced, more personal features. Cookies may also be used on our behalf by third parties managing our advertising on other websites to enable us to learn which advertisements bring visitors to our Sites and to otherwise improve or target our online advertising.

Most browsers accept cookies automatically but can be configured not to do so or to notify the user when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. Please note that if you disable cookies, you may be unable to access some customized features on our Site.

2. Other tracking technologies

A variety of other tracking technologies, like web beacons, pixels, and tags, are also used. These are small strings of code that are placed on a web page, in the emails we send you, or in our digital advertisements. When you access a page or platform containing one of these technologies, you establish a communication with a web server, which collects certain information about your computer or device. This information may include your IP address, browser type, operating system type, information about your interactions with our emails (such whether you opened, read, forwarded or clicked on any content within the email), and identifiers that have been stored in cookies. We (and third parties) may use these technologies to count the number of visitors to our Sites and to recognize users by accessing unique identifiers stored in cookies that we have set on their computers or devices. Being able to access these identifiers enables us to provide a personalized experience on our Sites. We may also include technologies like these in digital advertisements or in email messages to determine how these are acted on.

For purposes of the balance of this “Cookie Policy,” we will include all of these technologies within the generic term “cookies.”

3. Categories of cookies and your rights to opt out

As mentioned in the previous paragraphs, cookies are used for different purposes. Some cookies are “set” (delivered to your browser) by us. These are called “first party cookies.” Others, called “third party cookies” are set by third parties who are given access to do so on our Site. We are proud to offer you multiple ways to make choices about accepting or rejecting some of these cookies The primary way to do this is by accessing the Cookie Preference Center that we have established for each of our Sites (which you can access by clicking the “Customize Cookie Settings” link found in the bottom footer of each Site, near the link to the Privacy Policy). Within the Cookie Preference Center, you will find descriptions of each category of cookie (similar to those immediately below), and then you will be able to choose to reject certain categories of cookies, should you wish to do so (except that you cannot choose to opt out of receiving cookies falling within the “strictly necessary” category, because our Site will not function properly without these).

Cookies on our Sites fall into the following categories:

• Strictly Necessary Cookies
  These cookies are necessary for the Site to function and cannot be switched off in our systems through the Cookie Preference Center. These cookies are usually only set in response to your request for services, such as setting your privacy preferences, logging in, filling in forms, and accessing secure areas of the Site. You can set your browser to block or alert you about these cookies, but some parts of the Site will not then work.
• Analytics Cookies
  These cookies allow our Site to collect information about how you interact with the Site, including which pages you visit most often and if certain pages send you error messages. These cookies help us improve our services. If these cookies are blocked or disabled, our Site may become less functional, including the potential that some of our services may no longer be available to you.
•  Functional Cookies
  Functional cookies allow our Site to remember information, such as your preferred language, that can be used to customize your experience on our Site. These cookies also can be used to provide you with information specific to your region and may assist you in customizing our Site’s appearance. If these cookies are blocked or disabled, our Site may become less functional, including the potential that some of our services may no longer be available to you.
• Targeting Cookies
  Targeting cookies are used by parties that are involved in serving other companies’ advertising on our sites, or that are involved in determining which of our advertisements (or other parties’ advertisements) to show you on third-party websites. These cookies collect information about your online activities, such as the advertisements you have seen or the websites or pages you have visited, in order to draw inferences about what advertising might be relevant to you. This information is then used to show you targeted advertising (sometimes referred to as “interest based advertising” or “online behavioral advertising”) that may be most relevant to you, including when you visit other websites not belonging to us. If these cookies are blocked or disabled, our Site may become less functional, including the potential that some of our services may no longer be available to you.

With respect to this final category of cookies described above (targeting cookies), we offer a second means of opting out of these cookies – beyond our Cookie Preference Center. The Cookie Preference Center relates to the cookies that are set on our Site but does not affect the rest of the online world. There is also an industry-wide opt out program for targeting cookies that you can access by clicking here . Through this latter program, you can opt out of receiving targeting cookies from a broad array of third parties on any site, not just ours. Please be aware, though, that this opt-out process is itself cookie-based. In other words, if you opt out, a cookie is placed on your browser that informs these third parties that they are not to use cookies with you for targeted advertising. As a result, if you subsequently clear cookies from your browser (as many people do periodically), your opt out will be lost until you reinstate it.