Privacy Policy

Privacy

Fresh Media LLC, doing business as Fresh Media, LoMo Advertising and Fresh Group,  (collectively referred to as “FRESH”) is an online advertising technology company. FRESH provides this privacy policy to inform you how its technology processes information on behalf of the digital advertisers, website owners, and other businesses that use its services.

FRESH uses targeting technologies that comply with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.  FRESH has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.  If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification page once it is available, please visit https://www.privacyshield.gov. FRESH is subject to the investigatory and enforcement powers of the FTC with respect to our adherence to the Privacy Shield program rules.

WEBSITE PRIVACY PRACTICES

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request

Individuals located in the EU have additional rights under Privacy Shield and Safe Harbor which are listed below.

Personally Identifiable Information (PII)

FRESH collects Personally Identifiable Information (“PII”) from its websites, www.wearefreshgroup.com, www.freshtradingdesk.com, www.talktolomo.com, when you choose to provide it to us. PII is any information that can be used to identify or locate a particular person or entity. This includes, but is not limited to: name, address, telephone number, or email address. For example, you may choose to send PII about yourself in an email, or by completing a form on this website. FRESH uses this information only to contact you to respond to your inquiry. Once collected, FRESH will store your PII for a reasonable time for record keeping purposes.

Non-Personally Identifiable Information

FRESH also collects Non-Personally Identifiable Information (“Non-PII”) from visitors to this website. Non-PII is information that cannot by itself be used to identify a particular person or entity, and may include your IP host address, pages viewed, browser type, Internet browsing and usage habits, Internet Service Provider, domain name, the time/date of your visit to this Website, the referring URL and your computer’s operating system.

Cookies and other Tracking Technologies

FRESH and our partners use cookies or similar technologies to analyze trends, administer the website, and track users’ movements around the website. Users can control the use of cookies at the individual browser level. For more information about cookies, please visit http://www.allaboutcookies.org/cookies/.

We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising from those partners, click here. Please note you will continue to receive generic ads.

Third Party Websites

The FRESH website may contain links to and advertisements for websites operated by third parties whose privacy practices may differ from FRESH’s policies. While the company endeavors to associate only with reputable entities, FRESH cannot guarantee the privacy practices of other websites will reflect ours; we encourage you to check the privacy policies of all websites that you visit.

Updating / Deleting your PII

Upon request FRESH will provide you with information about whether we hold any of your PII. If you’d like to update, correct, delete, or deactivate any PII that you have provided to the company on this website, please send your request to dax@wearefreshgroup.com, and FRESH will process your request. We will respond to your request to access within a reasonable timeframe.

FRESH’S TECHNOLOGY PRIVACY PRACTICES

FRESH is in compliance with the Digital Advertising Alliance Self-regulatory Code. Our technology collects non-PII (defined above) from mobile apps and websites, including this Website and utilizes that information to deliver interest based advertising. We also may allow other third-party advertisers to collect Non-PII from this Website and utilize it to deliver relevant ads and for other purposes in accordance with industry standards. You may opt-out from interest-based advertising by clicking onto the DAA and NAI opt-out mechanisms.

Technology Overview

FRESH’s technology partners may use “network neighbor” data to help our clients deliver relevant digital advertisements on websites and mobile apps. “network neighbors” are generally two or more people that visit the same website pages, utilize the same wifi network or use the same mobile apps. For example, a network neighbor might be someone whose social networking profile page you’ve visited, used the same mobile application you’ve used or someone that visits the same website that you visit. Network neighbors are likely to share many similar interests, hobbies, and other key demographic characteristics with you, although we don’t typically know what (if any) interests or hobbies are shared by any group of network neighbors. Rather, FRESH believes that if you’re interested in a particular product or service, your network neighbors are likely to also be interested in that product or service. Therefore, by understanding whom your network neighbors are and what they like, the company’s proprietary technology will do a better job determining the digital ads that are likely to be of interest to you.

RESH’s technology collects information about the website(s) that you visit (including this Website), the mobile apps that you use and the ads that you see. And where we can reasonably infer that a particularly computer or device belong to the same household, we may extend our advertising and targeting capabilities across multiple devices. You may encounter our technology when: FRESH or one of our clients purchases digital ads on a website that you visit or a mobile app that you use or when one of our clients places a web beacon on a website that you visit.

The company uses the information collected in order to help make the digital ads you see more relevant to you, and for ad delivery and reporting purposes. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here. Please note our opt-out only applies to the browser on a particular device that has opted out and does not opt you out of being served advertising. You will continue to receive ads, but those ads will not be targeted via our technology. For more information about our opt-out mechanisms, including our mobile application choice mechanisms, please scroll down to the section of this Privacy Policy entitled:

“Controlling The Use of Your Information”.

Types of Information We Collect via Our Technology

Personally Identifiable Information (PII)

The company’s technology doesn’t collect Personally Identifiable Information (“PII”).

Non-Personally Identifiable Information

We collect Non-Personally Identifiable Information (“Non-PII”) via our technology, including but not limited to browser type, operating system, Internet Service Provider, IP address, and basic ad serving information such as the time and date an ad is served, the name of the mobile app or URLs from the web page visited. We also work with partners to enable our clients to bring their offline data into our systems for use by our technology. The data collected by our technology is de-identified prior to being used for ad targeting.

Public Forums
Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at dax@wearefreshgroup.com,. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Retention of Data Collected
We store PII such as email address or billing details so long as you continue to have a business relationship with FRESH for record keeping purposes. You may ask us to delete that information by following the instructions below. FRESH retains some data collected via its technology in its original form for up to 30 days in order to ensure that our technology is functioning properly. After 30 days, all original raw data is deleted; de-identified data may be stored for up to 3 years for research purposes. We also store Non-PII in cookies, which generally expire 9 months from the last time our systems have encountered a particular computer or device.

Controlling The Use Of Your Information

Opting Out from Interest Based Advertising (our “Choice Mechanism”)
Websites. If you’d like to opt out from having FRESH use your information to target advertising, please click here. When you opt out, FRESH will attempt to place an opt-out cookie on your computer or device. The opt-out cookie tells our technology not to use your data to target ads on websites from that computer or device. Please note that if you delete, block, or otherwise restrict cookies, or if you use a different computer or Internet browser, you will need to renew your opt-out choice.

Mobile Apps. Mobile operating systems (e.g., iOS and Android) offer opt-out choice mechanisms applicable to mobile applications and these choice mechanisms may be found via your mobile device settings. And FRESH participates in the DAA AppChoices mobile opt-out application as part of honoring the DAA Code for the Mobile Environment. Where our systems detect that a user of a device has opted out via their mobile operating system, our technology won’t use your data to target ads on mobile applications for that device. Similarly, when our systems indicate that a user of a device has opted-out out from FRESH via AppChoices, our technology won’t use your data to target ads on mobile applications for that device.

Please note that these opt-out choice mechanisms only apply to the particular device that has opted out and does not opt you out of being served advertising. You will continue to receive ads, but those ads will not be targeted via our technology.

Precise Location. If you’d like to adjust your choices regarding the use of precise location data by third parties such as FRESH, you may do so via your device settings. Also, most mobile applications that collect precise location information offer choice mechanisms.

Data Integrity, Purpose Limitation

We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use as described above.

Deleting your PII
Although FRESH doesn’t collect PII via our technology, if you’d like the company to update, correct, delete, or deactivate any PII that you have provided on the website, please send your request to dax@wearefreshgroup.com, and the company will process your request within a reasonable period of time after receipt.

Information Security
The security of your information is important to us, including but not limited to the PII collected via the website. FRESH has implemented reasonable security measures to protect the information, both during transmission and once it is received. This includes but is not limited to the use of firewalls and encryption. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while the company strives to use commercially acceptable means to protect your information, it cannot guarantee absolute security. If you have any questions about these security practices, please email dax@wearefreshgroup.com.

Information Relating to Children
FRESH’s products and services are designed for those 13 years of age and older. FRESH does not knowingly collect PII from anyone under the age of 13. If the company is made aware that it has received PII from someone under 13, it will use reasonable efforts to remove that information from its records.

Disclosure of Information to Third Parties, Onward Transfer

FRESH does not rent, sell or share your PII with non-affiliated third parties without your consent. The company may, however, share PII with trusted third-party partners who may help us to manage the Website. These third party contractors are prohibited from using the information for purposes other than performing services for FRESH. FRESH may also transfer Non-PII to our advertising clients and their agents. In certain jurisdictions such as the EU, some of this information may be considered personal information. In cases of onward transfer to third parties of personal data of EU individuals received pursuant to the EU-US Privacy Shield, FRESH is potentially liable.

he company may also share aggregate data collected on the website or via its technology with unaffiliated third parties. For example, FRESH may disclose that digital ads offering ‘country music’ ring tones receive more clicks than those offering ‘classic rock music’ ring tones. This information cannot be used to contact or identify any person individually.

FRESH may be required to disclose your information to third parties when obligated to do so by law and in order to investigate, prevent, or take action regarding suspected, or actual prohibited activities, including transfer reasonably intended to meet national security or law enforcement requirements, or when we believe in good faith that disclosure is necessary to protect our rights, including but not limited to fraud and situations involving potential threats to the physical safety of any person.

Finally, FRESH may transfer information, including any PII, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If FRESH is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

CHANGES TO THIS PRIVACY POLICY
This privacy policy is subject to change. If the company plans to make any material or substantive changes in the way it uses the PII collected through this website, it will post a clear and conspicuous notice on the website and in this privacy policy prior to the changes being made.

CONTACT INFORMATION
For questions or concerns relating to privacy, please email dax@wearefreshgroup.com.

Privacy Complaints by individuals located in the EU.

In compliance with the Privacy Shield, FRESH commits to resolve complaints about your privacy and our collection or use of your personal information. Persons located in the EU with inquiries or complaints regarding this privacy policy should first contact FRESH at dax@wearefreshgroup.com.