OpenGlass Privacy Policy

Welcome to OpenGlass’s Exchange Platform Privacy Policy. We are committed to protecting your privacy and treating your personal information, personal data, or the equivalent terminology in your region (collectively, Personal Data) with transparency, care, and respect.

The Exchange Platform Privacy Policy (Policy) explains how we collect, use, and share (collectively, Process) your Personal Data as part of our digital advertising marketplace. If you are looking for information on how you can exercise your rights under applicable data protection and privacy laws, such as from the U.S. (California), Europe, and Canada.

Any reference to OpenGlass, we, or our means OpenGlass Inc., and its direct and indirect global subsidiaries.

Personal Data we collect, use, and share (Process)

On the OpenGlass Platform, we Process your Personal Data when you visit a Publisher’s Digital Properties. OpenGlass Processes your Personal Data to provide our Platform Services if we have permission from Publishers to do so.

Below are the main types of Personal Data we may Process on the OpenGlass Platform for the provision of our Platform Services. The information we receive is predominantly determined by each Publisher that you interact with. We are not able to determine your name, email address, or other similarly identifying information based on the Personal Data we Process on the OpenGlass Platform.

Digital identifiers (Digital IDs):

We may Process unique identifiers that are associated with the Digital Properties you are using. Digital identifiers include:

• cookie IDs: unique identifiers assigned to cookies (small text file stored on your web browser when you visit a website);
• device advertising IDs: unique identifiers used for advertising purposes on various devices, including mobile devices, Connected TV (CTV) devices, and others. Some examples of device advertising IDs (not an exhaustive list) are the following:
  • Identifier for Advertisers (IDFA) is used on Apple devices running iOS,
  • Android Advertising ID (AAID) is used on Android devices,
  • Google Advertising ID (GAID) is a unique advertising ID assigned to Android devices by Google Play services,
  • Roku Advertising ID is a unique identifier assigned to Roku devices,
  • LG Smart TV Advertising ID is a unique identifier assigned to LG smart TVs, and
  • Samsung Smart TV Advertising ID is a unique identifier assigned to Samsung smart TVs;
• third-party IDs: unique identifiers that belong to third parties. Third-party IDs may be associated with broad aggregate audience segments and shared with Buyers to serve more relevant ads to you based on your interests (for example, ads related to sports or fashion).

Browser and device information:

Information including, but not limited to, the type and version of your browser, browser settings (such as language and local time), user agent, your IP address, device type (for example, laptop, mobile, TV), model, manufacturer, operating system, and time zone.

Location information:

Imprecise geolocation information such as city, country, zip code/postal code, and/or longitude and latitude with less than 2 decimal places. Publishers may provide us with precise geolocation information in the form of longitude and latitude with three or more decimal places.

Other data provided to OpenGlass:

Additional information provided to us by, or for, our Publishers to improve Publisher advertising. For example, a Publisher may include information about your interests or broad demographic information.

Purposes and Legal Bases for Processing Personal Data

We Process your Personal Data to provide our Platform Services when it is permitted by law and supported by a valid legal justification (Legal Basis). We rely on the Legal Basis of consent for the following Processing activities:

• Ad delivery: to deliver ads to you on Publishers’ Digital Properties;
• Ad reporting: to verify an ad was delivered to you with accuracy;
• Impression Counting: to count the number of times ads are displayed against a Digital ID.

We rely on the Legal Basis of legitimate interests for the following Processing activities:

• Ad vetting: to prevent fraud, malware, and other unacceptable behavior; and
• Troubleshooting, optimizing, and product improvement: to improve our Platform Services and ensure ads are delivered correctly to you.

We rely on the Legal Basis of legal obligations for the following Processing activity:

• Privacy Rights: to view and enforce your opt-out choices, and honor your privacy choices/rights. For example, if you make a request to delete your Personal Data, we will use your Personal Data to search, identify, and delete your Personal Data.

Sharing Personal Data

We may disclose, share, or sell (collectively, Share) your Personal Data with the following partners for the purpose of delivering ads to you:

• Buyers: we Share your Personal Data with Buyers to source ads that may be relevant to your interest(s). Buyers may Share Personal Data with their clients and partners for the provision of their services. Each Buyer Processes and Shares Personal Data in accordance with their own privacy policies, which may differ from the information found in this Policy. To help protect your Personal Data, OpenGlass contractually requires Buyers to comply with applicable data protection and privacy laws, and implement user-centric privacy practices;
• Identity Partners: On the instruction of Publishers, your Personal Data may be Processed by and Shared with Identity Partners, independent companies that Process online identifiers which they have collected independently from OpenGlass. For example, they may use online identifiers to group you into broad based, aggregated audience segments (for example, age range: 25-35; interests: cars). We do not actively create audience segments about you; however, our technology facilitates the delivery of these audience-based identifiers to Buyers;
• Vendors and service providers: Our third-party vendors may help us provide our Platform Services. For example, we use third-party vendors for fraud detection, load balancing, and content delivery network (CDN); and
• Legal requirements: We may be required to disclose your Personal Data to comply with our legal obligations, or in cases where we believe in good faith that such disclosure is required by law.

International Transfers of Personal Data

To provide our Platform Services, we may transfer your Personal Data internationally to any of our data center locations, or to any Buyer’s international data center locations. We respect the security and confidentiality of your data while effecting these international transfers. We ensure any international transfers of your Personal Data are compliant with applicable data protection and privacy laws.

When we transfer Personal Data outside of the European Economic Area, UK, or Switzerland we ensure that appropriate legal protections are in place. These protections may include a transfer mechanism such as the Standard Contractual Clauses approved by the European Commission. In the event of any conflict between the terms of this Policy and such transfer mechanism, the terms of the transfer mechanism will govern.

Data Privacy Framework

OpenGlass complies with the EU-U.S. Data Privacy Framework (DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF as set forth by the U.S. Department of Commerce. We have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. DPF Principles, the UK Extension to the EU-U.S DPF and the Swiss-U.S. DPF Principles (collectively, the Principles) with regard to the Processing of Personal Data received from the European Union, the United Kingdom (and Gibraltar), and Switzerland. If there is any conflict between the terms in this Policy and the Principles, the Principles shall govern.

OpenGlass is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). We may be liable if we fail to meet the requirements of the DPF in the onward transfers of Personal Data to third parties. To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/. For unresolved EU-U.S, the UK Extension to the EU-U.S. or Swiss-U.S. DPF complaints or concerns that we have not addressed satisfactorily or in a timely manner, you may contact the International Centre for Dispute Resolution/American Arbitration Association (ICDR/AAA) at https://go.adr.org/dpf_irm.html. Binding arbitration may be available for complaint resolution under certain circumstances. Learn more about the binding arbitration scheme for the EU-U.S. DPF at and for the Swiss-U.S. DPF at https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-sw-dpf.

Self-regulation initiatives

OpenGlass supports efforts for self-regulation in the digital advertising industry. We adhere to the NAI Code of Conduct and also participate in the IAB’s Transparency & Consent Framework and comply with its specifications and policies.

Data Retention

We retain Personal Data only for as long as necessary to fulfill the purposes described in this Policy or as required to meet legal or regulatory requirements. At your request, we will delete your Personal Data unless we are required to retain it to meet our legal or regulatory obligations. We may also create and retain anonymized information, and continue to use this information in accordance with this Policy.

Data security

We understand that the security, integrity, and confidentiality of Personal Data is a critical issue and we are committed to safeguarding your Personal Data. We have implemented a comprehensive security program that includes technical, administrative, and physical security measures to protect your information from unauthorized access, disclosure, use, and modification. Such measures include but are not limited to: encryption, controls that limit the access of your data, both technically and at our physical data center locations, and also by enabling information security practices such as employee training on the safe handling of Personal Data. We regularly review our security policies and procedures to ensure the protection of your information. Please keep in mind that, despite our best efforts, no security measures are perfect or impenetrable.

Changes to this Policy

We may update this Policy from time to time to accommodate new technologies, industry practices, regulatory requirements or for other purposes. The date at the top of this Policy reflects the most recent changes made. If any changes to this Policy are significant, we may take additional measures to inform you, as required by applicable data protection and privacy laws. We encourage you to review this Policy for the latest information on our privacy practices and to contact us if you have any questions or concerns.

Contact us

If you have any questions, concerns, or complaints about the above or our privacy practices, please contact us at support@openglass.tv

or at:

Attn: OpenGlass Inc.
c/o Privacy
447 Broadway
2nd FL #678
New York, NY 10013