1.About Us

Tangelo offers Services that connect buyers of advertising inventory (which we refer to as advertisers) with sellers of advertising inventory (which we refer to as publishers), to enable buyers to display advertisements on sellers’ Internet-connected devices and platforms, including internet-connected TV or over-the-top (known as “CTV” and “OTT” respectively) or other digital platforms (collectively “Digital Media Properties”) . In this policy, we refer to the advertisers and publishers collectively as “Clients”.

 

2.User Information that We Receive

We do not collect information that directly identifies an individual, such as name, address, phone number, or email address.

When you view an advertisement distributed through our Services on relevant Digital Media Properties, certain information on your device and your interaction with the advertisement (collectively, “User Information”) may be transferred by the publishers to us. User Information may be considered pseudonymized or de-identified “personal data” or “personal information” in some jurisdictions.

User Information that we may receive from publishers include such as your IP address, device identifiers and device-related information. We describe these data elements in detail in “Information We Collect, Use, Disclose, and the Purposes for such Disclosure”.

 

3.Use of User Information

User Information helps us to recognize a particular device without knowing the identity of the user of that device and enable us, our Clients, and our partners (such as third party advertising platforms) to select appropriate advertisements to display to you.

We and our Clients use User Information to guide decisions on buying and selling advertising space on Digital Media Properties. This data, which may also be combined with information from third-party services, helps deliver targeted ads that our Clients believe will interest specific users.

Specifically, we may use User Information to analyze the cost-effectiveness of different ad types to maximize revenue for our Clients, but our analysis isn't aimed at individuals but focuses on common factors like cities, ad formats and TV content preferences. For instance, we look at which cities have higher ad performance on startup screens or which programs have better ad returns. We might also analyze your User Information to detect, deter and prevent fraud, fraudulent traffic or to protect the security of our systems.

 

4.Information We Collect, Use, Disclose, and the Purposes for such Disclosure

4.1.What User Information Do We Collect

(a) Device identifiers. Device identifiers are alphanumeric strings that are unique to your device. These include:

• Identifier for Advertising on OTT and CTV platforms

• Cookie IDs

(b) Location information, including:

Geo-location or precise location of your device if you have given the app or site permission to collect your location information.

Typically, we do not infer location from WiFi identifiers that your device is connected to. To the extent that we do so, it is with express consent, where required by law or similar regulatory orders.

Location information we infer from your device’s IP address, provided that we will not infer location from an IP address to a more precise than city-level of accuracy unless you have given the app or site permission to collect your location information.

(c) Network information, including:

• Network provider or ISP

• Network type (e.g., WiFi or cellular)

• IP address

• IDs of WiFi access points to which your device is connected

• Date and time of connection

(d) Information about apps or sites, including:

• App or site name or version

• App identifier

• Other information about/on your device, including:

• Device type (e.g., make and model)

• Device startup time and update time

• Device name

• Screen size

• CTV browser used (e.g., Chrome, Safari, Firefox)

• Language settings (including country code) and time zone

• App usage

(e) Advertisement information. We collect information about the ad presented on your device, including:

• The content type of the ad (the advertiser and category, e.g. games, finance, entertainment, news)

• The ad type (e.g. whether the ad is a text, image, video or other format based)

• Where the ad is being served (e.g. the site, digital media or app on which the ad appears)

• Whether you viewed, clicked or otherwise interacted with the ad

​​

4.2.How Do We Use Your User Information

We use the User Information that we receive from publishers to:

1. Display advertisements on your device, which may include interest-based advertising customized to your interests, preferences, locations;

2. For remarketing or retargeting i.e. to display relevant ads if you have previously used a Digital Media Property that we partner with;

3. For bidding to serve advertisements and to determine which ads are most effective;

4. Analyze and provide our Clients with reports on the effectiveness of advertisements and campaigns, including across different types of devices based on our determination of devices that are related to the same person. We, or third parties whom we engage to provide this service, may use cross-device data to provide interest-based advertising services and to deliver tailored ads to users across multiple CTV and OTT devices;

5. Avoid showing you the same ads too many times;

6. Build custom audience segments to enable our Clients and partners better target their advertisements and offers;

7. Improve our Services and assist our Clients and partners in improving their products and services;

8. Detect, deter and prevent fraud, fraudulent traffic or to protect the security of our systems.

 

4.3.Who Do We Share User Information With

We may share User Information:

1. With our Clients;

2. With Tangelo Affiliates;

3. With our vendors and service providers;

4. With our Partners;

5. In connection with a business transfer;

6. With law enforcement or other authorities in legal proceedings;

7. To protect the rights of Tangelo or others.

 

5.International Data Transfers

In connection with our Services, your User Information may be transferred to, and processed by Tangelo, its Clients, affiliates, service providers, and partners in countries other than the country in which you are resident, including in Hong Kong SAR, China, Singapore and other countries/regions where these recipients are located. These countries may have data protection laws that are different from the laws of your country of residence and may not provide the same level of protection as your jurisdiction. Regardless of where your data is located, Tangelo shall process and protect your User Information in accordance with this Privacy Policy.

 

6.Your Privacy Rights and Choices

6.1.Opt-Out

Depending on where you live, certain activities described in “Information We Collect, Use, Disclose, and the Purposes for such Disclosure” may constitute “sharing” “selling” or processing of User Information for purposes of “targeted advertising” as such terms are defined under certain privacy laws. Depending on the relevant privacy law requirements and the Digital Media Properties that you interact with, you may opt out of relevant User Information processing activities by us.

If you opt-out of interest-based ads on your CTV or OTT TV device, your advertising ID will not be used to build profiles or target you with interest-based ads and it is likely that you will get irrelevant ads which are not tailored to your interest. To disable interest-based ads, please review your CTV or OTT TV’s settings menu. You may also visit https://thenai.org/opt-out/connected-tv-choices/ for more guidance (this link is provided for educational purposes only).

Note that because these opt outs are specific to the device or browser on which they are exercised, you will need to opt out on each browser and device.

6.2.Access, Deletion, Correction, Portability, Withdrawal of consent

In addition, depending on where you reside and other legal limitations, you may have the right to (i) request to know more about and access the categories and specific pieces of User Information we collect, use, and disclose, (ii) request deletion or restriction of your personal information, (iii) request correction of inaccurate personal information, (iv) obtain your User Information in a portable format and/or (v) if the processing of User Information is based on your consent, withdraw your consent at any time

If you would like to exercise any of these rights, please contact us by our contact details described in “Contact Us”.

We will not discriminate against you for exercising these rights. Note that when you exercise your rights, we may ask for additional information to verify your request. 

 

7.Additional Information for Residents of Certain U.S. States

Certain states, including California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia, have enacted consumer privacy laws that grant their residents certain rights and require additional disclosures (“State Privacy Laws”). If you are a resident of a state governed by a State Privacy Law this section applies to you. This section also serves as our California Notice at Collection. As a reminder, disclosures do not apply to the extent we act as a service provider or processor to our clients. In such cases, you must visit the privacy policies of our clients to understand how data is processed about you and to exercise your rights.

This policy explains how we collect (including the sources of collection), use, disclose, and retain information about you in connection with our platforms. As required by certain State Privacy Laws, please refer to “Information We Collect, Use, Disclose, and the Purposes for such Disclosure” to explain this same information, including the categories of personal information we collect, the types of entities to which we disclose it, and the ways we use each category of information. The relevant section explains our practices today and over the preceding 12 months.

In some cases, we may de-identify personal information so that it no longer identifies you and use this information for purposes like analyzing the effectiveness of the Services. We will use this information in de-identified form and we will not attempt to reidentify it, unless required by law.

We do not knowingly sell or share personal information about consumers under the age of 16, or the permitted legal age, where older.

 

8.Information Retention

We store the User Information we collect for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

We typically store the User Information we collect from your device, such as IP address and other information described above, in our systems for up to thirteen (13) months before we anonymize and aggregate that data into summary reports.

 

9.Security

We use industry-standard technical and organizational security measures to help protect information transmitted over or stored on our systems. Please note, however, that no transmission or storage of information can ever be guaranteed to be completely secure.

 

10.Changes to this Policy

We may update this policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. If we make material changes to this policy, we will notify you of any material changes by posting the revised policy on this website, and where necessary, by any other means required by applicable law.

​

11.Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at privacy@superctv.com or by post using the details provided below:

RM. 2, 3/F., Ruby Commercial Building, 480 Nathan Road, Kowloon, Hong Kong, China