Privacy Policy

Effective Date: April 29, 2025

Premion, LLC (“Premion” “we,” “us” or “our”) provides solutions for advertisers to manage digital advertising campaigns across “over-the-top” and connected TV streaming platforms. This “Privacy Policy” describes our data practices for personal information we collect through our websites and emails (collectively, “Website”) and in connection with our advertising technology solutions used by our clients, including the Octillion DSP (“Platform”) (collectively, the “Services”). Except as expressly provided in this Privacy Policy, it does not apply to information you provide to us offline or through other means.

California Notice at Collection. California residents can find important information regarding the personal information we collect and their privacy rights in the Your Privacy Rights section below.

Table of Contents

Personal Information We Collect

Information collected through the Website. 

We collect some or all of the following types of personal information about you that you provide to us when you use the Website:

  • Contact data, such as your first and last name, email address, mailing addresses, phone number, professional title and/or company name.
  • Registration or log-in data, such as information that you submit when you access and use certain features of our Website (e.g., our Platform).
  • Communications that we exchange when you contact us with questions, feedback, or otherwise.
  • Marketing data, such as the email address or contact details that we use to send marketing communications to you, your marketing preferences, and information about your responses to our marketing communications.
  • Other information. We may also collect other categories of personal information for uses in accordance with this Privacy Policy or otherwise described at the time of collection.

In addition, we automatically collect some or all of the following types of personal information from your device or browser when you use the Website:

  • Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers (e.g., Apple’s ID for Advertising or Google’s Advertising ID), general location information (such as city or state), and precise geolocation (if you permit our Services to access it from your device settings).
  • Online activity data, such as the website you visited before browsing to our Services, pages, or screens you viewed on the Services, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

Our automatic data collection is facilitated by cookies and other technologies. Cookies are small data files placed on your computer when you visit a site. We may set cookies when you use the Website to track user trends and patterns, help you navigate between pages efficiently, remember your preferences and generally improve your browsing experience. Cookies used on the Website may also be set by analytics service providers and advertising partners. In addition to cookies, the Website may use pixel tags (also known as web beacons and clear GIFs) to compile statistics about use of the Website, measure the success of our marketing campaigns, and indicate whether recipients of our emails open or click links within them.

Information collected in connection with the Platform. 

We collect and process personal information in connection with our Platform, specifically, data about users, households, devices, and ads, and where those ads are shown. The types of personal information we collect include:

  • Unique cookie identifiers
  • Mobile device advertising identifiers
  • IP addresses
  • Interest information stored and/or used on the Platform by clients and partners
  • Interest information we create
  • Other information about browsers and devices, such as type, version and settings
  • Location information based on IP address or latitude/longitude coordinates, if provided to us
  • Information about ads that are shown, such as which ads are shown to a device or user, where (which web page or app) they are shown, and at what time
  • Hashed email addresses and other identifying information (or information derived from such)
  • JavaScript objects and installed fonts

We receive this personal information from the following sources:

  • Advertisers and agencies, which may bring or collect their own information via features on our Platform (for example, that they collect on their own websites) that we then store and use on their behalf to enhance their advertising campaigns
  • Bid requests, which are sets of information that describe an ad space that is available to be filled. We get these requests from the “supply” side of the advertising ecosystem, meaning websites, apps, smart TVs, and others, as well as their agents. The requests contain information about the ad space, the device, and sometimes the user, including location information. They also usually have an ID that enables us to match the request with information we may already have.
  • Third-party suppliers, which provide us with information that we use to target and optimize advertising campaigns (for example, by personalizing ads).
  • Purveyors of connected TV devices and apps, which may send us information about the video content viewed on the device or app.
  • Pixels and cookies, which allow us to recognize web browsers across sites and over time, and therefore to record information about them over time.
  • Mobile device IDs, which are provided by the device operating systems, like Apple’s iOS and Google’s Android, for purposes of allowing mobile apps and their advertising partners to recognize a device over time. We use these IDs the same way we use cookies.
  • Mobile SDKs, which are bits of code that some of our partners enable to be placed in mobile apps. This enables our partners to send us data about the mobile app and device in association with the mobile device ID.
  • Network requests originating from the devices on which the ad was shown, which allows us to confirm that the ad was delivered and provide information for us to measure the ad.

Some of this personal information is processed on our own behalf, in which case we are a controller, and the personal information is treated in accordance with this Privacy Policy. Some of this personal information is processed for the benefit of a client, in which case we are a processor, and the personal information is treated in accordance with the client’s privacy policy. We are not responsible for how our clients treat the information we collect on their behalf, and we recommend you review their privacy policies to learn more about what they do with that data.

Data from other sources.

We may combine personal information from the Services with personal information we obtain from other sources, such as:

  • Content partners, such as internet streaming platforms and networks with which Premion has relationships, that provide us information about their streaming audiences’ devices and viewing activity, which we use to help our advertisers deliver advertising that is more likely to be relevant to their viewers’ interests.
  • Data providers, such as information services and data licensors.
  • Publicly-available sources, such as social media platforms.
  • Business partners, such as joint marketing partners and event co-sponsors.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

Service delivery. We may use your personal information to:

  • provide, operate, and improve the Services;
  • communicate with you about the Services, including by sending you announcements, updates, and support and administrative messages; and
  • provide support for the Services, and respond to your requests, questions, and feedback.

Operation of the Platform. We may use your personal information to:

  • Personalize ads and increase advertising relevancy and effectiveness.
  • Deliver advertising and measure the success of delivery.
  • Measure advertising frequency and other data, such as how many times an ad was shown, as well as where and when it was shown.
  • Measure, attribute, and report on the performance and success of campaigns.
  • Measure actions taken by a user regarding a particular advertisement, such as whether they clicked on an advertisement, downloaded an app, or took other, subsequent actions, such as purchased the product marketing in the advertisement. (This is done by matching data collected from our platform with the advertiser’s own data and data from other companies. In doing so, we do not receive any data that allows us to identify the purchaser of the product.)
  • Associate devices that might be related to each other, such as devices used by the same person or in the same household.
  • Prevent malicious activity or invalid advertising traffic. This may include identifying and preventing purveyors of malware or bots that try to take advertising dollars for advertisements that aren’t shown to real users or that try to harm users’ devices.

Research and development. We may use your personal information to administer surveys and other market research and for other research and development purposes, including to analyze and improve the Services and our business. As part of these activities, we may create anonymous data (including aggregated and/or de-identified data) from personal information we collect. We convert personal information we collect into anonymous data by removing information that makes the data personally identifiable to you. We will maintain and use deidentified information in deidentified form and not attempt to reidentify it, except for purposes of testing to ensure that the information has been adequately deidentified. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

Marketing and Targeted Advertising. We may send you Premion-related and/or other marketing communications via email and other channels as permitted by law. We also work with third-party advertising partners that use cookies and other technologies to help us advertise our services. These advertisements are delivered by our advertising partners and may be targeted based on your geographic area and activity on the Services and other online services. To learn more about your choices in connection with advertisements, please see the section below titled Advertising choices.

Compliance and operations. We may use your personal information to:

  • operate our business;
  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
  • enforce the terms and conditions that govern the Services; and
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How We Share Your Personal Information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

  • Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
  • Service providers and vendors. Companies and individuals that provide services on our behalf or help us operate the Services or our business, such as customer service and support providers; technology providers (including technology support, web hosting providers, email and text communications providers, and mobile app developers); shipping and fulfillment service providers; survey and market research providers; advertising and marketing partners; and analytics services providers.
  • Platform partners. Third parties involved in the operation and/or delivery of our Platform, such as advertising technology platforms, inventory partners, content partners, and data providers.
  • Business partners. Third parties with which we co-sponsor events or promotions, with which we jointly offer products or services, or whose products or services may be of interest to you.
  • Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
  • Clients. The businesses and individuals that engage us for advertising services in connection with the services we provide to them.
  • Authorities and others. Law enforcement, government authorities, central banks and private parties, as we believe necessary or appropriate for the compliance and operations purposes described above.
  • Business transferees. Acquiring and other relevant parties (and their advisors) to business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business, assets, or equity interests in Premion (including, in connection with a bankruptcy or similar proceedings).

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties on our Services, that information may be seen, collected and used by others. We cannot be responsible for any unauthorized third-party use of such information.

Retention

The length of time we retain particular categories of personal information is determined based on whether it is sufficient to fulfill the purposes for which we collected it, including to satisfy legal, regulatory, accounting, or reporting requirements, establish or defend legal claims, enforce our agreements, resolve disputes or fraud prevention. We may either delete or anonymize personal information we no longer require.

Your Choices

Your privacy rights. You can make certain requests regarding your personal information as described in the section below entitled “Your Privacy Rights.” If your request relates to the services we provide on behalf of a client, please contact that client directly.

Opt-out of marketing emails. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive Services-related and other non-marketing emails.

Text message alerts. We may offer text news alerts for your phone or wireless device via short message service (“SMS”) or similar technology. You must register with us to receive this service, which may require providing us your name, telephone number, and other personal information. You can cancel or modify your alerts by accessing your account through the Services or by texting “STOP” to the number associated with the text news alert. Message and data rates may apply for this service.

Advertising choices. You can limit use of your information for targeted advertising by making a request as detailed in the section below entitled “Your Privacy Rights” or through the following means:

  • Browser settings. Blocking third party cookies in your browser settings.
  • Ad industry tools. Opting out of targeted ads from companies participating in the following industry opt-out programs:
  • Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for targeted advertising purposes.

You will need to apply these opt-out settings on each device and in each browser from which you wish to opt-out.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals except where we expressly indicate otherwise. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.

Cookies. Most browsers let you remove and/or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, our Services may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

Declining to provide information. We need to collect personal information to provide certain Services. If you do not provide the information requested, we may not be able to provide those Services.

Other Sites and Services

The Services may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or other online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions.

We also may make third-party partners’ content, products or services available through our Services, whereby our partners’ brands appear on the Services in connection with such content, products or services. We may share with our partners information you provide, or that is collected, in the course of visiting any pages that are made available in cooperation with our partner. In some cases, the partner may collect information from you directly, in which cases the privacy policy of our partner applies to the partner’s use of your information.

The privacy policy of our partners may differ from ours. If you have any questions regarding the privacy policy of one of our partners, you should contact the partner directly for more information.

Security

The security of your personal information is important to us. We employ organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International Data Transfers

Our Services are intended to be used only by residents of the United States.
We are headquartered in the United States, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective.

Children

Our services are not intended for children under the age of 16, and we do not knowingly collect any personal information from a child under 16. If we become aware that we have inadvertently received personal information from a user under the age of 16 as part of the Services, we will delete such information from our records.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will update the date of this Privacy Policy and post it on the applicable Service(s). Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

Your Privacy Rights

Residents of certain states have the rights described below under state privacy laws. However, we honor requests described in this section from all users of our digital properties who reside in the United States, regardless of your state of residence.

For purposes of this section, “personal information” has the meaning given to “personal data”, “personal information” or similar terms under the applicable privacy laws of the state in which you reside. Premion is the “controller” of your personal information covered by this Privacy Policy for purposes of applicable privacy laws.

If your request relates to the services we provide on behalf of a client, please contact that client directly.

You have the following rights:

  • Information. You have the right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting and any selling or sharing personal information, the categories of personal information that we sold or disclosed for a business purpose, and the categories of third parties to whom we disclosed, sold or shared the personal information.
  • Access. You can request a copy of certain personal information that we have collected about you in a structured, machine-readable and commonly used format.
  • Deletion. You can ask us to delete certain personal information that we maintain about you.
  • Correction. You can ask us to correct inaccurate personal information that we maintain about you.
  • Opt-out of tracking for targeted advertising purposes. You can opt-out of certain processing of your personal information for targeted advertising purposes. California law classifies our use of some targeted advertising services as “sharing” of your personal information with those services from which you have the right to opt-out. You can request to opt-out of this activity here. You can also turn on the Global Privacy Control (GPC) to opt out of the “sharing” of your personal information through websites in each participating browser that you use. Learn more at the Global Privacy Control website.
  • Opt-out of sales of personal information. You can opt-out of any sales of your personal information for monetary or other valuable consideration.
  • Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by applicable privacy laws.

How to Exercise Your Rights. You may exercise your privacy rights described above as follows:

Verification of Identity; Authorized Agents. We may need to verify your identity to process your information, access, deletion, and correction requests, and we reserve the right to confirm your residency. To verify your identity, we may require authentication into your account on the Services, government identification, a declaration under penalty of perjury or other information, where permitted by law. Furthermore, your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to applicable state law. If you have not provided your agent with such a power of attorney, we may ask you and/or your agent to take additional steps permitted by law to verify that your request is authorized, such as information required to verify your identity and that you have given the authorized agent permission to submit the request.

The rights described above are subject to exemptions and, in certain cases, we may decline your request as permitted by law. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. You can ask to appeal any denial of your request in the same manner through which you may submit a request.

Additional Information for California Residents

This section provides disclosures required by California law about information practices currently and during the past 12 months.

Personal Information that We Collect, Use and Disclose. The list below summarizes our collection, use and disclosure practices for each category of personal information listed above in the Personal Information We Collect section. We may also disclose personal information to professional advisors, authorities and others, and business transferees as described above in the How We Share Your Personal Information section of this Privacy Policy. 

Contact Data

  • Sources: You
  • Purposes: Service delivery, Research and development, Marketing, Compliance and operations
  • Third parties to whom we disclose for business purposes: Affiliates, Business partners, Service providers
  • Third parties with whom we share for targeted advertising: Advertising partners

Registration Data

  • Sources: You
  • Purposes: Service delivery, Research and development, Marketing, Compliance and operations
  • Third parties with whom we disclose for business purposes: Affiliates, Business partners, Service providers
  • Third parties with whom we share for targeted advertising: None

Communications

  • Sources: You
  • Purposes: Service delivery, Research and development, Marketing, Compliance and operations
  • Third parties with whom we disclose for business purposes: Affiliates, Business partners, Service providers
  • Third parties with whom we share for targeted advertising: None

Marketing Data

  • Sources: You, Automatic collection
  • Purposes: Service delivery, Research and development, Marketing, Compliance and operations
  • Third parties with whom we disclose for business purposes: Affiliates, Business partners, Service providers
  • Third parties with whom we share for targeted advertising: Advertising partners

Device Data

  • Sources: You, Automatic collection
  • Purposes: Service delivery, Research and development, Marketing, Compliance and operations
  • Third parties with whom we disclose for business purposes: Affiliates, Service Providers
  • Third parties with whom we share for targeted advertising: Advertising partners

Online Activity Data

  • Sources: You, Automatic collection
  • Purposes: Service delivery, Research and development, Marketing, Compliance and operations
  • Third parties with whom we disclose for business purposes: Affiliates, Business partners, Service providers
  • Third parties with whom we share for targeted advertising: Advertising partners

Data Derived from the Above Listed Information

  • Sources: May be derived from the information listed above
  • Purposes: Service delivery, Research and development, Marketing, Compliance and operations
  • Third parties with whom we disclose for business purposes: Affiliates, Service Providers
  • Third parties with whom we share for targeted advertising: Advertising partners

California Categories of Personal Information. California law requires that we describe to California residents the categories of personal information we collect by reference to certain categories described in Cal. Civ. Code Section 1798.140(v). All categories described in this Privacy Policy include “identifiers” and “customer records”, Registration Data includes “commercial information”, Device Data and Online Activity Data include “internet or other electronic network activity information”; any credentials you use to access the Service and your device’s precise geolocation are “sensitive personal information”; and Data Derived from the Above Listed Information includes “inferences”.

Sale of Personal Information/Use of Sensitive Personal Information. We do not sell personal information of California residents as “sell” is defined under the California Consumer Privacy Act, except to the extent that the “sharing” of personal information for targeted advertising described above constitutes a “sale” of personal information. We do not use or disclose sensitive personal information (as defined under the California Consumer Privacy Act) of California residents for purposes subject to consumer limitation rights under the California Consumer Privacy Act. We do not have actual knowledge that we have sold or shared the personal information of California residents under 16 years of age.

Shine the Light / Your California Privacy Rights. Under California’s Shine the Light Law (California Civil Code Section 1798.83), California residents may also ask companies with whom you have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined in the Shine the Light Law) during the preceding year for their own direct marketing purposes. California residents may send requests for this information to privacy@tegna.com. For all requests, you must put the statement “Shine the Light Request” in the body of your request, and provide your first and last name. Please also indicate in your request the name of the website or other digital service to which your request applies. We are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Additional Information for Oregon Residents

Oregon residents can request a list of specific third parties, other than natural persons, to which we have disclosed personal information. The list we provide may be limited to the third parties to which we have disclosed your personal information. You can submit this request by following the instructions in the How to Exercise Your Rights section above. 

How to Contact Us

Please direct any questions or comments to:

TEGNA Inc.
8350 Broad Street
Suite 2000
Tysons, VA 22102
Attention: Legal Department (Privacy)
Email: privacy@tegna.com