Last Reviewed and Effective: June 13, 2023

Safe Exchange Inc. (“SEI”, “we”, “us” or “our”) respects your privacy. This Privacy Policy describes how we collect, use and share personal information. This Privacy Policy applies to this website, our direct interactions with you and our adtech service (“Safe Exchange”) (collectively, our “Services”). 

Please read this Privacy Policy carefully. If you have any questions about this Privacy Policy, please contact us at privacy@safex.tv. If you do not agree to the terms of this Privacy Policy, please do not use our Services. From time to time, we may update this Privacy Policy. When we review or update the Privacy Policy, we will also update the date listed above. The updated policy is effective as of that date. 

Safe Exchange is designed to provide ad content that is appropriate to a specific audience.  For more information about our privacy practices when that audience includes children, please click here.

Personal Information that We Collect

Personal information is any information that can be used to identify you or could be reasonably linked to you. It does not include information that has been deidentified or aggregate information. 

The type of personal information we collect from and about you will depend on our relationship with you and how you interact with our Services. 

When you engage with us directly, such as by visiting our website, completing a “contact us” form or purchasing Safe Exchange ad services, we may collect the following categories of personal information from you: 

• Identifying Information, including your name, email address, phone number, job title, company name.
• Commercial Information, including products you purchased or a record of your inquiries.
• Financial Information, including payment information.
• Technical Information, including internet protocol (“IP”) address, cookies, java script, web beacons, clear gifs, HTTP headers, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Services.
• Usage Data on how you navigate our website, including the content and features you use or view on the website, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
• Marketing and Communications Data, including your communication preferences in receiving information from us. 

When you engage with Safe Exchange, we may collect limited technical information, including internet protocol (“IP”) address, device ID, browser type and version, location, operating system and platform, and other technology on the devices you use to access our Service.

How We Use Personal Information

When we collect your personal information directly from you, we may use it for the following business purposes: 

• To sell you our products; 
• To market our products; 
• To respond to your questions and inquiries;
• To process payments; 
• To perform analytics; 
• To enforce our Terms and Conditions or other contractual agreement(s) with you, and protect the security and integrity of our Services; 
• To pursue legitimate interests, such as improving our products, development of new products or processing for statistical purposes; and 
• To fulfill our legal obligations under applicable law, regulation, court order or other legal process.

The limited information that we collect when you engage with Safe Exchange Services may be used for these additional business purposes: 

• To perform or provide analytics, including confirming ad placement in a particular program; 
• To reconcile ad sales and ad performance; and
• To troubleshoot technical issues. 

Disclosure of Personal Information

When we have collected information from you directly, we may disclose it for the business purposes listed above to the following entities: 

• Our subsidiaries and affiliates; 
• Our service providers that support us in providing our Services; 
• Our marketing partners; 
• Our third party analytics providers in order to improve the functionality and features of our Services; 
• Our third party marketplace partners;
• Other entities as permitted by law, in the event of a transfer of ownership or assets, in the event of bankruptcy, where needed to comply with the request of law enforcement or a regulatory agency or other legal process, or to protect our interests or the safety of our Services.

Additionally, the information that we collect through Safe Exchange may be disclosed to our ad partners. 

Your Consumer Rights

You have the following rights to your personal information: 

• To be informed about the personal information we process about you.
• To access that personal information.
• To transfer that personal information in certain circumstances.
• To correct your personal information if it is inaccurate or incomplete.
• To delete your personal information, subject to certain exceptions.
• To restrict processing in certain situations. 
• The right to opt-out of the sale or sharing of personal information by the business; and
• The right not to receive discriminatory treatment if you exercise your privacy rights.

Children’s Information

Safe Exchange is designed to provide ads that are appropriate for a designated audience. When an ad partner identifies advertising inventory that is within child-directed content or where the ad partner signals that the advertising inventory includes children, we implement additional privacy protocols to protect a child’s information, and we do not provide personal information about the ad viewer to our ad partners. Only anonymized ad analytics are provided, and we do not use persistent identifiers that can recognize a user over time and across different websites.  

We do not sell or share children’s personal information. 

Security Of Personal Information

The security of your personal information is important to us. We have in place commercially reasonable physical, technical, organizational and administrative safeguards appropriate to the type of personal information we process to protect the security and privacy of your personal information. While we strive to use commercially acceptable means to protect your personal information, no business can fully eliminate the security risks associated with collecting and processing information via the internet. 

Digital Technologies

Our website uses a variety of digital technologies, including cookies, web beacons, pixels, and cookies to automatically collect information about how our website used.  Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.  A pixel tag (also known as a web beacon) is a piece of code embedded in our website that collects information about how you engage with our website.  The use of a pixel tag allows us to see that a user has used a certain feature of our website. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded. 

You can set your browser not to accept cookies or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. Certain features of our website may not function properly if cookies are rejected or deactivated. 

Information for Individuals located in the EEA and UK 

The information in this section will apply if you are located in the European Economic Area or United Kingdom.

Lawful Basis

We will only process your personal information if we have a lawful basis to do so. The lawful bases that we rely upon are: 

• Our legitimate interest;
• Your consent;
• Legal obligation; or 
• Contractual obligation. 

International Transfers

We are an international company that is based in Canada. Your personal information may be transferred outside of the country where you are located.  We may also store your personal information outside of the EEA or UK. 

Contact Us

If you have any questions about this Privacy Policy, please contact us by email: privacy@safex.tv or phone: 1-888-495-4320