Bold Screen Media, LLC (“Bold Collective,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, sell, and share information in connection with our advertising technology services and related business operations.
This policy applies to information we process through the HBX exchange, our Forage curation service, our ad serving and measurement technologies, and this website. It covers information we receive from publishers, supply partners, advertisers, demand partners, and other participants in the digital advertising ecosystem, located primarily in the United States.
Notice at Collection. For purposes of the CCPA, this Privacy Policy also serves as our Notice at Collection. Sections 02, 03, 04, and 06 identify the categories of personal information we collect, the purposes for which we use each category, whether each category is sold or shared, and how long we retain it. We provide this notice at or before the point at which we collect personal information, and we do not collect categories of personal information, or use them for purposes, other than those disclosed here without first providing an updated notice.
Alternative formats. If you use assistive technology and need this policy in an alternative accessible format, contact us at privacy@boldcollective.co and we will provide one at no charge.
Bold Collective operates HBX, a programmatic exchange for audio and video advertising, and Forage, an inventory curation service. We connect publishers and supply partners with advertisers and demand-side platforms.
Our role under U.S. state privacy laws depends on the specific data flow:
Where we act as a business, the rights and opt-out mechanisms described in Sections 05 through 08 apply to us directly. Where we act as a service provider, we assist our clients in responding to requests they receive.
We collect, receive, or process the following categories of information:
| Category | Examples | CCPA statutory category |
|---|---|---|
| Online and device identifiers | Cookie IDs, browser IDs, mobile advertising IDs (Apple IDFA, Google GAID), CTV and connected device IDs, publisher-provided pseudonymous IDs | Identifiers |
| Network and device information | IP address, user agent string, operating system, browser type, device type, screen resolution, connection and carrier information | Identifiers; Internet or network activity |
| Advertising activity | Ad requests, impressions, bids, clicks, completions, viewability and listen-through events, frequency data | Internet or network activity |
| Approximate location | City, state, postal code, or region derived from IP address or other non-precise signals | Geolocation data |
| Audience and interest data | Inferred audience segments, interest categories, and contextual classifications | Inferences; Commercial information |
| Cross-device and identity graph data | Probabilistic or deterministic associations between browsers, devices, and identifiers, used for frequency capping, measurement, and attribution | Identifiers; Inferences |
| Business contact information | Names, titles, business email addresses, and phone numbers of employees of our publisher, advertiser, and partner organizations | Identifiers; Professional information |
We do not collect directly identifying information such as consumer names, personal email addresses, or phone numbers from users browsing publisher properties.
Please note that under the CCPA and comparable state laws, “personal information” is defined broadly and expressly includes unique identifiers, IP addresses, device identifiers, and inferences drawn from them. Information that does not identify you by name is still personal information under these laws, and the rights described in this policy apply to it.
We collect the information above from:
We use the information we collect for the following business and commercial purposes:
We do not use personal information for any purpose that is incompatible with the purposes disclosed here, and we do not retain it longer than reasonably necessary for those purposes.
Under the CCPA, “sale” means disclosing personal information for monetary or other valuable consideration, and “sharing” means disclosing personal information for cross-context behavioral advertising. These are broad legal definitions that cover routine programmatic advertising activity.
We sell and share personal information as those terms are defined by the CCPA and comparable state laws. When an ad request flows through HBX, we transmit identifiers, device and network information, approximate location, and advertising activity data to demand partners so they may bid on and target advertising. This constitutes selling and sharing under these laws.
You have the right to opt out. See Section 05.
| Category | Sold or shared? | Recipients |
|---|---|---|
| Online and device identifiers | Yes | Demand-side platforms, advertisers, agencies, measurement vendors |
| Network and device information | Yes | Demand-side platforms, advertisers, agencies, measurement vendors |
| Advertising activity | Yes | Demand-side platforms, advertisers, agencies, measurement vendors |
| Approximate location | Yes | Demand-side platforms, advertisers, agencies |
| Audience and interest data | Yes | Demand-side platforms, advertisers, agencies |
| Cross-device and identity graph data | Yes | Demand-side platforms, measurement and attribution vendors |
| Business contact information | No | — |
Separately from the sales and sharing described above, we disclosed the following categories of personal information for business purposes to the categories of recipients listed:
| Category | Disclosed to | Business purpose |
|---|---|---|
| Online and device identifiers | Cloud hosting and storage providers; fraud and IVT prevention vendors | Service provision, security, fraud detection |
| Network and device information | Cloud hosting and storage providers; fraud and IVT prevention vendors | Service provision, security, fraud detection |
| Advertising activity | Cloud hosting and storage providers; analytics and reporting vendors; publishers and supply partners | Service provision, delivery and revenue reporting |
| Approximate location | Cloud hosting and storage providers | Service provision |
| Audience and interest data | Cloud hosting and storage providers | Service provision |
| Cross-device and identity graph data | Cloud hosting and storage providers | Service provision, frequency capping, measurement |
| Business contact information | Cloud hosting, CRM, billing, and communications providers | Service provision, account management, billing |
We also disclose personal information in ways that are not sales or sharing:
Do Not Sell or Share My Personal Information
Because we operate as an intermediary and do not have a direct relationship with the individuals whose information flows through HBX, you can exercise your opt-out through any of the following:
We will not require you to create an account to exercise this right, and we will honor a valid opt-out within 15 business days of receipt.
We retain personal information only as long as reasonably necessary for the purposes described in this policy. Our retention periods by category are:
| Category | Retention period |
|---|---|
| Online and device identifiers | 13 months from last activity |
| Network and device information | 13 months from collection |
| Advertising activity (logs) | 13 months from collection |
| Approximate location | 13 months from collection |
| Audience and interest data | 90 days from last refresh |
| Cross-device and identity graph data | 13 months from last observation |
| Aggregated and de-identified reporting | Retained indefinitely; no longer personal information |
| Business contact information | Duration of the business relationship plus 3 years |
We may retain information beyond these periods where necessary to detect and investigate fraud or security incidents, to comply with legal obligations, or to establish, exercise, or defend legal claims.
Depending on your state of residence, you may have the following rights. These apply where we act as a business or controller.
Submitting a request. Email privacy@boldcollective.co or use our request form at privacy@boldcollective.co.
What we need. Because we do not hold your name, email address, or phone number, we generally cannot connect a request to your information without a relevant identifier — such as a cookie ID, mobile advertising ID, or device ID. We will explain how to supply this when you contact us. This limitation is a function of how our systems work, not a barrier we impose, and we will not ask you for information beyond what is necessary to locate your data.
Verification. We take reasonable steps to verify your identity or the identifier you provide before acting on a request to know, delete, or correct. Opt-out requests do not require verification.
Timing. We confirm receipt within 10 business days and respond substantively within 45 calendar days. If we need more time, we will notify you and may extend by an additional 45 days.
Authorized agents. You may designate an authorized agent to submit requests on your behalf. We may require written proof of the agent’s authority and, where permitted, verification of your identity.
Appeals. If we decline your request, you may appeal by replying to our response or emailing privacy@boldcollective.co with “Appeal” in the subject line. We will review and respond in writing within 45 calendar days, or within the period required by your state’s law. If we deny your appeal, we will provide information about how to submit a complaint to your state attorney general or privacy regulator.
We do not intentionally collect, use, or disclose sensitive personal information as defined by the CCPA and comparable state laws. Specifically:
We do not use or disclose sensitive personal information for purposes that would trigger a right to limit under the CCPA. If this changes, we will update this policy and provide the required “Limit the Use of My Sensitive Personal Information” control.
We produce aggregated and de-identified information — including campaign reporting, inventory analytics, and benchmark data — that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or device.
Where we use such information, we publicly commit to the following: we maintain and use it only in de-identified form; we do not attempt to reidentify it; and we contractually obligate any recipient of it to comply with the same restrictions. We treat de-identified and aggregated information as outside the scope of the rights described in Section 07, consistent with applicable law.
Our services operate within a broader advertising ecosystem. The publishers whose properties you visit, the advertisers whose ads you see, and the demand-side platforms and vendors that receive information through HBX each maintain their own privacy policies and make their own decisions about how they collect and use information. This Privacy Policy describes only our practices.
We are not responsible for the privacy practices, content, or compliance of those third parties, and exercising a right with us does not exercise it with them. If you want to understand or limit how a publisher, advertiser, or platform handles your information, contact that party directly or use the controls it provides.
Where we act as a service provider or processor for a client, as described in Section 01, that client is the business or controller for the information in question. Requests concerning that information should be directed to the client, and we will assist them in responding as our contract with them requires. If you send such a request to us, we will tell you so and, where we are able to identify the relevant client, refer the request to them.
Our advertising systems use cookies and similar local storage technologies to enable ad delivery, frequency capping, measurement, and analytics.
This website. Separately from our advertising systems, boldcollective.co uses Google Analytics to understand how the site is used. Analytics cookies are set only after you accept the cookie notice — we apply Google Consent Mode, so storage remains denied until you do. You can change or withdraw that choice at any time via Cookie settings in the footer. We also honor the Global Privacy Control on this website. Declining does not affect any part of the site.
We maintain administrative, technical, and physical safeguards designed to protect the information we process against unauthorized access, loss, misuse, disclosure, or alteration. No system can guarantee perfect security, but we review and improve our controls on an ongoing basis and in line with industry standards.
Our services are not directed to children. We do not knowingly collect personal information from children under 16 years of age.
Consistent with the CCPA, we do not knowingly sell or share the personal information of consumers we know to be under 16 years of age without affirmative opt-in consent — from the consumer directly if they are between 13 and 16, or from a parent or guardian if they are under 13. We rely on our publishers and supply partners to identify child-directed inventory and to transmit the appropriate signals, and our agreements require them to do so.
If we become aware that we have collected personal information from a child, we will delete it.
California Civil Code Section 1798.83 permits California residents to request information about the disclosure of personal information to third parties for those third parties’ own direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes. To make an inquiry under this section, contact us at privacy@boldcollective.co.
This Privacy Policy describes our advertising operations and does not cover personal information we collect from our employees, job applicants, or contractors in the context of that relationship.
California employees, applicants, and contractors hold the same rights described in Section 07 with respect to their personal information. To exercise those rights, or to request the notice applicable to that information, contact privacy@boldcollective.co.
Personal information about employees of our publisher, advertiser, and partner organizations, collected in a business-to-business context, is covered by this Privacy Policy. Those individuals hold the rights described in Section 07.
We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date above. We review and update this policy at least once every 12 months. If we make material changes, we will provide notice to partners or post a prominent notice on this site.
Bold Screen Media, LLC
Attn: Privacy Team
2060-D East Avenida de Los Arboles #289
Thousand Oaks, CA 91362
privacy@boldcollective.co