Privacy Policy

Last Updated 12/31/2023

ClearTrust Media, LLC. (hereinafter referred to as “ClearTrust Media”, “we”, “us” or “our”) operates a platform and community marketplace that helps people form relationships directly with one another to buy and sell units of time that display advertising content on billboards around the world, whether through our website or our mobile applications (“Platform”).

This Privacy Policy is intended to inform you about how we treat Personal Information that we process about you. If you do not agree to any part of this Privacy Policy, then we cannot provide the Platform or Services to you, and you should stop accessing the Platform and deactivate your ClearTrust Media Account. You can find out more about how to deactivate your ClearTrust Media Account by emailing us at support@cleartrustmedia.com.

DEFINITIONS

Where the definition of a term does not appear in this Privacy Policy (such as “Screen Details”, “Campaign”, “Content,” “Services” etc.), it shall be given its definition as outlined in our Terms of Service.

“Affiliates” means companies related by common ownership or control. They can be financial and non-financial companies.

“Aggregated Information” means information about all of our users or specific groups or categories of users that we combine together so that it no longer identifies or references an individual user.

“Data Controller” means ClearTrust Media, the company responsible for the use and processing of Personal Information.

“Third Parties” means companies or persons not related by common ownership or control (i.e. non-affiliates) or other unrelated individuals. Third Parties can be financial and non-financial companies, or persons other than you and ClearTrust Media.

“Personal Information” means information (which may include sensitive information) relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.

WHAT TYPES OF INFORMATION DOES CLEARTRUST MEDIA GATHER ABOUT ITS USERS?

  1. Information that you give us

We receive, store and process information, including Personal Information, that you make available to us when accessing or using our Platform and Services. Examples include when you:

  • fill in any form on the Platform, such as when you register or update the details of your user account;
  • access or use the Platform, such as to search for or post Billboards, make or accept Campaigns, pay for Campaigns, book or pay for any associated services that may be available, or communicate with other users;
  • communicate with ClearTrust Media; and
  • share information with another User.
  1. Information we get from your use of our Platform

We also receive, store and process information, possibly including Personal Information, when you access or use our Platform and Services, including but not limited to:

  • Mobile Data

When you use certain features of the Platform, in particular our mobile applications we may receive, store and process different types of information about your location, including general information (e.g. IP address, zip code) and more specific information (e.g. GPS-based functionality on mobile devices used to access the Platform or specific features of the platform). If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

  • Log Data

We may also receive, store and process Log Data, which is information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with ClearTrust Media or logged in to your ClearTrust Media Account, such as your IP Address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, device event information, pages viewed and the order of those pages, and the amount of time spent on particular pages.

  • Cookies and other Tracking Technologies

ClearTrust Media uses cookies and other similar technologies, such as mobile application and other device identifiers, on the Platform. We may also allow our business partners to use their cookies and other tracking technologies on the Platform. As a result, when you access or use the Platform, you will provide or make available certain information to us and to our business partners.

While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application. We track your activities if you click on advertisements for ClearTrust Media services on Third-Party platforms such as search engines and social networks, and may use analytics to track what you do in response to those advertisements.

We may, either directly or through Third Parties we engage to provide services to us, also continue to track your behavior on our own Platform for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the Platform and pay for your activities on the Platform. We may also, either directly or through Third-Parties we engage to provide services to us, track your behavior on our own Platform to market and advertise our services to you on the Platform and Third-Party websites. Third Parties that use cookies and other tracking technologies to deliver targeted advertisements on our Platform and/or Third-Party websites may offer you a way to prevent such targeted advertisements by opting-out at the websites of industry groups such as the Network Advertising Initiative and/or the Digital Advertising Alliance. You may also be able to control advertising cookies provided by publishers, for example Google’s Ad Preference Manager. Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on or about the Platform – it just will not be tailored to your interests. In addition, if you disable cookies, you may lose some of the features and functionality of using our Platform, Application and Services, as cookies are necessary to track and enhance your use and access.

Third Parties may not collect information about users’ online activities on the Platform except as described in this policy and our Cookie Policy.

HOW CLEARTRUST MEDIA USES AND PROCESSES THE INFORMATION THAT YOU PROVIDE OR MAKE AVAILABLE

We use, store and process information about you for the following general purposes:

  • to enable you to access and use the Platform;
  • to enable you to communicate with other Users, including but not limited to by sending them messages or other information during the Campaign placement or Content Approval process;
  • to operate, protect, improve and optimize the Platform, ClearTrust Media’s business, and our users’ experience, such as to perform analytics, conduct research, personalize or otherwise customize your experience, and to provide customer service;
  • to help create and maintain a trusted and safer environment on the Platform and Services, such as detection and prevention of actual and potential fraud and other harmful activity, conducting investigations and risk assessments, enforcing our Terms and policies, conducting checks against databases and information sources (such as but not limited to public government databases) for fraud detection and prevention, risk assessment and harm prevention purposes. In this regard, we may do any or all of the foregoing with or without further notifying you;
  • to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
  • to send you marketing, advertising, and promotional messages and other information that may be of interest to you, including information about ClearTrust Media, our services, or general promotions for partner campaigns and services. You can unsubscribe or opt-out from receiving these communications in your settings (in the “Account Information” section) when you login to your ClearTrust Media Account;
  • to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with Third Parties.

WHAT ARE YOUR DATA PROTECTION RIGHTS?

ClearTrust Media would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request ClearTrust Media for copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that ClearTrust Media correct any information you believe is inaccurate. You also have the right to request Our Company to complete the information you believe is incomplete.

The right to erasure – You have the right to request that ClearTrust Media erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that ClearTrust Media restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to ClearTrust Media’s processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one week to respond to you. If you would like to exercise any of these rights, please contact us at our email: support@cleartrustmedia.com

Call us at: 1-617-584-4444

Or write to us: ClearTrust Media, LLC. 30 North Gould Street, Suite 12737, Sheridan, WY 82801.

WHEN CLEARTRUST MEDIA DISCLOSES OR SHARES YOUR PERSONAL INFORMATION, AND TO WHOM

IMPORTANT: When you use the Platform, your data may be sent to the United States and possibly other countries.

We may transfer, store, use and process your information, including any Personal Information, to countries outside of the European Economic Area (“EEA”) including the United States. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.

Your Personal Information may be disclosed as follows:

  1. Parts of your public profile page that contain some Personal Information may be displayed in other parts of the Platform to other users for marketing purposes or if you post content in a community forum or other features on the Platform that are visible to the public.
  2. Your public Billboard Details page will always include some minimum information such as the city where the Billboard is located, your billboard description and your calendar availability. Parts of your public Billboard Details page may be displayed in other parts of the Platform to other Members and/or Third-Party platforms for marketing purposes. The Platform may also display the Billboard’s approximate geographic location on a map, such that a user can see the general area of the Billboard.
  3. The Platform allows your public Billboard Details pages to be included in search engines, in which case your Billboard Details pages will be indexed by search engines and may be published as search results. We do not control the practices of Third-Party search engines, and they may use caches containing outdated information, including any information indexed by the search engine before you change your settings or the information on your public profile or public Listing pages.
  4. When you submit a Campaign to book one or more spots on a Billboard, your full name and your company name (if applicable) and other Personal Information will become visible to the Billboard Owner. We will not share your phone number and your billing and payout information will never be shared with another user.
  5. We may distribute parts of the Platform (including your Billboard Details Page) for display on sites operated by ClearTrust Media’s business partners and affiliates, using technologies such as HTML widgets. If and when your Billboard Details are displayed on a partner’s site, information from your public profile page may also be displayed.
  6. ClearTrust Media may provide your Personal Information to its Affiliates, including Stripe, and their employees, to use and process your Personal Information in the same way and to the same extent that we are permitted to under this Privacy Policy. These related entities comply with the same obligations that we have to protect your Personal Information under this Privacy Policy. You can unsubscribe or opt-out from receiving marketing communications in your settings (in the “Account” section) when you login to your ClearTrust Media account.
  7. You acknowledge, consent and agree that ClearTrust Media may access, preserve and disclose your account information and Collective Content if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary (a) to respond to claims asserted against ClearTrust Media; (b) to comply with legal process (for example, subpoenas and warrants); (c) to enforce and administer our agreements with users, such as the Terms of Service, the Payments Terms of Service, this Privacy Policy, and the Host Guarantee Terms and Conditions; (d) for fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes; or (e) to protect the rights, property or personal safety of ClearTrust Media, its users or members of the public.
  8. We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless:
  • providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; or
  • we believe that providing notice would (a) be futile, (b) be ineffective, or (c) would create a risk of injury or bodily harm to an individual or group, or (d) create or increase a risk of fraud upon ClearTrust Media’s property, its Members, the Platform, Application, or Services (collectively, “Risk Scenarios”).
  • In instances where ClearTrust Media complies with legal requests for user data without notice to the user for the reasons described above, ClearTrust Media will use commercially reasonable efforts to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply

    9.We may also publish, disclose and use Aggregated Information and non-personal information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

STATE PRIVACY LAWS

For California & Vermont residents: ClearTrust Media will not share information it collects about you with Affiliates or Third Parties, except as required or permitted by your state’s law.

BUSINESS TRANSFERS BY CLEARTRUST MEDIA

If ClearTrust Media undertakes or is involved in any merger, acquisition, reorganization, sale of assets or bankruptcy or insolvency event, then we may sell, transfer or share some or all of our assets, including your Personal Information. In this event, we will notify you before your Personal Information is transferred and becomes subject to a different privacy policy.

HOW TO ACCESS, CHANGE OR DELETE YOUR INFORMATION, OR CANCEL YOUR ClearTrust Media ACCOUNT

You may review, update, correct or delete the Personal Information in your ClearTrust Media Account. If you would like to correct your information, you can do so by logging in to your ClearTrust Media Account. To cancel your ClearTrust Media Account entirely, please email us at support@cleartrustmedia.com. Please also note that any information posted by you may continue to be publicly available on the Platform in association with your first name, even after your ClearTrust Media Account is cancelled.

SECURING YOUR PERSONAL INFORMATION

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the security of your transmissions to us and of your Personal Information that we store.

YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES

The Platform will contain links to other websites not owned or controlled by ClearTrust Media. ClearTrust Media does not have any control over Third-Party websites. These other websites may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Information from you. They will have their own rules about the collection, use and disclosure of Personal Information. We encourage you to read the terms of use and privacy policies of the other websites that you visit.

Some portions of the Platform implement Google Maps/Earth mapping services, including Google Maps API(s). Your use of Google Maps/Earth is subject to Google’s terms of use (located at www.google.com/intl/en_us/help/terms_maps.html) and Google’s privacy policy (located at www.google.com/privacy.html), as may be amended by Google from time to time.

CHANGES TO THIS PRIVACY POLICY

We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion. We may change this Privacy Policy at any time. If we make material changes to the Privacy Policy, we will notify you either by posting the changed Privacy Policy on the Platform or by sending an email to you. We will also update the “Last Updated” date at the top of this Privacy Policy. If we let you know of changes through email communication, then the date on which we send the email will be deemed to be the date of your receipt of that email.

It’s important that you review the changed Privacy Policy. If you do not wish to agree to the changed Privacy Policy, then we will not be able to continue providing the Platform and Services to you, and your only option will be to stop accessing the Platform and Services and deactivate your ClearTrust Media Account. You can find out more about how to deactivate your ClearTrust Media Account by emailing us at support@cleartrustmedia.com.

GOT FEEDBACK?

Your opinion matters to us! If you’d like to provide feedback to us about this Privacy Policy, please email us at support@cleartrustmedia.com. For all other questions or concerns, please email us at www.ClearTrust Media.com/contact.

FOR USERS RESIDING IN THE EU: YOUR RIGHT TO SEE AND CHALLENGE INFORMATION PROVIDED TO US BY THIRD PARTIES

You are entitled to see and challenge any information that Third Parties may provide to us as part of our fraud detection, prevention and risk assessment efforts in circumstances where all of the following factors apply: (i) if we use Third Parties to carry out automated checks or risk assessments, and (ii) if we make a decision which has legal consequences for you or which significantly affects you, and (iii) if such decision is based solely on such automated checks or risk assessments. In order to request this, please address your request directly to ClearTrust Media, Privacy Office, 7120 Rafael Ridge Way, Las Vegas, Nevada 89119. Please state clearly in your request that you wish to see and/or challenge the information that Third Parties may have provided to ClearTrust Media as part of our fraud detection, prevention and risk assessment efforts. We may request proof of identification to verify your request.

COOKIE POLICY

ClearTrust Media uses “cookies” in conjunction with the Platform to obtain information. A cookie is a small data file that is transferred to your device (e.g. your phone or your computer) for record-keeping purposes. For example, a cookie could allow the Platform to recognize your browser, while another could store your preferences and other information.

Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the Platform may not work as intended or may not work at all without cookies.

A) ClearTrust Media cookies and Third Party cookies

  • ClearTrust Media may place our cookies on your device via the Platform. Accordingly, our Privacy Policy will apply to our treatment of the information we obtain via our cookies.
  • We may also allow our business partners to place cookies on your device. For example, we use Google Analytics for web analytics, and so Google may also set cookies on your device. As further explained below, Third Parties may also place cookies on your device for advertising purposes.
  • There are two types of cookies used on the Platform, namely “persistent cookies” and “session cookies”.
  • Session cookies will normally expire when you close your browser, while persistent cookies will remain on your device after you close your browser, and can be used again the next time you access the Platform.

B) Other technologies
The Platform may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain Log Data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.

C) Uses for ClearTrust Media cookies

ClearTrust Media uses cookies and similar tracking technologies for a number of purposes, such as the following:

  • to enable, facilitate and streamline the functioning of the Platform across different webpages, devices and browser sessions.
  • to simplify your access to and use of the Platform and make it more seamless.
  • to monitor and analyze the performance, operation and effectiveness of the Platform, so that we can improve and optimize it.
  • to show you content (which may include advertisements) that is more relevant to you.
  • for fraud detection and prevention.

D)Uses for Third-Party cookies

Our partners’ cookies are intended to obtain information to help them provide services to ClearTrust Media. For example, Third Parties we engage to provide services to us may track your behavior on our Platform to market and advertise ClearTrust Media listings or services to you on the Platform and Third-Party websites, or to help us detect or prevent fraud or conduct risk assessments. Third Parties websites that use cookies and other tracking technologies to deliver targeted advertisements on our Platform and/or Third-Party websites may offer you a way to prevent such targeted advertisements by opting-out at the websites of industry groups such as the Network Advertising Initiative and/or the Digital Advertising Alliance. You may also be able to control advertising cookies provided by publishers, for example Google’s Ad Preference Manager. Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on or about the Platform – it just will not be tailored to your interests.

In addition, Facebook places a cookie via the Platform that allows Facebook to obtain aggregated, non-Personal Information to optimize their services. For example, if a user clicks on an advertisement for the ClearTrust Media mobile app on Facebook and subsequently installs the app, this cookie will inform Facebook that a user (who is not personally identified) has installed the app after clicking on the advertisement. This cookie may also inform Facebook that a user is using the app, without identifying the specific actions taken by the user in the app.

E) Disabling Cookies

Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Platform. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel

F) Changes to this Cookie Policy

We can change this Cookie Policy at any time. If we make material changes to the Cookie Policy, we will let you know either by posting the changed Cookie Policy on the Platform or by sending you an email.

It is important that you review the changed Cookie Policy. If you do not wish to agree to the changed Cookie Policy, then we cannot continue to provide the Platform to you, and your only option is to stop accessing the Platform and Services and deactivate your ClearTrust Media Account. You can find out more about how to deactivate your ClearTrust Media Account by emailing us at support@cleartrustmedia.com.