Filament Privacy Policy

Effective: March 1, 2025

This privacy policy (“Privacy Policy”) explains what information Filament Marketing, Inc. (“Filament”, “we,” “us,” or “our”) collects from you (“you” or “your”) when you use, access or interact with our Website, Customer Websites, Products or related services (the “Services”). By using, accessing or interacting with the Services, you agree to all the terms and conditions stated in this Privacy Policy. This Privacy Policy only applies to information collected from sources as described herein. 

We provide digital products, including, but not limited to, inclusion and exclusion lists, Deal IDs, and curation services (“Products”). Third parties (which may include advertisers, advertising agencies, marketers, researchers, telecommunications companies, technology providers and other entities) license our Products (“Customers”) and employ our Products in connection with ads placed on YouTube, programmatically, and/or related services. Customers typically use our Products to deliver ads on safe channels to improve, including but not limited to, brand safety, targeted advertising, measurement insights, market research and analytics, analyzing device information, and other types of customization. Filament does not collect information on or related to Consumers and their Devices, or any type of Personally Identifiable Information. Our Products do not contain any PII in their creation, transmission, or application. If Customer uses marketing tactics such as remarketing, custom audiences, 3rd party data, and/or other consumer data, customer is responsible for the lawful collection, storage, and use of such PII. 

In order to access and use the Services as a Customer, you must agree to our Product Terms of Service at https://www.wearefilament.com/terms-of-service (the “Terms”). The Terms only apply to Customers and all users of the platform (i.e., and not Consumers). 

As used in this Privacy Policy, “Personal Information” means any information or set of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. “Personal Information” does not include information that is not associated with an identified or identifiable individual or information that is reported in the aggregate (provided that such aggregated information is not identifiable to a natural person or household), and does not include information as to which identifying characteristics have been removed without means reasonably likely to be used by any person to re-identify the natural person or household, directly or indirectly. For purposes of this Privacy Policy, “Personal Information” encompasses “personal Information” under the California Consumer Privacy Act of 2018 (“CCPA”).

Collection and Use of Information Through Our Website

Consumer- and Customer-Provided Information: When you visit our Website, we may collect certain types of information about you that you submit voluntarily. This information is “Personal Information” since it identifies you, and may include your name, address, email address, and telephone number. This may occur when you send us an email, submit a website form requesting information about Filament or our Services, use an on-site live chat service, or otherwise communicate with us. Our legal basis for processing this information is your consent, the performance of a contract between you and us, and our legitimate interests, namely the proper administration of our Website and communications with you.

Registration and Billing Information: When Customers or their representatives access the Website or, we may process information about you that was provided by you when you registered, for example, the Customer’s name, email address, and password (“Registration Information”). We also collect certain information from representatives accessing the Services on behalf of a Customer, including credit card numbers and associated billing information (“Billing Information”) in order to process subscriptions. 

Automatically-Collected Information: Whether you are a Consumer visiting our Website or acting on behalf of a Customer as part of the registration process, we may receive additional information about you that is collected automatically. This additional information may include Internet protocol (IP) address, domain names, browser, device type, access times, latitude and longitude location information, the web pages you view, and other tracked user actions. This information may also include Cookies (defined below), web bugs, device information, and navigational data like Uniform Resource Locators (URLs), which we may use to gather information regarding the date and time of your visit, as well as your geo-location (from your IP address). “Cookies” are small pieces of information that a website sends to your browser. 

How We Use Information We Collect Through Our Website: We use information that we collect through our Website to respond to your requests, resolve problems, improve the quality of the Website and Services, and market our products or services and those of third parties to you. We may also anonymize Personal Information by removing identifying characteristics and aggregating it with the information of others so that it no longer constitutes “Personal Information”. We may use such information to create compilations of aggregated data and/or statistics and reports, and any other uses without restriction. We may use information we collect through our Website to comply with our legal and regulatory obligations, policies and procedures, and for internal administrative purposes.

CHOICE
(Disclosing Personal Information to Third Parties)

Filament does not request or knowingly receive or collect Sensitive Personal Information. Nonetheless, if at any point in the future Filament receives or collects Sensitive Personal Information about you, Filament will not process such information about you for purposes other than those for which the information was originally obtained or subsequently authorized by you unless you explicitly consent to the processing, or as required or permitted, or where not prohibited by law or regulation. “Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, political opinion, religious or philosophical beliefs, trade union membership, genetic data, biometric data where processed to uniquely identify a person, any information that concerns medical or health conditions or sex life, or information relating to the commission of a criminal offense. 

We will only disclose your Personal Information in limited circumstances and only to the extent we are permitted to do so by the terms of this Privacy Policy and by law. We will disclose your Personal Information (i) when we reasonably believe we are required to do so by law, regulation or other government authority or when we deem it appropriate or necessary to provide such information to law enforcement authorities, (ii) to enforce our Terms and this Privacy Policy, (iii) to protect and defend the rights or property of us, or (iv) to protect the safety of our employees, agents, or users of the Products.  We will not sell or transfer your Personal Information to any company or organization, except that we may transfer your personally identifiable information to a successor entity upon a merger, sale, consolidation or other corporate reorganization to which we are a party. 

Opting Out of Collecting Information About You on Customer Websites (For Consumers to Customer Websites)

Please note that this opt-out link sets a “session” cookie (also called a “first-party cookie”) to exclude you from our Products. 

You may also opt-out of Filament and other entity’s data collection practices though the Network Advertising Initiative (“NAI”) opt-out page https://optout.networkadvertising.org/?c=1, or Digital Advertising Alliance’s (“DAA”) opt-out page https://optout.aboutads.info/?c=2&lang=EN 

Opting Out of Marketing Communications

If you receive marketing or promotional emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “Contact Us” section.

DATA SECURITY

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. Taking into account the risks involved in the processing and the nature of the Personal Information we process, Filament maintains administrative, technical, and physical safeguards to protect information in our possession against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing. This includes, for example, firewalls, password protection, encryption, and other access and authentication controls.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. 

ACCESSING AND CONTROLLING YOUR INFORMATION

Data protection laws (notably, the CCPA) make a distinction between organizations that process Personal Information for their own purposes (known as “businesses” (under the CCPA)) and organizations that process personal data on behalf of other organizations (known as “service providers” (under the CCPA)). If you have a question or complaint about how your Personal Information is handled, these should always be directed to the relevant business, since the business has primary responsibility for your Personal Information.

For Consumers to Customer Websites: When Filament acts as a provider of Services to its Customers on Customer Websites, we do not use, collect or permit our Customers to send to us Personal Information about Consumers. We have no direct relationship with Consumers on Customer Websites, and any such Consumers who seek access, or who seek to correct, amend, or delete their Personal Information should direct their inquiries to the relevant Customer.

For Consumers to Our Website: We are a business (under the CCPA) in respect of Personal Information that Customers provide us as part of their accounts and Consumers provide us when visiting our Website. Under laws in certain countries and US states in which Filament operates, Customers who manage their accounts through our Service and Consumers to our Website from those countries/states have a right to access Personal Information about themselves, and to amend, correct or delete Personal Information that is inaccurate, incomplete, or outdated or restrict processing of or port their Personal Information. Filament will, upon request, provide you with confirmation regarding whether Filament is processing Personal Information about you, consistent with applicable law. In addition, upon your request, Filament will take reasonable steps to correct, amend, or delete your Personal Information that is found to be inaccurate, incomplete or processed in a manner non-compliant with this Privacy Policy or applicable law or restrict processing of or port your Personal Information, except where the burden or expense of doing so would be disproportionate to the risks to your privacy, where the rights of persons other than you would be violated or where doing so is otherwise consistent with applicable law. Unless prohibited by applicable law, Filament reserves the right to charge a reasonable fee to cover costs for providing copies of Personal Information that you request.

Please note that while any amendments, corrections, or deletions will be reflected in active user databases (as updated within a reasonable period of time), Filament may retain all Personal Information for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.

If you are accessing the Services on behalf of a Customer, you may review and/or change certain of your Personal Information by logging into the Website and accessing the Customer’s account. We may limit the Personal Information you can change on the Website. You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy, and you agree that we are under no obligation to delete or modify information that you have previously chosen to provide us as to which you have not instructed us to take such action. Please remember, however, if we have already disclosed some of your Personal Information to third parties, we cannot access that Personal Information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.

Upon your request, we will close your account as soon as reasonably possible, in accordance with applicable law. We may continue to use your Personal Information in accordance with this Privacy Policy even after we have closed your account, except that we will not display it on the Website or through the Services in a manner that personally identifies you. In addition, we may retain your Personal Information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms, and take other actions otherwise permitted by law.

USE OF THIRD PARTY AFFILIATES

Filament may also use third parties for purposes of linking existing Consumers or otherwise known IDs (“Matching IDs”). Matching IDs may represent device IDs, cookie IDs, customer IDs, or other types of data meaningful to Filament, and is recognized only as another pseudonym in Filament’s systems. Filament requires that such third parties obscure and protect all Matching IDs before sending them to Filament, such that the underlying data is either meaningless to Filament or is encrypted such that Filament has no ability to access the underlying data. 

THIRD PARTIES NOT GOVERNED BY THIS PRIVACY POLICY

This Privacy Policy addresses only Filament’s use and disclosure of information we collect from or about Consumers to our Website or to Customer Websites utilizing the Service, or acting on behalf of a Customer as part of the registration process. The use and disclosure restrictions contained in this Privacy Policy do not apply to any third party and we do not control the privacy policies of third parties. If you disclose information to others, including to Customers, you are subject to the privacy policies of those third parties where applicable.

The Website may contain links to other websites that are not owned or controlled by us. When you click on such a link, you will leave our Website and go to another site. During this process, another entity may collect Personal Information from you. We have no control over, do not review, and are not responsible for the privacy policies of or content displayed on such other websites.

CHILDREN’S PRIVACY

Our Services are not directed at nor intended for use by individuals under 16, and we require our Customers to put necessary filters in place to not transmit this type of data to us. Moreover, we do not target to collect data from children under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.  If you are under the age of 16, please do not attempt to register with the Services or send any information about yourself to us, including your name or e-mail address. If you learn that a child under 16 has provided us with Personal Information, please contact us. If we become aware that a child under 16 has provided us with his or her Personal Information, we will promptly delete such data. 

Data Retention and Destruction 

We will retain Personal Information for as long as necessary to accomplish our purposes for such data as set forth in this Privacy Policy. You can request that your information be deleted by contacting us at the address provided at the bottom of this Privacy Policy. At the time your information is deleted, we will destroy your Personal Information using reasonable data destruction practices. We may, however, retain certain information to comply with legal or contract obligations or to facilitate law enforcement requests.

Changes

We may revise this Privacy Policy from time to time in our sole and absolute discretion. If we decide to change our Privacy Policy, we will post the revised policy on our Website. If changes are significant and materially affect your rights under this Privacy Policy, we may provide a more prominent notice on the Services. As we may make changes at any time without notifying you, we suggest that you periodically consult this Privacy Policy. Please note that our rights to use any information collected will be based on the Privacy Policy in effect at the time the information is used.

CONTACT US

If you have any questions, comments or concerns about this Privacy Policy or would like to request additional information regarding our privacy practices, please contact us at: info@wearefilament.com Please also mention “Privacy Policy” in the title of your email message.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (CCPA)

In addition to our Privacy Policy, this Privacy Notice for California Residents supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We have provided this notice in compliance with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect (CCPA)

Our Website collects Personal Information, and as described our Privacy Policy, we do not collect Personal Information in connection with our Products or Customer Websites. Within the last twelve (12) months, our Website and our Products have collected the following categories of Personal Information from consumers:

(Note: in this table, Yes indicates that a given category of data was collected, and No indicates that a given category of data was not collected.)

Category and Examples	Collected on the Website?	Collected on our Products (from Customer Websites)?
A: Identifiers	Yes	No
A real name, Internet Protocol address, email address, or other similar identifiers.
B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Yes	No
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.
C: Protected classification characteristics under California or federal law	No	No
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information	No	No
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information	No	No
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity	Yes	No
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data	Yes	Yes
Physical location or movements.
H. Sensory data	No	No
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information	No	No
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	No	No
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other Personal Information.	Yes	Yes
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

To summarize the above, we collect Personal Information about Consumers to our Website, and we do not collect Personal Information about Consumers on Customer Websites, as further described in the Privacy Policy.

With respect to Categories F, G and K in the table above regarding our Products and Customer Websites, Filament does aggregate information from large groups of visitors, in an anonymous and de-identified way, and these aggregations may rely on algorithmic inferences drawn from information collected on those Websites, as listed in other categories above. We use such information to create compilations of aggregated data and/or statistics and reports.

Note that “Personal Information” does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, including:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from our Customers or their agents. For example, from documents that our Customers provide to us related to the Service for which they engage us.
• Indirectly from our Customers or their agents through their use of our Service. 
• Directly and indirectly from activity on our Website or a Customer Website. 

Use of Personal Information (CCPA)

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided.
• To provide you with information, products or services that you request from us.
• To provide Customers with information regarding you and products or services of Customer.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our Website and present their contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our Customers or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our or a Customer’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us or a Customer is among the assets transferred.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without updating this notice.

Sharing Personal Information (CCPA)

We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose: None.

We disclose your Personal Information for a business purpose to the following categories of third parties:

• Our affiliates.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any Personal Information.

Your Rights and Choices (CCPA)

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights (CCPA)

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and verify your request, we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data portability request).
• (Applicable if we sell or disclose your Personal Information for a business purpose) Two separate lists disclosing:
  • Sales, identifying the Personal Information categories that each category of recipient purchased; and
  • Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights (CCPA)

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights (CCPA)

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:

• Contacting us via: info@wearefilament.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format (CCPA)

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination (CCPA)

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to This Privacy Notice (CCPA)

We may revise this privacy notice from time to time in our sole and absolute discretion. If we decide to change our privacy notice, we will post the revised statement on our Website. If changes are significant and materially affect your rights under this privacy notice, we may provide a more prominent notice on our Website or Services. As we may make changes at any time without notifying you, we suggest that you periodically consult this privacy notice. Please note that our rights to use any information collected will be based on the privacy notice in effect at the time the information is used.

Contact Information (CCPA)

If you have any questions, comments or concerns about the privacy notice or would like to request additional information regarding our privacy practices, please contact us at:

• Contacting us via: info@wearefilament.com