Last Updated: November 10th, 2021
2. Information We Collect
Hulu may collect the following information from or about you, including personal information, from the following sources:
Information You Provide to Us. We collect information you provide to us. For instance, when you register to use the Hulu Ad Manager Service through your advertiser account, we may collect identifiers and personal information including your name, business name, business email address, business phone number, credit card or other payment method information, business address, ZIP code, and other information. We collect details about the business that you represent, including EIN, business registration details, and other information. In addition, Hulu may collect information you provide to us when you upload content (including ad content or to verify your business) to Hulu Ad Manager Services, respond to surveys, contact Hulu through customer service or communicate with us by other means, or participate in promotions or events. We may also collect information you provide when you make changes to your account profile or update your Hulu Ad Manager preferences.
Usage, Technical and Log Data. When you use the Hulu Ad Manager Services, we may collect information from and about the browser or device you’re using and information about your internet or other electronic network activity, including through analytics tools and the technologies described below (“Data Collected Through Cookies and Similar Technologies”). This information may include your IP address, device type, browser and software characteristics (such as type and operating system), geolocation data (which may include precise location data), referral URLs, network state, device identifiers or other unique identifiers such as advertising identifiers (e.g., “ad-ID” or “IDFA”) and identifiers associated with browser cookies (see our description of “Cookies and Local Storage” below), and carrier information. We also collect information about your activity on the Hulu Ad Manager Services including information about the campaigns you create, the materials and resources with which you engage (e.g., knowledge articles and webinars), and your targeted audience.
Data Collected Through Cookies and Similar Technologies. Like many online services, we use various technologies to collect usage data and store preferences. These technologies are discussed below.
- Cookies and Local Storage. A cookie is a small data file that is transferred to your computer’s hard disk. We may use both session cookies and persistent cookies to better understand how you interact with the Hulu Ad Manager Services, to monitor aggregate usage by our users and web traffic routing on the Hulu Ad Manager Services, and to customize personalized advertising. These uses allow us to improve the Hulu Ad Manager Services. We may create a unique device or user ID for you and store it in a cookie so we can customize your experience based on your preferences. We may collect information through other kinds of local storage (also referred to as “Flash cookies”) and HTML5 local storage. Because these technologies are similar to browser cookies, they are sometimes called “browser cookies,” even though they may be stored in different parts of your computer.
You can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. For information about disabling cookies or deleting information contained in Flash cookies, please click here. Please note that disabling cookies or deleting information contained in cookies or Flash cookies may interfere with the performance and features of the Hulu Ad Manager Services, including not being able to store your preferences or login information.
- Web Beacons, Pixels and mobile SDKs. In addition to cookies, we may use other technologies such as web beacons or pixel tags, which can be embedded in web pages, videos, or emails, to collect certain types of information from your browser or device, check whether you have viewed a particular web page, ad, or email message, and determine, among other things, the time and date on which you viewed or used the Hulu Ad Manager Services, the IP address of your computer, and the URL of the web page from which the Hulu Ad Manager Services were viewed. We may also use or work with third parties including our business partners and service providers who use mobile Software Development Kits (“SDKs”) to collect information, such as advertising identifiers (e.g., “ad-ID” or “IDFA”) and information related to how mobile devices interact with the Hulu Ad Manager Services.
The use of these various technologies in connection with advertising on the Hulu Ad Manager Services is explained further below. To learn about opting out of interest-based or online behavioral advertising, please see the information we have provided in Section 6 (“Your Controls and Choices, Including Opt-Out Options”).
Information from Partners and Other Sources. We may collect information about you from other sources, including service providers (e.g., data licensors, research and analytics companies, and payment processors), public databases, our marketing partners, and advertisers. This may include information (whether identifiable, de-identified or anonymous, and whether collected online or offline) about your interests, demographic data, purchasing behavior, and your activities online (such as websites visited and advertisements viewed).
3. Use of Information We Collect
Use in General. We use the information we collect from or about you in order to help deliver a first-class user experience, including for the following purposes:
- providing the Hulu Ad Manager Services, including customer support;
- contacting and communicating with you, including for information on your account, transactions with us, or feedback about features on our sites and applications or changes to our policies, promotions, updates, and notifications;
- customizing the Hulu Ad Manager Services and evaluating how well the Hulu Ad Manager Services perform;
- managing our suppliers, independent contractors, service providers and others throughout the supply chain;
- administering surveys, sweepstakes, contests, and other promotional activities or events;
- customizing recommendations;
- operating and optimizing the Hulu Ad Manager Services, such as by conducting analytics and research;
- compiling aggregate data for internal and external business purposes;
- detecting security incidents, preventing potentially fraudulent, illegal or harmful activities and otherwise enforcing the Hulu Advertising Manager Terms and other policies;
- protecting your and our rights and complying with legal obligations;
- other uses in accordance with our Hulu Advertising Manager Terms; and
- any other purpose that is disclosed to you at the time we collect the information or that is related to a request made by you.
Use of Payment Information. We use payment information, such as credit card numbers and billing ZIP code, and commercial information, such as the Hulu campaigns you create and purchase, to help provide the Hulu Ad Manager Services. For example, we use payment information to process payments (we use a third-party payment processor to do this), to retrieve account information for advertisers, to determine whether an advertiser is eligible for promotions, and to detect abuse of the Hulu Ad Manager Services.
Retention of Data. We retain your information as long as it is necessary for us to provide the Hulu Ad Manager Services and to fulfill our contractual obligations and rights. If we retain additional information, we retain it only for so long as we have a legitimate business purpose in keeping such data.
4. Sharing Information with Others
We may share the information collected from or about you with the following:
- Service Providers. We may share your information with third party service providers that provide business, professional, or technical support functions for us, help us operate the Hulu Ad Manager Services, or administer activities on our behalf. The categories of information that we share with service providers will vary depending on the types of services they provide. For example, we share payment information with our third-party payment processor to assist us in our billing efforts, email addresses with our marketing service providers to assist with our email campaigns, and IP address, hashed emails, and advertising identifiers with service providers to assist in our advertising and marketing efforts.
- Partners and Affiliates. We may share your information with select partners, affiliates, and other third parties that we believe may have offers of interest to you.
- Third Parties When Required By Law or When Necessary to Protect Your or Our Rights. In some instances, we may disclose information from or about you without providing you a choice. For example, we may disclose your information in the following ways: to protect the legal rights of Hulu and our affiliates or partners; to protect the safety and security of users of the Hulu Ad Manager Services or third parties; to enforce our Hulu Advertising Manager Terms; to protect against fraud; and to comply with or respond to the law or legal process or a request for cooperation by a government entity, whether or not legally required.
- Third Parties in Connection with Certain Transactions. If we sell all or part of our business, make a transfer of assets, or otherwise might be involved in a change of control transaction, or in the event of bankruptcy, we may transfer information from or about you to one or more third parties as part of the transaction, including the due diligence process.
- Parties with Your Consent or When You Otherwise Choose to Share. We may also share information from or about you with any party when we have your consent or when you otherwise choose to share such information.
5. Your Controls and Choices, Including Opt-Out Options
You have the following controls and choices regarding how we and third parties use certain information collected from or about you.
Opt-Out Options for Third-Party Online Behavioral or Interest-Based Advertising.
- Advertising that is based on information collected from or about you across websites, applications and other platforms over time is known as online behavioral or interest-based advertising. Some of the third parties (e.g., ad networks and partners; data exchanges; marketing analytics, digital advertising and marketing service providers) that collect information from or about you on the Hulu Ad Manager Services in order to provide more relevant advertising to you participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising and/or may be members of the Network Advertising Initiative (“NAI”). Hulu is committed to complying with the DAA Self-Regulatory Principles for Online Behavioral Advertising and the DAA Application of Self-Regulatory Principles for the Mobile Environment.
- To learn more and to make choices about the use of information from or about you for online behavioral or interest-based advertising on websites (desktop and mobile browsers), please visit the DAA and the NAI. You may also use the opt-out mechanism in the “About Ads” link at the bottom of the Hulu Ad Manager site. You can also exercise controls through the settings available to you through your device(s), such as re-setting your device’s advertising identifier, selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices). Please note that your opt-out choices will only apply to the specific browser or device from which you opt out.
- There is currently no consensus among industry participants as to what “Do Not Track” means and how to respond to “Do Not Track” browser signals. As such, we do not respond to such signals. Instead, to opt-out of website-based third-party interest-based or online behavioral advertising, please exercise one of the choices listed above.
6. Security and Account Access
The security of your information is important to us. We use a variety of physical, technical, and administrative measures to safeguard information in our possession against loss, theft and unauthorized use, disclosure, and modification. For example, we take steps to limit access to sensitive information from or about you to those Hulu employees, agents, and contractors who have a legitimate business reason to access such information. We also use measures like encryption and hashing to help protect sensitive information when in transmission.
Despite these efforts, please note that there is always a possibility that a breach in data transmission or storage may occur and we cannot guarantee the security of any information from or about you 100% of the time. Please refer to the U.S. Federal Trade Commission’s website for information on how to protect yourself from identity theft.
Hulu Ad Manager Services are only for users over the age of 18 acting on behalf of a business entity and are not directed at persons under the age of 18. If we become aware that we have unknowingly collected personal data about a child under 18 years of age, we will make commercially reasonable efforts to delete such information from our database. If you are the parent or guardian of a child under 18 year of age who has provided us with personal data, you may contact us to request it to be deleted.
8. Applicable Law
Hulu is headquartered in the U.S. and the Hulu Ad Manager services are intended for users in the U.S. By utilizing Hulu Ad Manager Services, you consent to the collection, storage, and processing of information under U.S. laws.
10. Questions/Contacting Us
Attention: Legal Department
2500 Broadway, 2nd Floor
Santa Monica, CA 90404