Effective:  July 2, 2018

We have prepared this Privacy Notice to explain how, why, and when we collect data from you to provide targeted advertising services for our clients.

1. What data we collect and how we use it

We may collect the following categories of information for the purposes explained below.

• • Advertiser website activity: This is data about your browsing activity on the Advertiser’s website. For example, which pages you visited and when, and what items you placed into your online shopping cart.
  • Device and browser information: This is technical information about the device or browser you use to access the Advertiser’s website. For example, your device’s IP address, cookie string data and (in the case of mobile devices) your device type and mobile device’s unique identifier such as the Apple IDFA or Android Advertising ID.
  • Ad data: This is data about the online ads we have served (or attempted to serve) to you. It includes things like how many times an ad has been served to you, what page the ad appeared on, and whether you clicked on or otherwise interacted with the ad.
  • Data from Advertising Partners: This is data that we receive from other digital advertising companies that we work with (“Advertising Partners”) to help us deliver ads to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers that some Advertisers or other third party ad platforms choose to share with us, such as your “Customer ID” with an Advertiser or an identifier associated with a hashed (not readable) version of your email address. We may work with these Advertising Partners to synchronize their unique, anonymous identifiers to our own to enhance data points about a particular unique browser or device.
  • Email and Postal Addresses from Advertisers: Some Advertisers choose to share actual email addresses and postal addresses about their customers with us, so that (with the help of Advertising Partners) we can help the Advertiser serve targeted ads to customers. Also, we may assist an Advertiser with sending emails to customers (for instance, if the Advertiser is using a sending service). We use the Advertiser’s supplied e-mail and postal addresses for the purpose of assisting that particular Advertiser.
  • Hashed email addresses: If an Advertiser allows, we may collect hashed versions of the emails that are entered on that Advertiser’s site. These hashed emails are used as an additional identifier to help us better target ads for Advertisers, including across multiple devices or browsers.

We use this data to help our Advertisers identify and serve ads to you that are more relevant to you. We also use this data to operate, improve and enhance our services including enhancing the data points we or our Advertising Partners have about a particular user, browser, or device, or to target, optimize, cap, or synchronize advertising.

2. Data Sharing

We may disclose information about you:

• • With an Advertiser whose site you have visited: We may share information about how you have interacted with that Advertiser’s site or its Ads.
  • With our service providers: We contract with companies who help with parts of our business operations. We require that our service providers only use your information in connection with the services they perform for us.
  • With service providers to our Advertisers: Our Advertisers may contract with companies who handle data (such as Advertisers’ customer lists) for them.

With our subsidiaries and related companies

• • In connection with legal proceedings: When we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of DBA Media, our Advertisers or any other third party.
  • In connection with a sale of our business: If a third party acquires some or all of our business or assets, we may disclose your information in connection with the sale.

We also share hashed email addresses (or other identifiers associated with those hashes), technical data that we collect about your browsing habits and your device (such as data relating to our cookies, tracking pixels and similar technologies) with other advertising companies in the digital advertising ecosystem. This enables them and us to better target ads to you.

Finally, we may disclose aggregated, anonymized information with other third parties.

3. Cookies and related technologies

We use cookies, tracking pixels and related technologies to provide our services for Advertisers. Cookies are small data files that are served by our platform and stored on your device. They enable us to identify your device when you move between different websites and applications, so that we can serve targeted advertising to you.

4. Your choices and opting-out

We recognize how important your online privacy is to you, so we offer the following options for controlling the targeted ads you receive and how we use your data:

You can opt out of receiving targeted ads served by us or on our behalf by clicking on the blue icon that typically appears in the corner of the ads we serve. Please note that, if you delete your cookies or upgrade your browser after having opted out, you will need to opt out again. Further, if you use multiple browsers or devices you will need to execute this opt out on each browser or device. If you opt-out we may collect some data about your online activity for operational purposes (such as fraud prevention) but it won’t be used by us for the purpose of targeting ads to you.

DBA Media is also a member of the Network Advertising Initiative (NAI) and adheres to the NAI Codes of Conduct. You may use the NAI opt out tool here, which will allow you to opt out of seeing targeted ads from us and from other NAI approved member companies.

We also comply with the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA). You may opt out of receiving targeted ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAA website here.

We also comply with the Canadian Self-regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance of Canada (DAAC). You may opt out of receiving targeted ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAAC website here.

We also adhere to the European Interactive Advertising Digital Alliance (EDAA) guidelines for online advertising and you may opt out via their Your Online Choices website.

Please note that when using the ad industry opt-out tools described above:

If you opt-out we may still collect some data about your online activity for operational purposes (such as fraud prevention) but it won’t be used by us for the purpose of targeting ads to you.

If you use multiple browsers or devices you may need to execute this opt out on each browser or device.

Other ad companies’ opt-outs may function differently than our opt-out.

You can opt-out of our tracking your online activity for targeted advertising purposes (Do Not Track): We respond to “do not track” or “DNT” signals sent from your browser. If the website of one of our Advertisers receives a DNT signal, during that visit, we will not link data we collect to your browser identifier so that new data collected about you will not be used by us for targeted advertising purposes, but older data collected about you may still be used.

To opt out of receiving targeted ads that are based on your behavior across different mobile applications follow the below instructions, for iOS and Android devices:

iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting

For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising”

Opting out will not prevent you from seeing ads, but those ads will likely be less relevant because they won’t be tailored to your interests. The ads might, for instance, be randomly generated or based on the web page you are visiting.

In addition, if you are located in the European Economic Area you may also have the right to access, correct or update some of the information we hold about you. You can also request that we delete your information. If you wish to exercise any of these rights, please contact us at info@DBA.media. Please note that in many cases, we hold identifiable information only on behalf of our Advertiser clients, and we may instead direct you to contact them.

5. Data retention

We retain the identifiable data we collect directly for targeting purposes for 13 months, after which time we employ measures to de-identify the data by removing unique identifiers and truncating associated IP addresses.

Identifiable data collected for other purposes is held no longer than necessary for our business purposes or to meet legal requirements.

6. Security

We apply technical, administrative and organizational security measures to protect the data we collect against accidental or unlawful destruction and loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against other unlawful forms of processing.

7. International transfers

We may transfer the information we collect about you to countries other than the country where we originally collected it for the purposes of storage and processing of data and operating our services. Those countries may not have the same data protection laws as your country. However, when we transfer your information to other countries, we will protect that information as described in this Privacy Notice and take steps, where necessary, to ensure that international transfers comply with applicable laws. For example, if we transfer your information from the European Economic Area to a country outside it, such as the United States, we will seek to take additional steps such as entering into EU compliant data transfer agreements with the data importer where necessary.

Pending further developments relating to the status of data transfers to the US under the previous Safe Harbor regime, to the extent they are applicable, DBA Media, Inc. (our U.S.-based parent company) will continue to comply with the principles of the U.S./EU and U.S./Swiss Safe Harbor Frameworks regarding Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement with respect to the personal information it receives in the U.S. from the relevant European countries, effective as of the date its certification is posted to the U.S Department of Commerce website at http://safeharbor.export.gov/list.aspx. To exercise their rights under Safe Harbor or file a complaint, residents of those countries may contact DBA Medial, Inc. as described below, and our Advertisers can log into their accounts to directly access and correct certain information they have submitted. In the event we are unable to resolve a disagreement with a covered European resident regarding the handling of his or her personal information under Safe Harbor, we agree to resolve the matter through the International Centre for Dispute Resolution / American Arbitration Association Safe Harbor Dispute Resolution Program (http://info.adr.org/safeharbor). To learn more about the Safe Harbor Frameworks, please visit http://www.export.gov/safeharbor.

8. Changes to this Privacy Notice

Changes to this Privacy Notice will be posted on this page. If we make a material change to our privacy practices, we will provide notice on the site or by other means as appropriate.

9. Contact us about questions or concerns

If you have any questions about this Privacy Notice or our privacy practices, you can contact partners@dbaplatform.com.