Personagraph Online Advertising Services Privacy Policy

Effective as of September 15, 2017

This Privacy Policy applies solely to the consumer data that Personagraph Corporation (“Personagraph”) collects or processes in connection with providing online advertising software and services to our clients (“the Services”). Note that this policy does not apply to information collected in connection with other services we may provide to our clients, and does not apply to data collected offline by Personagraph or through our website. For more information about our website privacy practices, visit our Web Site Privacy Policy.

This Privacy Policy describes

  1. Our Services
  2. The Consumer Information We Collect
  3. Technologies Used to Collect Usage Data
  4. How We Use Consumer Information
  5. When We Share Consumer Information with Others
  6. The Choices Consumers Have Regarding Our Use of Information
  7. How We Respond to Do Not Track Signals
  8. How We Secure Consumer Information
  9. Other Important Information

1. Our Services

Personagraph provides data solutions and licenses proprietary technology that helps our clients to better understand their customers and to serve targeted offers and content and serve more relevant advertising to their customers, both within their own properties (including their websites, apps and emails) and elsewhere online. Personagraph does not have a direct relationship with the customers and users who interact with our clients, although we may collect some information directly when you interact with one of our clients. Our clients have their own privacy policies that govern the use of the data they collect.

Our Services include the following:

  • Integration of tracking technologies (described in Technologies Used to Collect Data) into client mobile applications, websites, and other online services that allow clients or Personagraph to collect information about users and their interactions and interests.
  • Collection and management of data to measure the user engagement with websites, mobile applications, advertisements, and other marketing materials.
  • Creation and management of de-identified information (described in The Consumer Information We Collect) that allows our clients to recognize their customers across devices and platforms and better understand their customers’ interests, including to target advertising.
  • Operate a marketplace that allows clients to identify consumers that may be interested in certain products or services and target offers that may be of interest to them.

2. The Consumer Information We Collect

In order to provide our Services, we collect information that does not personally identify consumers, but which may be linked to a particular computer or device, such as device identifiers, IP addresses, advertising IDs, and other user identification numbers. We consider this non-personally identifiable information, or “Non-PII,” so long as the data is not linked to information that can be used to identify you personally as a specific individual, such as name, email address, physical address, and telephone number (“Personally Identifiable Information or PII”). We may collect that information directly, or we may receive information from our clients or other third parties. We may collect information about your online activities over time and across online services.

The Non-PII we collect and receive includes, but is not limited to:

  • Information about a consumer’s computer, mobile phone or other device, including IP address, unique device identifiers, advertising IDs, cookie IDs, browser type, browser language, and other transactional information;
  • Demographic and interest data about consumers, such as age range, gender, and intent to purchase certain goods or services;
  • General location data, such as the country, city, or zip code in which a consumer resides.
  • De-identified information, which is created by removing all information that can be used to directly identify or contact you as a specific individual, such as your name and email address. De-identification may be accomplished by using a mathematical process (commonly known as a hash function) to convert PII into a code that we cannot use to identify you directly.

We also collect and store information that we receive from clients and other business partners and other third party sources, which may have been initially collected online or through offline interactions.

We do not use PII for online advertising purposes unless a consumer has provided opt-in consent.

3. Technologies Used to Collect Data

We use many technologies to collect data. Some examples include:

Cookies and Local Storage. Cookies and local storage are data files placed within a browser on a device. Cookies and local storage can both be used to store a unique identifier for your device that can be used to recognize your device whenever you visit a website or other online service. Clients may also disclose to us the unique identifiers associated with the cookies they place on your device. Most browsers provide you with the ability to disable or decline cookies and local storage. You will need to check your browser’s settings for further information.

Web Beacons. Web Beacons are small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) that are embedded within websites and other online services (invisible to the user) and allow us to collect Non-PII.

Embedded Script. An embedded script is programming code that is designed to collect information about your interactions with websites and other online services. The code is temporarily downloaded onto your device from our web server, is active only while you are connected to the client Property and is deactivated or deleted thereafter.

SDKs and APIs. SDKS and APIs are programming codes that are installed on a device, typically within a mobile application that you chose to download onto your mobile device. We may use SDKS and APIs to collect Non-PII through client mobile apps.

These technologies, and similar technologies we may use, and the information they collect, may be used for many purposes, including, without limitation, tracking your visits and how you navigate websites, mobile apps and other online services, and determining your preferences and interests for the purposes of serving you targeted advertisements and other marketing messages.

4. How We Use Consumer Information

We store and process consumer information collected or received in connection with the Services to provide Services to our clients and for our own internal business purposes, such as to optimize or improve the Services, and for legal compliance. Our Services enable our clients to better understand and use the information gathered from their customers and visitors and to serve more relevant advertisements. For example, the information we collect may be used by us and our clients to:

  • Better understand consumers and their interests and how they interact with websites, apps and other online services;
  • Target advertisements for products or services that may be of interest to customers and visitors; and
  • Connect the devices and browsers used by one customer to that customer (using Non-PII, including de-identified PII data).

5. When We Share Consumer Information with Others

We may share data with our clients and other third parties with a consumer’s consent, as otherwise described in this privacy policy and in the following circumstances:

Non-PII: We may disclose or share Non-PII, including aggregate statistics and hashed or otherwise de-identified data, with third parties in our discretion.

Our Clients: We provide insights to our clients, or to a third party at a client’s direction, regarding their existing customers and potential new customers. We do not share PII in this situation, but rather we use de-identified data (such as hashed email addresses) or aggregated information.

Third-Party Service Providers: We use third party service providers to perform certain functions on our behalf. These third-party service provides may have access to PII but only as needed to perform these services.

Assignment and Transfers: All information about you, including PII, is treated as a business asset, and may be disclosed to actual or potential acquirers and lenders, and transferred by us in connection with a sale or transfer of our business or assets, including as a result of a merger, acquisition, reorganization, dissolution, bankruptcy or liquidation. We reserve the right, as part of this type of transaction, to transfer or assign your information (including PII) and other information we have collected from users of the Services. By providing your PII, you agree that we may transfer such information to the acquiring entity without your further consent.

Law Enforcement, Legal Process, and Emergency Situations: To the extent permitted by law, we will disclose your information to government authorities or third parties pursuant to a court order, legal request, subpoena or other legal process, to prevent or investigate a possible crime, such as fraud or identity theft, or to protect the rights, property or safety of ourselves or others. We reserve the right to report to appropriate law enforcement, governmental authorities and other third parties any activities that we, in good faith, believe to be harmful or unlawful, with or without providing notice to you. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.

6. The Choices Consumers Have Regarding Our Use of Information

We understand that you may wish to opt-out of our use of information about you or your devices to provide targeted advertising services to our clients. The opt-out choices below apply only with regard to our use of information for targeted advertising purposes. Please note that it may take up to 7 days to process your opt-out request.

You may limit Personagraph’s association of your mobile device with other non-PII and online activities by resetting the advertiser ID on your Apple or Android device. You may also exercise choice by visiting the privacy settings of your Android or iOS device and selecting “limit ad tracking” for Apple iOS devices or “opt-out of interest based ads” for Android devices. More information about how to change these settings can be found at:

Please be aware that opting out does not mean that you will no longer receive targeted marketing messages in your mobile apps or web browsers. You may still receive generic advertisements and you may see targeted advertisements based on information collected and used by entities other than Personagraph.

7. How We Respond to Do Not Track Signals

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services that you visit. Like many websites and online services, we do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

8. How We Secure Consumer Information

We take commercially reasonable steps to protect and secure the consumer information that we store or process. However, no method of transmission over the Internet or electronic storage is 100% secure.

9. Other Important Information

Users Outside of the United States: We operate our Services from the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States and will be treated in accordance with United States law.

Changes to this Services Privacy Policy: We may change this Privacy Policy from time to time, and we will post the revised policy and provide notice on the Personagraph Website. Any changes will be effective as soon as we post the revised policy, unless a different date is stated.

Questions: If you have any questions, comments or concerns regarding our Services Privacy Policy and/or practices, you may contact us at legal@personagraph.com or by mail to 920 Stewart Drive, Suite 100, Attn: Legal Department, Sunnyvale, CA 94085.