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Privacy

Statement on Privacy

We think that everyone has a fundamental right to privacy. We also believe that respect for privacy rights & consumer choice can coexist with an advertising ecosystem that accounts for consumer’s relevant and personalized interests and behavior. This data-driven ad ecosystem supports millions of small, medium, and enterprise-sized publishers that create valuable content and monetize it through advertising. The more relevant that advertising is, the more revenue these publishers generate, and the more free content they can create. Further, this advertising ecosystem creates highly skilled jobs not only at publishing & media companies, but also data & technology companies, and brands. If executed well, there is a clear path for the ad ecosystem to benefit consumers, publishers, and brands, in a privacy-centric way.

We were excited to build our business when the Mobile Advertising ID (MAID) was first introduced because it offered a privacy-safe way to map data to consumers. It gave consumers the flexibility to stop ad tracking or reset their MAID anytime they wanted. It was a needed and positive evolution from the privacy-fraught cookie infrastructure of web browsers.

As part of our commitment to privacy rights, TrueData welcomes the new crop of privacy regulations that started in Europe, California and are now moving across the globe. We are advocates for national comprehensive privacy regulations, especially for the United States. Improved privacy regulations create a brighter future for those who create and consume content online. Consumers will be better informed about and have more control over how information about them is used. With clear and uniform privacy regulations, companies also benefit from shared rules of the road for operating and planning their businesses.

TrueData Privacy Policy

Effective as of June 1, 2022

1. TRUEDATA’S SERVICES

TrueData Solutions, Inc. (“TrueData”) is a technology company that provides clients with proprietary data solutions, including those that help publishers drive ad revenue and brands find great customers. TrueData works with co-op providers  (“Providers”) such as app publishers, brands, marketers, and data and technology companies that generate information about people and devices, such as app ownership, and app usage.  TrueData offers data and technology solutions to publishers, brands, and other companies that use data for Advertising Services (defined below), Data Modeling (defined below), analytics, and other related purposes; as well as for non-advertising research and analysis of consumer behavior (“Customers”). Collectively, these activities are referred to as the “TrueData Services” or the “Services.”

2. SCOPE OF THIS PRIVACY POLICY

This TrueData Privacy Policy (“Privacy Policy”) covers the information that we collect or receive from the following sources:

Data request form and web portal: “DO NOT SELL MY PERSONAL INFORMATION PAGE”. Please note: third parties have their own privacy policies and this Privacy Policy does not apply to their chosen policies related to collection, use, storage, destruction, disclosure, and/or processing of any information the third parties handle.

3. SOME HELPFUL TERMINOLOGY

We use some phrases in this Privacy Policy that are unique to our business or the technology underlying our data engine. Here are definitions of some of the key terms that you’ll need to know to make it easier to understand this Privacy Policy.

“Advertising Services”

Data services to marketers, brands, and other companies that use the information collected by TrueData for ad targeting, audience creation, measurement, analytics, and other purposes associated with advertising (regardless of medium or channel) via online or offline channels including display, mobile, social, email, direct mail, and video.

“CCPA”

The California Consumer Privacy Act (California Civil Code 1798.100-1798.199), a California state law now in effect that addresses the privacy rights of California consumers. 

Personal Information

“Personal information” is the meaning employed by CCPA, which is 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 certain de-identified or aggregated information, information publicly available in government records, or certain other information excluded from the CCPA’s scope.

“Email Addresses”

e collect versions of email addresses that consumers have entered on our Partners’ registration, checkout, or other such forms.

“Mobile Advertising ID”

A “mobile advertising ID” or “MAID” is a unique identifier of a mobile device used in the mobile advertising ecosystem. This can be Android’s Ad ID (AAID) or Apple’s Identifier for Advertisers (IDFA). 

“Data Modeling”

“Data Modeling” is a process that includes a broad set of probabilistic, inferential, or mathematical techniques used to turn raw data into useful insights, intelligence, scores, or predictions.

4. TYPES OF DATA WE COLLECT

We collect data, including Personal Information, from the following categories of sources.

A. From Your Internet-Connected Devices:

We collect or receive the following types of information, from websites, mobile apps, data aggregators, public sources and our technology (or other, similar means): 

Note that some of our information we collect may fall into more than one of the above categories. For example, an IP address is both a unique identifier and device data.

B. From Third Parties and Aggregated Public Sources:

We may collect information from public and private sources of aggregated data (e.g. the Apple App Store and the Android Play Store), website crawling, or from other third parties or public sources that we use in providing the TrueData Services:

C. In Our Corporate Capacity and From our Site

People who visit TrueData’s Site are generally representatives of businesses (such as for our Providers or our clients) that are interested in TrueData’s Services, not individual consumers.

When individuals visit our Site, they may choose to provide information to us, such as when they create or log in to their account with us, to contact us to request or provide information, or apply for a job.  In addition, when you interact with our Site, we (and third parties) may collect technical information from your browser or device by automated means such as pixels, cookies, web beacons, local storage, JavaScript, API, and other similar technologies.  We may also collect this kind of information when you interact with email messages we have sent you.  As we and our service providers develop other technologies, we may also gather information through other methods.

We may collect the following categories of information from our Site:

We may also sometimes collect information through business channels and Events such as trade shows, or through marketing platforms that help us identify new customers. 

5. HOW TRUEDATA USES THE DATA WE COLLECT

We use the information we collect under this Privacy Policy for the following purposes:

When we create certain databases (such as, to help companies market to consumers across various devices or methods), we may de-identify or otherwise obfuscate certain personal information for privacy or security reasons. 

6. DATA SHARING

As to the personal information that we collect in the course of operating our Services, we may share and disclose such information as follows: 

7. HOW TO CONTROL DATA COLLECTED ABOUT YOU

We recognize that your privacy is important to you, so we offer the following ways to give you control over the data that we collect from you.

Opting out of Tailored Advertising:

We recognize that your privacy is important to you, so we offer the following ways to give you control over the data that we collect from you.

Opting out of Tailored Advertising:

We use and share information we collect from both online and offline sources to inform the advertising you see online and to tailor it to your interests.  This may include using information collected across the online applications you use (such as on mobile devices, web browsers, or internet-connected televisions), or information associated with hashed email addresses or other hashed identifiers.

The Network Advertising Initiative (NAI) maintains a site with tools and instructions for how to opt out of Tailored Advertising by NAI member companies.  TrueData is a member of the NAI and adheres to the NAI Code of Conduct. To opt out of Tailored Advertising by TrueData and other NAI member companies, please visit:

https://optout.networkadvertising.org

Further, we also support our own TrueData Opt-Out process. We strive to respond to requests from residents of other jurisdictions outside California. If you use multiple devices or multiple email addresses, make sure you apply the opt out or data control mechanisms provided to all of the web browsers, internet-connected devices, and email addresses you use for a complete opt-out. Opting out using a single browser, device, or email address will not automatically opt out all browsers, devices, or email addresses you use.

Other companies’ opt outs or data control mechanisms may function differently than ours. Note that when you opt out of Tailored Advertising, you may continue to receive contextual ads which are ads based on the content of the web page or app on which they appear.

California Residents:

If you are a California resident, you may have additional rights in connection with the data we collect about you. To learn more about these rights and how to exercise them, please refer to section 11 of this Privacy Policy.

8. DATA RETENTION

We may retain data for use with the TrueData Services for up to 30 months from the most recent date of receipt, or a shorter period where that is required by law. We may archive and store backups of those data for up to 10 years.

9. SECURITY MEASURES

TrueData uses security controls designed to protect information from loss, misuse, and unauthorized access. However, no security control is one hundred percent secure, and thus, TrueData cannot guarantee the absolute security of your information.

10. CHANGES TO THIS PRIVACY POLICY

Changes to this Privacy Policy will be posted on this page. If we make a material change to our privacy practices, we will provide notice on our Site or by other means as appropriate. If we are required by applicable data protection laws to obtain your consent to any material changes before they come into effect, then we will do so in accordance with law.

11. ADDITIONAL RIGHTS FOR CALIFORNIA CITIZENS

Your Rights Under the CCPA

Under the CCPA, California residents have certain rights around TrueData’s collection, use, and sharing of their personal information.

The below chart summarizes the categories of personal information we collect when we act as a “business” under the CCPA, where we collect it from, how we use it, and who we share it with.  This chart is updated in an annual review and reflects the prior twelve (12) months from the date of last review.

CATEGORIES COLLECTED EXAMPLE DATA ELEMENTS SOURCES WE COLLECT FROM PURPOSES BEHIND COLLECTION, USE, AND SHARING CATEGORIES OF THIRD PARTIES WE DISCLOSE TO
IDENTIFIERS MOBILE ADVERTISING ID

IP ADDRESS

EMAIL ADDRESS

NAME (FIRST AND LAST)

MAILING ADDRESS

UIDv2.0

CTV IDs (ifa, ifa_type)

PHONE NUMBER

COOKIES, COOKIE IDS, AND OTHER SIMILAR ONLINE IDS

YOUR DEVICE

OUR PROVIDERS

ADVERTISING SERVICES

ANALYTICS

DATA MODELING

LEGAL

FRAUD OR DECEIT DETECTION

CUSTOMERS

OUR PROVIDERS

DEMOGRAPHICS AGE

GENDER

LANGUAGE

EDUCATION

EMPLOYMENT

ETHNICITY

HOMEOWNER

HOUSEHOLD INCOME AND SIZE

EMPLOYMENT RELATED INFORMATION

INDUSTRY

MARITAL STATUS

PRESENCE AND NUMBER OF CHILDREN

TIMEZONE

YOUR DEVICE

OUR PROVIDERS

ADVERTISING SERVICES

ANALYTICS

DATA MODELING

CUSTOMERS

OUR PROVIDERS

GEOLOCATION DATA LATITUDE

LONGITUDE

TIMESTAMP

COUNTRY CODE

ADDRESS

ALTITUDE

SSID/WIFI

ACCELEROMETER

YOUR DEVICE

OUR PROVIDERS

ADVERTISING SERVICES

ANALYTICS

DATA MODELING

CUSTOMERS

OUR PROVIDERS

COMMERCIAL INFORMATION PURCHASE & TRANSACTION DATA YOUR DEVICE

OUR PROVIDERS

ADVERTISING SERVICES

ANALYTICS

DATA MODELING

CUSTOMERS

OUR PROVIDERS

DEVICE & SITE DATA DEVICE CHARACTERISTICS

APP INSTALL DATA

SITE VISITATION DATA

TIMESTAMP

PRIVACY SIGNALS

AMBIENT SIGNALS

YOUR DEVICE

OUR PROVIDERS

ADVERTISING SERVICES

ANALYTICS

DATA MODELING

CUSTOMERS

OUR PROVIDERS

INFERENCES DRAWN TO CREATE A PROFILE ABOUT A CONSUMER

SUCH AS PREFERENCES, CHARACTERISTICS, PSYCHOLOGICAL TRENDS, PREDISPOSITIONS, BEHAVIOR, ATTITUDES, INTELLIGENCE, ABILITIES, AND APTITUDES.

YOUR DEVICE

OUR PROVIDERS

ADVERTISING SERVICES

ANALYTICS

DATA MODELING

CROSS-DEVICE LINKING DATA MOBILE ADVERTISING ID

CTV IDs (ifa, ifa_type)

DETERMINISTIC SHARED IDENTIFIERS

HOME IP

YOUR DEVICE

OUR PROVIDERS

ADVERTISING SERVICES

ANALYTICS

DATA MODELING

CUSTOMERS

OUR PROVIDERS

Your Specific Rights Under the CCPA

The CCPA grants certain rights to residents of California regarding their personal information.  If you are a natural person who resides in California (a “Consumer”), this section of the Privacy Policy applies to you.  If you are not a Consumer, this section does not apply to you and you should not rely on it.

These rights are not absolute and may be subject to exceptions and verification.  TrueData may be required or permitted by law to decline any request.  Only you, a person that you authorize to act on your behalf, or an entity registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to accessing or deleting your personal information.

A. Right to Access

You can make a request to access the categories or specific pieces of personal information TrueData collected, used, or shared about you in the past twelve (12) months.  Along with your verified request, we will give you any categories of sources from which the personal information is collected; the purpose for collecting, selling, or sharing; and any categories of third parties with whom we share such personal information. 

B. Right to Delete

You can make a request to delete any personal information TrueData has collected from you. Upon receiving a verified request, TrueData will notify you once your information has been deleted. We will also communicate your deletion request to our Customers and direct them to delete your personal information.

C. How to Exercise your Access and Deletion Rights

There are two ways to submit a request to access or delete your personal information. First, you may submit a request at ACCESS OR DELETE MY DATA PAGE. Second, you can submit your request via our toll-free number: (888) 868-5427. We are unable to process faxed requests at the toll-free number provided; if you would like to submit your request to us using our toll-free number,  please use a telephone to submit your request verbally. After the tone please very slowly state your email address and please also leave your telephone number as well, and we will contact you with the instructions on how to proceed with your request. When you finish recording you may hang up or press the pound key for more options. 

To protect the privacy and security of your personal information, we will attempt to verify your identity before acting on your request.  Your request must include details sufficient for us to properly understand, evaluate, and respond to the request.  To verify your request to know or delete, we may need to request additional information from you, and, in certain circumstances, we may ask you to verify your identity and proof of California residency, which may include a signed declaration under penalty of perjury that you are the individual whose personal information is the subject of the request.  

Please also note that as part of the verification process, we’re required to consider (a) the difficulty of verifying whether data that we hold and data we have linked to it truly and solely belongs to the data subject making the request, along with (b) the potential adverse effects on disclosure of personal data to the wrong individual (or a person who is purposefully seeking the information of another).  Because such improper disclosure would likely adversely affect the privacy rights and freedoms of the relevant data subject/consumer, we limit certain personal data we make available.  In particular, we believe that in most cases we cannot verify to a sufficiently high degree that precise location data we have collected pertains to the person who has submitted the request, or whether either the person in possession of a device or the person requesting the information is the actual device owner.  (For instance, some people may be temporarily in possession of another person’s phone – e.g., a partner, friend or work colleague – whether consensually or not, and many phones are not password-protected).  

D. Right to Opt-Out of Sale

California Consumers have the right to opt out of “sales” of their personal information.

The CCPA’s broad definition of  “sale” may include using services to deliver targeted advertising on other sites or applications. This means that if you make a request to opt out of TrueData’s “sales” of personal information, it will likely have a direct impact on the types of advertisements you see online. TrueData will honor requests to opt out of “sales” of your personal information. 

There are two ways to submit a “request to opt-out of the sale” of your personal information. First, submit a request at DO NOT SELL MY PERSONAL INFORMATION PAGE. Second, you can submit your request through the email at privacy@truedata.co.  In the subject line, include “CCPA Consumer Request,” and note in the body of the email that you would like to opt-out of sale.

E. Right to Non-Discrimination

TrueData values giving consumers control over their privacy and personal information.  If you choose to exercise any of your rights under the CCPA, we will not differentiate our services as a result of your decision.  We also do not offer any financial incentives to opt-in to sell your personal information.

F. Use of an Authorized Agent

You can appoint a person or a business entity registered with the Secretary of State to act on your behalf. In order to do so, you must provide the authorized agent with written permission to do so, and a power of attorney that fulfills the requirements of the CCPA. TrueData may request more information from the authorized agent (or from you) if needed to verify the authorized agent’s identity or to avoid any breach of security or instances of fraud.

G. Minors

We do not knowingly collect personal information of minors under the age of 16, nor are our Sites or Services developed for, offered to, or directed at children under the age of 16. If you believe that we have collected information of a child under the age of 16, please contact us and we will take appropriate action. 

H. TrueData as a Service Provider

Sometimes we act as a “Service Provider” to other companies — for instance, when we help other businesses use their own customers’ information for marketing, analytics, or other services.  As to personal information that we hold as a “Service Provider,” you would generally need to reach out to the business (our customer) to exercise your CCPA rights.   

12. THE GDPR AND SIMILAR LAWS:  YOUR DATA CHOICES AND ACCESS RIGHTS

If you are a resident of one of many European countries, including the United Kingdom, an important European privacy law (or an equivalent counterpart to it) the General Data Privacy Regulation (the “GDPR”) provides you with certain rights, and places certain obligations on companies regarding how your “personal data” (as the GDPR uses that term) is used.  We describe those rights and obligations below, and how and in what circumstances we honor them.  

You may have similar rights in countries that have adopted statutes similar to the GDPR, such as Brazil and Turkey.

We set out our compliance with the GDPR and, to the extent applicable, those other laws, in this section.

Legal Basis. The GDPR requires us to tell you about the legal ground we’re relying on to process any “personal data” (as the GDPR uses that term) about you. The legal grounds for us processing your personal data for the purposes set out in Section 2 above will typically be because:

Your rights to deletion or revocation of consent (sometimes referred to as a right to be forgotten, to restrict processing, or to otherwise object to processing).  You have the right to request that we delete your personal data (or where applicable, withdraw your prior consent to our processing your data).  You may also request that we correct or “rectify,” restrict or delete your personal data.   You may exercise these rights by contacting us at privacy+international@truedata.co or through our website privacy portal located at  https://info-prod.truedata.co/access-delete-request .  If you request that we delete your personal data, or withdraw your consent, we will customarily retain a copy of your data sufficient to suppress it from our active databases in the future:  but if that is not what you wish, you may indicate that to us (in which case your information may be added to our database later, because we will not have “suppressed” it).

Moreover, when we delete your personal data, we may retain it (to the extent legal permissible) for certain important (but narrow) internal purposes such as legal, compliance, accounting or auditing purposes, and in some cases, for security purposes.  

Personalized Online Advertising Opt-Outs.  You may object to profiling by online advertising platforms with whom we sometimes partner to help generate (and measure or analyze) “personalized” online advertising.  These platforms are generally separate third party “controllers” of your data.  You may visit industry websites provided at [https://optout.aboutads.info) (by the Digital Advertising Alliance) and https://optout.networkadvertising.org/ (by the Network Advertising Alliance) or https://www.Youronlinechoices.eu/ (the European Digital Advertising Alliance) to do so, as to many of the largest platforms involved in personalized online advertising.

You may unsubscribe from marketing and other communications that we may send (on behalf of ourselves or others) by clicking the “opt-out” or “unsubscribe” link in the footer of those emails. 

Your right to access your personal data.  In some jurisdictions, you may have the right to request access to a copy of your personal data.  You may request access to the personal data we hold about by visiting the web page at https://info-prod.truedata.co/access-delete-request.  when you request access to your information, we are required — for privacy and other important compliance reasons — to verify your identity in a legally sufficient manner: if we cannot do so, we will not be able to satisfy your access request.

Please note that as part of the verification process, we may not be able to sufficiently “verify” your identity in a manner sufficient to safeguard against the potential adverse privacy effects on disclosure of personal data to the wrong individual (or a person who is purposefully seeking the information of another).  Because such improper disclosure would likely adversely affect the privacy rights and freedoms of a relevant data subject/consumer, we limit certain personal data we make available.  In particular, we believe that in most cases we cannot verify to a sufficiently high degree that precise location data we have collected pertains to the person who has submitted the request, or whether either the person in possession of a device or the person requesting the information is the actual device owner.  (For instance, some people may be temporarily in possession of another person’s phone – e.g., a partner, friend or work colleague – whether consensually or not, and many phones are not password-protected.)  Where that is the case, we may provide a subset of the data that we hold.

Questions or Concerns.  If you have a complaint or concern or question about how we handle your personal data, please contact us as at the above contact addresses, and we will seek to address any concerns you may have.  If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority.

When We are a Processor.  EU data protection law (and certain other data protection laws) makes a distinction between organizations that process personal data for their own purposes (known as “data controllers”) and organizations that process personal data on behalf of other organizations (known as “data processors”).   TrueData sometimes acts as a data controller (for instance, when we make decisions about the data that comprises our own datasets) and sometimes acts as a processor (for instance, if we ingest information that belongs to a customer, such as to analyze it solely for their benefit and at their direction).   We generally are only able to help data subjects exercise their rights as to data we are a data controller of.   If you have a question or request as to data we’re a processor of, you should generally address that to the relevant data controller.

CONTACT TRUEDATA

If you have any questions regarding our Privacy Policy or our privacy practices, or about TrueData generally, you can contact us by any of the following methods:

Via email at privacy@truedata.co

Via regular mail at the following address:

 

TrueData Solutions, Inc.

c/o TrueData Privacy Office

1325 Palmetto St, Suite 108

Los Angeles, CA 90013