Effective as of January 1, 2020
TrueData Solutions, Inc. (“TrueData”) is a technology company that provides clients with a unique combination of proprietary data solutions that function as an engine to maximize the impact of data on their growth. TrueData works with co-op providers (“Providers”) such as app publishers; brands; marketers; and data and technology companies that generate information about mobile devices, app ownership, and usage. TrueData offers data and technology solutions to marketers, brands, and other companies that use mobile data for Advertising Services (defined below), Data Modeling (defined below), analytics, and other related purposes (“Customers”). Collectively, these activities are referred to at the “TrueData Services.”
Some Helpful Terminology
“Advertising Services” include data services to marketers, brands, and other companies that use mobile data for ad targeting, audience creation, measurement, analytics, and other purposes associated with advertising via online or mobile channels including display, mobile, social, email, and video.
“CCPA” means the California Consumer Privacy Act (California Civil Code 1798.100-1798.199), a state law that addresses the privacy rights of California consumers. This law was passed at the end of June 2018 and finalized by the California State Legislature on September 13, 2019. It goes into effect on January 1, 2020.
We use “personal information” with the meaning given under the CCPA, and do not include certain de-identified or aggregated information, information publicly available in government records, or certain information excluded from the CCPA’s scope.
“Hashed Email Addresses”
We collect hashed versions of the email addresses that consumers have entered on our Partners’ mobile apps. Hashing is a technology process that pseudonymizes (i.e. digitally scrambles) email addresses. For instance, when [firstname.lastname@example.org] is run through a typical hashing function, it becomes the following string of digits such as JJI2120F0B7B1A1A7E8F8CCD6F8B6CC8498912058D5. We take this step to de-identify data and protect email addresses, while being able to use the unique identifier created for the purpose of rendering our identity mapping and other solutions (also called “cross-device matching”).
“Mobile Advertising ID”
A “mobile advertising ID” is a unique identifier for your device in the mobile advertising ecosystem. This can be Android’s Ad ID (AAID) or Apple’s Identifier for Advertisers (IDFA). (See the section below entitled “How to Limit Collection of Mobile Data” for guidance on how to change your device settings.)
“Data Modeling” is a process that includes a broad set of probabilistic, inferential, or mathematical techniques used to turn data into usable insights, intelligence, scores, or predictions.
Types of Data We Collect
From Your Device:
We collect the following types of data directly from your device unless you have opted-out or have otherwise refused to provide consent where required.
- Device Data. Device data tells about the device you’re using, such as its make; model; registered country code; mobile carrier; operating system and version; its unique identifier; crash data (if applicable); and what settings and permissions you’ve enabled. Your device and software settings affect what information your device makes available to us such as the language you prefer to use on your mobile device; mobile applications you install on your device and purchase you make in those mobile applications; bluetooth or wireless preferences; and the like.
- Unique Identifiers. We collect identifiers such as mobile advertising IDs, IP addresses, and hashed email addresses directly from your device as mentioned above and from our Providers.
- Geolocation Data. We collect location data such as latitude, longitude, and timestamps directly from your device as mentioned above and from our Providers.
- Demographic Data. We collect information such as your age or gender that you voluntarily provide when you install a mobile app or sign up for services via a mobile app.
Note that some of our data may fall into more than one of the above categories. For example, an IP address is both a unique identifier and device data.
From Our Data Providers:
In addition to the above, we receive device data, unique identifiers, geolocation data, and demographic data from our Providers that include mobile app publishers (e.g. games, content, retail, and other brands); marketers; and other types of data and technology companies that generate and share personal information and aggregated data or other information that is not personal information for Advertising Services, to create linkages among data elements, data modeling, analytics, and similar purposes.
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) or from other third parties or public sources that we use in providing the TrueData Services:
- Metadata from mobile apps
- Point of Interest data such as an identifier for a commercial location (e.g. a retail store or a coffee shop)
- Census data and other publicly available data sources
How TrueData Uses the Data We Collect
We combine personal information with the data in our database for the purposes of Advertising Services, analytics, making inferences, and Data Modeling for quality control on our data solutions. We also use personal information and other data for internal business purposes such as the development, enhancement, improvement, and release of new products and services. This allows us to create technology products that we license or sell to Customers. These products help our Customers understand their end users better in order to create enhanced experiences for them. We may use personal information to maintain and enhance TrueData Services, for example, to debug or research technical issues and resolve them.
The data may also be used in aggregated form (which is not personal information) to run analytics on certain customer segments, advertising campaigns, or other datasets.
We use the information that you provide or that we collect to understand and analyze the usage trends and preferences of our users for our internal business purposes, such as to improve the way the TrueData Services works, and to create new features and functionality.
TrueData Services contain mobile data received from our Providers and may be supplemented with publicly available information from time to time.
From time to time users of Are you in TrueData will provide their contact information and post inquiries or requests. We use this data only to verify and respond to the inquiries.
We may use personal information for legal or regulatory compliance or to assert or protect our rights.
We may disclose or share personal information that we have collected about you via the Site or when we provide TrueData Services to our Providers and Customers and as described below. We will not share personal information submitted through the Are you in TrueData other than in our responses to inquiries or requests.
- With our Customers and with our Providers: We provide TrueData Services to our Customers and Providers that include agencies; brands; mobile app publishers; and other companies that use data for Advertising Services such as targeting; audience creation; measurement; analytics; and other purposes associated with advertising via online or mobile channels including display, mobile, social, email, and video.
- With our Service Providers: Service providers are companies that provide TrueData with special business, technical, and operational services; and are different from Providers of data. We may also share your personal information with service providers and/or data processors to help us operate, provide, improve, understand, customize, support, and market our Services. For example, we use service providers for business operations such as Site and data hosting. We may also use service providers to assist us with providing our TrueData Services to Customers or Providers. Our service providers are contractually required to use personal information only to provide their service to us, and are contractually prohibited from using or disclosing personal information for their own purposes.
- In Connection with a Financing or Sale of Our Business: If a third party invests in, or acquires, some, or all, of our business or assets, we may disclose your information in connection with the sale (including during due diligence in preparation for the transaction).
- In Connection with Legal Obligations: We may disclose your personal information as required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights; protect your safety or the safety of others; investigate fraud; or respond to a government request. In certain situations, TrueData may also be required to disclose personal data in response to lawful requests by public authorities.
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.
You Can Find Out if You are in TrueData.
At any time, individuals may see if their information is listed in TrueData at Are you in TrueData.
You May Request Correction Or Removal Of Your Personal Information.
You may, at any time, request an update, to opt out of sale of your personal information, or to delete your personal Information in TrueData by sending an email request to email@example.com or by following the instructions at Are you in TrueData.
In order to honor your request to opt out of the sale of your personal information, we must use your email address to look for your information in our system. If we find your information, we will inform you by email, and explain how you can choose to block your data from further use by TrueData. We will retain your email in our system for legal record obligations under the CCPA and to ensure that your data is not re-ingested in the future.
How To Limit Collection of Mobile Data
You may opt out with the NAI Opt-Out Tool. TrueData is a member of the NAI and adheres to the NAI Code of Conduct. You may learn more about opting out of data collection on mobile devices at their website, and can also opt out of seeing personalized ads from NAI-approved member companies.
Note the following when using our opt out or data control mechanisms: If you use multiple devices, make sure you apply the opt out or data control mechanisms to all of your devices. We may not have all of your devices connected back to your user and you may need to perform opt outs on each device.
Other companies’ opt outs or data control mechanisms may function differently than ours. To stop receiving targeted ads that are based on your behavior across different mobile applications, follow the instructions below for iOS and Android devices:
On an Apple device, go to Settings / Privacy / Advertising. You can turn on “Limit Ad Tracking,” which will prevent advertisers from collecting your mobile advertising ID. You can also reset your mobile advertising ID, which will disconnect your mobile device from any information previously connected, in which case we do not attempt to connect data between the two advertising identifiers. When “Limit Ad Tracking” is enabled, we stop collecting your data on that mobile advertising ID.
On an Android device, go to Settings / Google / Ads. You can turn on “Opt-out of Ads Personalization,” which will prevent the use of your mobile ad identifier for advertising.
Note that when you opt out of targeted advertising, you will continue to receive contextual ads which are ads based on the content of the web page or app on which they appear.
For identifiable data that we hold on behalf of our Providers and Customers (e.g., their lists of hashed email addresses, location data, mobile advertising ID, and other identifiable data) that we received in providing the TrueData Services, we retain it for up to ten (10) years from the most recent date of receipt or until we receive a request to delete it.
TrueData uses reasonable security controls to protect mobile 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.
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, 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.
Your Specific Consumer Rights From the CCPA
These rights are not absolute and all requests are 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.
To protect the privacy of your personal information, we are required to verify your request. Verifiable requests must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to the request. To make a request to know or delete, 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.
When TrueData receives a consumer request, we make every effort to honor your request. We maintain records of all the requests received, the time it takes to respond to requests, and we track the outcomes of all requests.
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.
Right to Delete
You can make a request to delete any personal information TrueData has collected about 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.
Right to Opt-Out of Sale
California broadly defines “sale” to include using services to deliver targeted advertising on other sites or applications. This means an opt-out of sale request will likely have a direct impact on the types of advertisements the requestor receives. A valid request will make TrueData stop and refrain from selling any of your personal information. We will also communicate your opt-out of sale request to relevant third parties.
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.
Use of an Authorized Agent
Some Internet browsers allow users to send a “Do Not Track” signal to websites you visit. TrueData does not currently respond to this signal.
Via email at firstname.lastname@example.org
Via our webform to submit requests: Are you in TrueData
Via regular mail at the following address:
TrueData Solutions, Inc.
c/o TrueData Privacy Office
555 W 5th St, 35th Floor
Los Angeles, CA 90013