BoldWin – Privacy Notice
Last updated: June 2026
About this Privacy Notice
This Privacy Notice is meant to give you information about what personal data we collect about you, how we use it, why we use it, and how you control the data processing.
Table of Contents
1.The Basics: Who We Are, Our Role, and Definitions
2.Personal Data We Collect, How We Use it, and Why
2.1.Visitors to Our Website and Social Media Pages
2.2.Customers
2.3.Prospective Customers and Partners
2.4.Visitors to Publisher Assets
3.Marketing Services
4.Sharing the Personal Data We Collect
5.International Transfers
6.Security
7.Your Rights - How to Control Our Use of Your Personal Data
8.Data Retention
9.Cookies and Similar Technologies
10.Third-Party Services
11.Children
12.Changes to the Privacy Notice
13.Annex A – Your Rights Under CCPA
14.Annex B – Our Data Partners
1.The Basics
1.1.Who We Are
1.1.1.Boldwin Ltd. is a global ad-tech company that operates and provides an online supply-side platform. Our offices are located at Shvil Hameretz 4, Tel Aviv – Yafo, Israel, and our registration number is 515564979.
1.1.2.If you have questions about our company or your privacy, or want to exercise your rights, you can contact us at [email protected].
1.1.3.We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:
•United Kingdom (UK)
•European Union (EU)
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter, or make use of your data subject rights, please visit the following website: https://app.prighter.com/portal/bold-win.
1.2.Our Role: Controller and Processor. Certain data protection laws, including the laws in the EU, differentiate between a party that determines why and how personal data is processed (called a "controller") and a party that processes personal data solely on the controller's behalf and according to the controller's instructions (called a "processor"). We are the controller with respect to the processing described in this Privacy Notice.
1.3.Definitions and Recommendations
1.3.1.When we refer to "services", we mean services available through our platform.
1.3.2.When we refer to "personal data", we mean information that is defined as personal data under law. This includes information that identifies you directly or indirectly, including unique identifiers like IP addresses or cookie IDs.
1.3.3.When we refer to "you", we mean visitors to our website any user of our platform on behalf of our customers (called a "platform user"), or any visitor to the assets on which we place ads.
1.4.A Note on Legal Bases. Certain jurisdictions only allow the processing of personal data where a legal basis has been established. Under the EU's General Data Protection Regulation ("GDPR"), the possible legal bases include (but are not limited): your consent, the processing is necessary to perform a contract with you, the processing is necessary to fulfill our legal obligations, or a company has a legitimate business interest to process your personal data.
2.Personal Data We Collect, How We Use It, and Why. Below is a description of the types of personal data we collect, how we use it, and the reason why we consider each use lawful. You have no legal obligation to provide us with personal data, but if you don't provide us with certain information, we may not be able to provide you with the associated services. For the avoidance of doubt, we may also use personal data to enforce our rights, enforce our contracts, protect our assets, and pursue available remedies or limit damages we may sustain.
2.1.Visitors to Our Website and Social Media Pages.
2.1.1.Contact Form Information – When you send us a message through the contact form on our site, we collect any data you provide, such as your name, phone number, email, and the content of your message.
How We Use this Data: To respond to your message.
Legal Basis: We process this personal data based on the performance of a contract with you.
2.1.2.Activity and System Data (including Cookies) – When you visit our site, we automatically collect data about your computer or mobile device, including personal data such as your IP address, device ID, browsing history (e.g. the other sites you've visited before ours), and your activity on our site (e.g. what pages you visited, for how long, and what links you clicked on). For more information about the cookies we use and how to adjust your preferences, see the Cookies and Similar Technologies section below.
How We Use this Data: We use this data to provide and maintain the website (e.g., load balancing, security, and fraud prevention). We also use aggregated analytics to understand usage of the website and to improve it and develop new services. One of the tools we use to collect and analyze this data is "Google Analytics". For more information about how Google collects information and how you can control such use, see: www.google.com/policies/privacy/partners/.
Legal Basis: When we process this personal data to provide and maintain our site and/or through strictly necessary cookies, we do so to perform a contract with you. When we process this personal data to improve our products and services, develop new products or services, and to prevent fraud, we do so based on our legitimate interests to develop and improve our products and services, and to prevent fraud. For analytics cookies and similar technologies, we rely on your consent.
2.1.3.Visitors to Our Social Media Pages – When you engage with our social media outlets, such as when you post on our Facebook or LinkedIn pages, like our posts, answer surveys, or similar activities, we collect the personal data you provide, such as the content of your post and the information available to us through your profile or account. The social media companies we use may also provide us with aggregate and analytical information about activity relating to us.
How We Use this Data: We may use this information to engage with you or respond to your posts and comments and to analyze the effectiveness of our social media efforts and to improve how we manage them.
Legal Basis: When we process your personal data to engage with you or respond to your posts and comments, we do so on the basis of our legitimate interest to engage with and serve our audiences in an effective manner. When we process your personal data to improve our social media outlets, we do so based on our legitimate interest to improve our services, and develop new ones.
2.2.Customers.
2.2.1.Business Contact Details. If you represent a customer using our services, we collect basic contact details about you, including your name, email address, phone number, job title, and the company you represent.
How We Use this Data: We use this information to allow you to access our services, prevent fraud, and address any issues that arise. We use your contact details to communicate with you about our services and/or to send you marketing and promotional materials about our products and services.
Legal Basis: When we process your registration data to provide you with our services, we do so to perform a contract with you, in this case our customer agreement. When we process your registration data to maintain our services, including to prevent fraud, protect the security of and/or address issues with our services, we do so on the basis of our legitimate interest to maintain our assets. When we send you marketing communications, we do so based on your consent, which you may withdraw at any time. We may also use engagement metrics (e.g., opens and clicks) derived from cookies and similar technologies embedded in marketing materials we send you; for more information, see the Cookies and Similar Technologies section below.
2.2.2.Platform Users. If you are a platform user, we process the following information from and about you.
2.2.2.1.Registration Data – In order to access our platform, we will create an account for you. For creating an account, you will be asked to provide your name and email address.
How We Use this Data: We use your registration information to allow you to access our platform, save your preferences, protect the security of our platform, prevent fraud, and address any issues that arise. We use your contact information to send you promotional materials about our services.
Legal Basis: When we process your data to provide you with our platform and services, we do so to perform a contract with you, in this case our agreement with the customer on whose behalf you access our platform. When we process this data to maintain our platform, including to prevent fraud, protect the security of and/or address issues with our platform, we do so on the basis of our legitimate interest to maintain our assets. When we process your data to send you promotional materials about our services, we do so based on your consent, as may be required under applicable law, which may be revoked at any time, including by contacting us at
2.2.2.2.Activity and System Data (Cookies) – If you are a platform user, when you access and use our platform, we collect data about your activity and the systems you use, including IP address, device ID, user agent, session identifiers, and usage data (such as login times, features accessed, and actions taken within our platform). This data may be collected via necessary cookies and non-necessary cookies, as detailed in Section 2.1.2.
How We Use this Data: We use this data to (i) provide you with our platform and maintain our platform, including security, fraud prevention and addressing problems, and (ii) generate aggregated analytics data about the use of our platform so we can maintain and improve the platform and develop new products or services.
Legal Basis: When we process this personal data to provide and maintain our site and/or through strictly necessary cookies, we do so to perform a contract with you. When we process this personal data to improve our products and services, develop new products or services, and to prevent fraud, we do so based on our legitimate interests to develop and improve our products and services, and to prevent fraud. For analytics cookies and similar technologies, we rely on your consent.
2.3.Prospective Customers and Partners. If you are a contact person of a prospective customer or partner, we may process your business contact information, including your name, email, phone number, position with such prospective customer or partner. We may also obtain enrichment data about you and your organization from third-party data providers (such as business intelligence platforms, lead generation services, and professional networking sites) to help us identify potential business opportunities, qualify leads, and personalize our outreach.
How We Use this Data: We use this data to identify and evaluate potential business relationships, conduct sales and marketing outreach, present our services, respond to inquiries, and maintain records of our business development activities.
Legal Basis: When we process this data for entering into the contract with the applicable customer or partner, we do so in performance of a contract or to take steps at the request of the relevant customer or partner prior to entering into a contract. When we process for the other purposes, we do so on the basis of our legitimate interests to grow our business, identify potential customers and partners, and market our Services.
2.4.Visitors to Publisher Assets. Through our services, we enable third-party publishers to display online advertisements to end users who use or otherwise interact with certain mobile webpages and desktop websites of the publishers. In the course of providing the services, we collect or receive the following personal data from such end users: IP address, device ID, user agent, and browsing history (e.g. the sites you visited before visiting the publisher's site). We also process geo-location data from such end users' devices (derived from IP address), which may include end users' location to a relatively precise degree, depending on the device settings.
How We Use this Data: We use this data to: (i) facilitate real-time auctioning of ad inventory to advertisers and their platforms, including by matching visitors across sessions for frequency capping (limiting how often you see the same ad), attribution (measuring ad effectiveness) and to identify visitors' interests to match relevant advertisements; (ii) detect and filter bot traffic, invalid traffic or other fraudulent or malicious activities, to protect our interests and assets and those of publishers and partners; and (iii) derive aggregated and anonymized insights based on the foregoing data to analyze trends and insights, to improve ad delivery and optimize our services.
Legal Basis: When we process this data to provide advertisements to you, we do so based on your consent, as obtained by the relevant publisher. You may withdraw your consent at any time by contacting the publisher directly. Additional information regarding Marketing Services is provided below. When we process this data for fraud detection, security purposes, and service optimization, we do so on the basis of our legitimate interests to maintain and improve our services, and to maintain the integrity of our, the publishers' and our partners' assets.
3.Marketing Services. As described above, we may use personal data we collect for advertising and marketing purposes as part of the services we provide to our customers (publishers). In the digital advertising ecosystem, visitors data flows between multiple parties to facilitate real-time advertising. When a visitor interacts with a publisher digital asset where our services are implemented, we collect the data described above and share it with partners and participants in the real-time bidding (RTB) process. This includes supply-side platforms (SSPs) that represent publishers' ad inventory, demand-side platforms (DSPs) that represent advertisers' buying interests, ad exchanges that facilitate the auction process, and ultimately advertisers and their advertising agencies who bid on and purchase ad placements. We also share such data with our partners who provide data enrichment services (such as adding demographic or interest-based insights to user profiles), identity synchronization services (to match user identifiers across different platforms for consistent ad experiences), and advertising technology solutions that support ad delivery and measurement. Each of these parties acts as a controller of the data and processes such data in accordance with their respective privacy notice and applicable legal requirements. A list of our current main partners, including identity resolution and data enrichment providers, is available in Annex B to this Privacy Notice.
3.1.Web Ads. We serve online ads based on the activity data we collect using cookies. You can change the way your browser manages cookies by adjusting the settings on your browser as explained below in the How to Adjust Your Preferences section.
3.2.Mobile Ads. Each mobile device is given a unique string of letters and numbers called a "Device ID." Device IDs are retrieved by apps and used to perform various functions, such as to communicate with servers. We use Device IDs to serve you with ads. Device IDs can be used to track which apps were downloaded by the particular device as well as in-app activity on that device. This information, especially when combined with other identifying information, gives us insights into the preferences and interests of the owner of a given device and allows us to serve you with ads that we believe will appeal to you.
3.3.Android Advertising ID. We collect Android's advertising identifier (AAID) from your device for advertising and user analytics only. We do not connect AAIDs to persistent device identifiers for advertising purposes. When we connect AAIDs to other personal data, we do so based on your explicit consent. When we use AAIDs for analytics purposes, we do not connect it with any other personal data. We use AAIDs in accordance with Google Play's Ads Policy.
4.Sharing the Personal Data We Collect. We share your personal data as follows:
4.1.Advertisers, Publishers and Partners. Data that is collected through publisher's assets as part of our provision of the services may be shared with the relevant publisher or advertisers placing advertisements on such assets. As part of our advertising services, we also work with identity resolution providers, such as ID5, to match user identifiers across different platforms and devices for consistent advertising experience. For details on the main partners we work with, please see Annex B below. Advertisers, publishers and other partners are able to combine the personal data they collect independently with personal data we share with them and are considered separate, independent controllers of such data. For more information about how these parties process your personal data, please contact them directly.
4.2.Service Providers. Below is a list of the types of service providers we use, the service each provides, and the types of data shared with each. All service providers have agreed to confidentiality restrictions and have undertaken to use your personal data solely as we direct.
Type of Service | Description | Personal Data Shared |
|---|---|---|
Cloud Computing | We use service providers that offer cloud computing services. They offer us space on their servers for us to store our files and programs, including your personal data. | All personal data that we collect is stored on third party servers. |
Customer Relationship Management (CRM) | We use an external CRM tool to help us keep track of our customers and information related to them, including their personal data. | Your name, company, position, email address, and phone number. |
Email Marketing | We use an independent vendor to send out marketing emails on our behalf. | Your name, position in your organization, and email address. |
Analytics Providers | We use a service provider to assist us with analytics services as well as fraud detection services. | Data collected automatically through our site and services, including IP addresses and cookie information. |
Business Intelligence and Market Research | We use business intelligence and market research services to provide us with company information, mobile app data, and contact details. | IP address, user agent, company and contact information |
4.3.Change of Ownership. If we are looking to sell our company, liquidate assets, or merge with another, we may share your personal data with other interested parties as part of negotiations toward that transaction. In such case, or where we do sell our company, your personal data shall continue to be subject to the provisions of this Privacy Notice.
4.4.Law Enforcement Related Disclosure. We may share your personal data with government agencies or other relevant parties, such as a law office or independent auditor: (i) if we believe that such disclosure is appropriate to protect our rights, property or safety (including the enforcement of this Privacy Notice) or those of a third party; (ii) if required by law or court order; or (iii) as is necessary to comply with any legal and/or regulatory obligations, such as audit requirements.
5.International Transfers. Some of our service providers are located in countries other than your own. When we transfer your personal data internationally, we will do so safely and securely and in accordance with applicable law.
5.1.If you are located in the EU, when we share your personal data with third parties based outside of the European Economic Area ("EEA"), we will ensure that they sign on agreements that require them to comply with applicable law, keep your data secure at similar levels to the level described in this Privacy Notice, and make sure that your data protection rights are protected. We will also implement the following safeguards:
5.1.1.When we transfer your personal data to Israel or the UK, we rely on the decision by the European Commission that says that those countries are considered to provide an adequate level of data protection.
5.1.2.When we transfer your personal data to entities in the US that are covered under the Data Privacy Framework (DPF), we rely on the decision by the European Commission that determines that these entities are considered to provide an adequate level of data protection.
5.1.3.Where we transfer your personal data to other countries or to entities not covered by the DPF, we (i) take additional security measures to protect the data and (ii) use specific contracts approved by the European Commission, known as the Standard Contractual Clauses, to give your personal data the same protection it has in the EEA.
5.1.4.Please contact us at [email protected] or [email protected] if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6. Security. The security of your personal data is our highest priority. We work hard to make sure that your personal data will be held securely and that it will not be shared or lost accidentally. However, it is impossible to guarantee absolute security. The security of your data also depends on the security of the devices you use and the way in which you protect your user IDs and passwords. These measures include:
6.1.Technical Measures. The electronic safeguards we employ to protect your personal data include secure servers, firewalls, expiration mechanism, and antivirus protections. If you are a visitor to a publisher digital asset on which our services are implemented, we encrypt your IP address, User IDs and similar data in transit using secure TLS 1.3 protocols, as well as implementing pseudonymization techniques such as IP masking and hashing identifiers.
6.2.Organizational Measures. We limit access to your personal data only to authorized personnel who have a need to know, including account managers, customer support staff, and software developers. We review these permissions regularly and revoke an employee's access immediately after his/her termination. We require employees to sign non-disclosure agreements according to applicable law and industry customary practice.
7.Your Rights - How to Control Our Use of Your Personal Data. Depending on which laws apply, you have certain legal rights over your data. Below is some general information about rights that may apply to you but we recommend checking the law or consulting with a lawyer to understand what applies in your specific case. To exercise your rights, please contact us at [email protected]. If you want to exercise your rights regarding your personal data held by other controllers you can contact the applicable controller directly. We may ask for reasonable evidence to verify your identity before we can comply with any request.
7.1.Right of Access. You may have a right to know what personal data we collect about you. We may charge you a fee to provide you with this information, if permitted by law. If we are unable to provide you with all the information you request, we will do our best to explain why. See Article 15 of the GDPR for more details, if your personal data is subject to GDPR.
7.2.Right to Correct Personal Data. You may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data. See Article 16 of the GDPR for more details, if your personal data is subject to GDPR.
7.3.Deletion of Personal Data ("Right to Be Forgotten"). If you are located in the EU, you may have the right to request that we delete your personal data. Note that we cannot restore information once it has been deleted. Even after you ask us to delete your personal data, we may be allowed to keep certain data for specific purposes under applicable law. See Article 17 of the GDPR for more details, if your personal data is subject to GDPR.
7.4.Right to Restrict Processing. If you are located in the EU, you may have the right to ask us to stop processing your personal data. See Article 18 of the GDPR for more details, if your personal data is subject to GDPR.
7.5.Right to Data Portability. If you are located in the EU, you may have the right to request that we provide you with a copy of the personal data you provided to us in a structured, commonly-used, and machine-readable format. See Article 20 of the GDPR for more details, if your personal data is subject to GDPR.
7.6.Right to Object. If you are located in the EU, you may have the right object to certain processing activities. See Article 21 of the GDPR for more details, if your personal data is subject to GDPR.
7.7.Withdrawal of Consent. If we are processing your data based on your consent, you are always free to withdraw your consent, however, this won't affect processing we have done from before you withdrew your consent.
7.8.Right to Lodge a Complaint with Your Local Data Protection Authority. If you are located in the EU, you have the right to submit a complaint to the relevant data protection authority if you have any concerns about how we are processing your personal data, though we ask that as a courtesy you please attempt to resolve any issues with us first.
7.9.Your Rights Under Israeli law. If you are subject to Israeli law, you may request to access any personal data you have provided to us and request that such personal data be corrected, updated, or deleted, including in accordance with Articles 13 through 14 of the Israeli Privacy Protection Law, 1981. You may exercise such rights by emailing us at [email protected]. You may have the right to delete your personal data subject to and in accordance with Article 3 of the Israeli Privacy Protection Regulations (Provisions Regarding Information Transferred to Israel from the European Economic Area), 2023.
7.10.Your Rights Under the CCPA. If you are a resident of the State of California, depending on the applicability of certain laws and exemptions, you may have certain rights over your data, as detailed in Annex A to this Privacy Notice. Please note that the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), may not apply to us based on our current business operations and the applicable statutory thresholds. Nevertheless, as a matter of good faith and our commitment to transparency, we voluntarily provide California residents with the rights and disclosures described in Annex A below. Nothing in this section or in Annex A shall be construed as an admission that the CCPA applies to us.
8.Data Retention.
8.1.We retain your personal data as long as necessary to fulfill each of the purposes we described above. Once we're done with your data, we delete it.
8.2.When deciding how long to store personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized access, the purposes for which the personal data was collected, as well as applicable legal requirements. Please note that we may delete information from our systems without notifying you first. Retention by any of our service providers or subcontractors may vary in accordance with each business's retention policy.
8.3.With respect to geo-location data, as mentioned in Section 2.3 above, we delete such geo-location data following its transfer, per session, to the applicable advertisers, and do not retain such data thereafter.
8.4.With respect to end user data of visitors to publishers' digital assets, we do not retain such data after real-time processing. IP addresses and device IDs are deleted after extraction of traits from such data - we maintain aggregated and anonymized analytics for 24 months. Notwithstanding, we maintain a list of fraudulent addresses and identifiers for fraud prevention purposes, which is updated from time to time, based on third party providers' data.
9.Cookies and Similar Technologies.
9.1.What are Cookies? A cookie is a small piece of text that is sent to your browser by a website you visit. This piece of text acts as a sort of tag, letting the website know that it's you (really, your device) that's visiting. There are other technologies that act similarly, like web beacons, pixel tags, and Device IDs for apps, but for simplicity's sake we'll refer to them all as "cookies".
9.2.Websites can place their own cookies (called "first-party cookies") but can also place cookies from other sites (called "third-party cookies"). If your browser holds both first and third-party cookies for a given website, both the website and the third party are notified when you visit the site. We may place both first and third-party cookies on our site.
9.3.How We Use Cookies on our Site. While the specific names and types of cookies we use on our site may change from time to time, they generally fall into one of the categories listed below.
Cookie Type | Function |
|---|---|
Necessary | These cookies allow our site to work correctly. They enable your access our site, move around, and access different services, features, and tools. These cookies cannot be disabled. These cookies also help us identify and prevent security risks. They may be used to store your session information to prevent others from changing your password without your login information. |
Functionality | These cookies remember your settings, preferences, and other choices you make in order to help personalize and streamline your experience. |
Performance/Analytics | These cookies collect analytical information to help us understand how you use our site and/or our marketing communications, for example whether you have viewed messages, clicked on links, and how long you spent on each page. This helps us improve our site and/or our marketing communications or efforts, to better suit your needs. |
Third Party Cookies. In addition to our first-party cookies, we place cookies from the following third parties:
•Google LLC – Google Analytics (Performance/Analytics). For further information, please see Section 1.1.2.
•Mailchimp (Intuit Inc.) (Performance/Analytics). We use Mailchimp to send marketing emails and newsletters. Mailchimp places cookies and similar tracking technologies (such as pixel tags) in our emails to measure open rates, click-through rates, and other engagement metrics. For more information, see Section 3.2 and Mailchimp’s privacy policy at mailchimp.com/legal/privacy/.
9.4.How We Use Cookies in Our Services. In the course of providing services to our customers, we place advertising cookies on publisher assets. These cookies help advertisers show you ads. When we place advertising cookies, they help us track the efficiency of advertising campaigns. Advertising cookies may track your browsing habits and activity when visiting the publisher's assets and those of third parties and help us serve ads that are relevant and meaningful to you and your interests.
9.5.How to Adjust Your Preferences. Most web browsers are initially configured to accept cookies, but you can change the settings so your browser refuses all cookies or certain types of cookies. In addition, you are free to delete any existing cookies at any time. Please note that some features of the services may not function properly when cookies are disabled or removed. For example, if you delete cookies that store your account information or preferences, you will be required to input these each time you visit.
9.6.By changing your device settings, you can prevent your device's ad identifier being used for interest-based advertising, or you can reset your device's ad identifier. This means that you won't be shown ads that relate to your browsing activities. Typically, you can find the ad identifier settings under "privacy" or "ads" in your device's settings, although settings may vary from device to device. Adjusting your preferences does not mean you will no longer receive ads, it only means the ads that you do see can be less relevant to your interests.
10.Third-Party Services. You may have access to third-party services through our services. Please note that all use of third-party services is at your own risk and subject to such third party's terms and privacy policies. We do not take any responsibility for the performance of other services.
11.Children. We do not knowingly collect personal data from children for whom parental consent would be needed for such collection. In the event that you become aware that an individual for whom parental consent is needed has visited our site and/or used the services, please advise us immediately. The relevant age varies per jurisdiction and is usually between 13-16 years.
12.Changes to the Privacy Notice. We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business. We will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version.
CONTACT US
If you have any questions or comments about this Policy, please write to us at:
Boldwin Ltd.
Shvil Hamerez 4, Tel Aviv, 6653520, IL
You can also contact us via email at: [email protected]
Annex A
Your Rights Under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA)
Applicability of the CCPA. Please note that the CCPA may not apply to us based on our current business operations and the applicable statutory thresholds. Nevertheless, as a matter of good faith and our commitment to transparency, we voluntarily provide California residents with the rights and disclosures set forth below. Nothing in this Annex shall be construed as an admission that the CCPA applies to us.
If you are a resident of the State of California, depending on the applicability of certain laws and exemptions, you may have certain rights over your data. Below is some general information about rights that may apply to you. We recommend that you check the law or consult with a lawyer to understand what applies in your specific case. We may ask for reasonable evidence to verify your identity or to verify that you have been authorized to act on behalf of the relevant individual. For the purposes of this section, "personal data" shall have the meaning of "Personal Information" as defined under the CCPA.
1.Right to Know. You have the right to request that we disclose to you any or all of the following in respect of the 12-month period preceding your request:
-The specific personal data we have collected about you.
-The categories of personal data we have collected about you.
-The categories of sources from which we collected the personal data about you.
-The categories of third parties to whom we disclose personal data about you.
-The categories of personal data about you we have sold and the categories of third parties to whom we have sold such personal data.
-The categories of personal data about you we have disclosed for a business purpose and the categories of third parties to whom we have disclosed such personal data.
-Our business or commercial purpose(s) for collecting or selling your personal data.
2.Right to Delete. Subject to certain exceptions, you have the right to request that we or any of our service providers delete your personal data.
3.Right to Correct. You have the right to request that we correct any inaccurate personal data that we maintain about you, considering the nature of the personal data and the purposes of the processing of the personal data.
4.Right to Opt-Out of the Sale or Sharing of Personal Data. If you are 16 years of age or older or have consented to the sale of your personal data, you have the right to direct that we do not sell or share your personal data at any time. You may change your mind and opt back into the sale of your personal data at any time by contacting us. We may deny any request to opt-out of the sale of personal data that we deem in our good-faith, reasonable and documented belief is fraudulent.
5.Right to Limit Use and Disclosure of Sensitive Personal Data. To the extent we collect any sensitive personal data about you, you have the right to instruct us to limit our use of such personal data only for the purpose of providing you with our services and certain business operation purposes.
6.Right to Non-Discrimination for Exercising your Consumer Privacy Rights. You have the right not to be discriminated against for exercising any of your consumer privacy rights, such as, not being denied any goods or services or charged different prices or rates.
7.How to Exercise your California Privacy Rights
-Contact Information. To exercise any of the rights detailed above, please submit a verifiable request to us by contacting us at [email protected]. You may only request to exercise your right of access twice within a 12-month period.
-Submitting a Verifiable Request. In order to exercise your right to know or right to delete you must submit a request containing sufficient information that allows us to reasonably verify you are the person about whom we collected the applicable Personal Data or an authorized agent of such person, which may include details relating to your account. Any requests made through your password protected account will be verified through our existing authentication procedures for such an account.
-Submitting Requests through an Authorized Agent. An authorized agent may exercise requests on your behalf. In order to exercise your right to know or right to delete through an agent, we may ask for reasonable evidence to verify your identity and the agent’s identity, and written authorization permitting the agent to act on your behalf before complying with your request. In order to submit a request to opt-out of the sale of your personal data through an agent, we may ask for written authorization permitting the authorized agent to act on your behalf before complying with your request. We reserve the right to deny the request of any agent that does not provide proof that they have been authorized to act on behalf of the applicable consumer in accordance with applicable law.
8.The Past 12 Months. In the past 12 months we have not "sold" nor "shared" (as such terms are defined in the CCPA) any personal data about you. In the past 12 months, we have disclosed the following categories of personal data for a "business purpose" (as defined in the CCPA), all as specifically detailed in Section 2 of the Privacy Notice:
a.Category A: Identifiers such as a real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
b.Category D: Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
c.Category F: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.
d.Category G: Geolocation data.
e.Category K: Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Annex B
Our Data Partners
The following is a list of our main data partners with whom we share personal data as part of our advertising and marketing services. Each partner acts as an independent controller of the data they receive. We encourage you to review each partner’s privacy notice to understand how they process your personal data and how you can exercise your rights with them.
Partner's Name | Purpose of sharing | Data Shared | Privacy Notice Policy |
|---|---|---|---|
TripleLift Xandr Magnite Media.net Ads Interactive | Facilitating programmatic advertising and real-time bidding for ad placements | IP Address, Device ID, User Agent | TripleLift Platform Privacy Notice; Microsoft Advertising Legal, Privacy, and Personalization Policy (For Xandr) ; Magnite Advertising Platform Privacy Policy; Media.net Privacy Policy; Google Privacy Policy |
ID5 IntentIQ LiveRamp | Identity resolution services for cross-platform user identification in digital advertising | IP address, user agent, device identifiers (IFA/IFV) |
