Trust

Privacy Guidelines

Last Updated: September 7, 2017

A. Privacy Overview

These guidelines apply to Amobee, Inc. and Turn Inc. (“Amobee”).

Amobee provides its advertisers and their agencies, its website and app publishers and other ad inventory providers and its data vendors (its “Business Partners”) with technologies that enable the serving and display of relevant advertisements to individuals who access a publisher’s website, mobile app, or other online content. Amobee’s technology also helps its partners collect and manage the data generated by such advertisements as well as data that its Business Partners may already have and data that they collect regarding visitors to their digital properties, including websites and mobile applications.

Amobee advertising technology collects and uses data to help make online advertising more relevant and for ad delivery and reporting purposes. By delivering more relevant advertisements, Amobee plays an important role in keeping the Internet free, dynamic and vibrant. That’s because advertisers will pay more when their ads are tailored to an audience’s interests and publishers of websites and apps get more money when their audiences receive tailored advertisements instead of generic ones. That helps publishers continue to provide great content at a great price—often free.

These privacy guidelines explain the various ways individuals may interact with Amobee and its advertising technology and the ways in which individuals may exercise control over the use of information collected by Amobee.

Opt Out of Tailored Advertising from Amobee

To opt out of receiving the tailored advertising made possible by Amobee advertising technology in your current browser or mobile applications on your current device, please visit Amobee’s Consumer Opt-Out page.

B. Amobee Advertising Technology

B(1). Technology Overview

Amobee advertising technology collects and uses data to help make online advertising more relevant and for ad delivery and reporting purposes. This plays an important role in keeping content on the Internet and within mobile apps largely free, dynamic and vibrant by improving the relevancy of advertisements displayed throughout the Internet.

Here’s how it works: Amobee advertising technology collects data about the websites and apps that a user interacts with and the advertisements that a browser or app displays. This information cannot be used by Amobee to identify a particular individual, so it is called non-personally identifiable information (“non-PII”). This information may include non-PII identifiers (such as mobile device advertising identifiers, IP address or your browser’s user agent string) specific to the user’s browser or device as well as non-PII demographic and interest information provided by third parties.

An individual’s non-PII may be collected by Amobee advertising technology when:

  • Amobee or a business partner purchases online advertisements on a website that the individual visits or an app that the individual uses.
  • An Amobee business partner places one of Amobee’s web pixels on a website that the individual visits or uses.
  • A user interacts with an app from which Amobee collects data.
  • In some countries (none of which are in North America or Europe), when the user’s Internet service provider has a special relationship with Amobee (such ISPs, the “Partner Carriers”).

Amobee advertising technology allows Business Partners to target users by submitting lists of pseudonymized data to Amobee. For example, Business Partners may submit lists of pseudonymized e-mail addresses or pseudonymized postal codes; in some places postal codes are considered personally identifiable information (“PII”). Amobee cannot use the lists to identify particular individuals because Amobee does not have access to the e-mail addresses or postal codes once they have been pseudonymized. Thus the lists constitute non-PII. “Pseudonymization” means replacing any identifying characteristics of data with a pseudonym, or, in other words, a value which does not allow the data subject to be directly identified.

Amobee advertising technology also offers data management services to Business Partners via its data management platform (“DMP”). The Amobee DMP enables its Business Partners to collect, store and analyze non-PII about their audiences. Amobee’s Business Partners may use its DMP and data collection tools to develop and name custom data segments. Amobee does not exercise control over the manner in which its Business Partners label their custom data segments in the DMP, but as applicable, Amobee contractually requires that its Business Partners using the DMP adhere to self-regulatory codes offered by the Network Advertising Initiative (“NAI”), Digital Advertising Alliance (“DAA”) and/or certain other industry standards. Amobee also contractually prohibits its Business Partners using the DMP from bringing PII into the DMP.

Amobee’s business intelligence product uses data from a variety of sources to provide agencies and advertisers with a broad understanding of consumer sentiment. The business intelligence product does not use such data to target advertisements to users.

B(2). What Information Is Collected and How It Is Collected

Amobee’s advertising technology collects and uses only non-PII, including: information about the device and its IP address; the browser or application used; which and how many, business partner web pages have been viewed by a browser or application; search terms entered on business partner websites; referring and exit pages; the date and time an advertisement was viewed; location data; browser or device-specific identifiers (such as mobile device advertising identifiers or your browser’s user agent string); and other similar information. In certain instances, Amobee may collect and match this non-PII across devices, browsers, or applications through deterministic methods or statistical correlation for the purposes of identifying devices, browsers, or applications belonging to the same user and providing more relevant advertising. Amobee also obtains non-PII from third party data vendors that receive such non-PII pursuant to their own privacy policies. Amobee does not collect PII via its advertising technology.

Amobee advertising technology generally collects non-PII using cookies and pixels as described below in Amobee Use of Cookies and Pixels.

Through the Partner Carriers, Amobee collects Internet usage information about users. For example, Amobee collects the domain and user-agent of websites visited by users and of resources loaded from those websites. The carriers also provide Amobee with basic demographic information about the users such as their gender and age. Amobee does not have access to the full URLs visited or to any PII about the users.

Amobee’s business intelligence product uses information from Business Partners, including Internet traffic data, public social media posts and Internet traffic from the Partner Carriers.

B(3). The Amobee ID and ID Syncing

Amobee associates the non-PII that it collects about a browser or device with a randomly generated pseudonymous identifier known as an Amobee ID, which itself is non-PII. Amobee uses ID Syncing (described below) to associate Amobee IDs with identifiers and data from Business Partners and other industry participants in an effort to display relevant advertisements on a wider range of websites, apps and content. As part of this process, Amobee may populate an Amobee cookie with a new or existing Amobee ID.

ID Syncing (also known as cookie syncing or cookie matching) is a common and useful industry practice that enables advertisers to use data to coordinate an advertising campaign across multiple publishing platforms and advertising service providers.

As an example, suppose an individual uses a web browser to visit a merchant’s website and then leaves the website. The merchant wants to advertise relevant products to that visitor after she leaves the website. To do so, the merchant stores a cookie on the visitor’s browser with an arbitrary ID (for example, merchant ID “123”) and associates the ID with information about what the visitor shopped for on the merchant’s website. If the merchant wanted to use that information to advertise on other websites, the merchant could buy advertising through an online advertising exchange or marketplace. In order to buy appropriate advertising, the merchant would need to match the ID “123” with the arbitrary ID that the exchange has assigned to the same visitor (for example, exchange ID “XYZ”). Using ID Syncing, the merchant can know that its ID 123 is associated with the same browser or device as the marketplace ID XYZ and the merchant may be able to show more relevant advertisements to the visitor.

ID Syncing is also used with Partner Carrier data to associate the Amobee ID with the proprietary IDs of other advertising exchanges, and to associate the Amobee ID with the proprietary IDs of our Partner Carriers. These proprietary IDs have been pseudonymized and are non-PII.

B(4). How the Collected Information Is Used

Amobee uses the non-PII it collects to identify the audience most likely to respond to a particular ad, to serve those ads and to analyze trends. This helps support the online advertising ecosystem, app and website developers and consumers by supporting content and delivering more effective advertisements. Amobee may also share this information with its affiliates and Business Partners.

Amobee advertising technology enables Amobee’s Business Partners to use advertising segments to deliver relevant advertising tailored to consumers’ interests. An advertising segment is defined by non-PII attributes, which often includes combinations of information such as geography, age range, gender, activities and/or interests.

Amobee customers may use non-sensitive health-related segments to help deliver tailored advertising. For example, Amobee customers may deliver tailored advertising regarding healthy living because a browser previously visited websites that are focused on health-related topics such as yoga and healthy eating. Review a list of health-related segments that are made available to Amobee’s Business Partners by third-party data providers.

Amobee uses business intelligence data to give market insights to agencies and advertisers.

B(5). Cross-App and Cross-Device Advertising, Ad Delivery and Reporting

Amobee may collect and use the information and the data segments described above for cross-app advertising, i.e., advertising across browsers and apps on a single device, as well as cross-device advertising, i.e., advertising across multiple devices. Amobee also collects and uses cross-app and cross-device information for ad delivery and reporting purposes. As described elsewhere in these privacy guidelines, Amobee does not collect PII via its advertising technology, including across apps and devices.

Amobee uses certain techniques to enable its advertising technology to serve meaningful advertising content on behalf of its customers and Business Partners across apps and devices, including cookie and ID Syncing and similar practices.

B(6). Market Research Surveys

Amobee may serve ads that invite you to participate in market research surveys. These surveys allow you to share your opinions, if you wish to do so. The surveys collect the same types of non-PII Amobee collects when serving ads in addition to any survey responses. Amobee uses this information to better understand market research trends and help ascertain the effectiveness ads delivered by Amobee’s technology.

B(7). Data Retention

Amobee removes non-PII associated with an Amobee ID from its ad-decisioning database if more than 30 days have passed since it has seen any activity associated with the Amobee ID, or has delivered advertising to a computer or device associated with the Amobee ID. However, if the same non-PII is associated with both an active and inactive Amobee ID, the non-PII will only be deleted from the inactive Amobee ID and will not be deleted from the set of information associated with the active Amobee ID. Amobee may retain this and other data it collects in other formats for as long as necessary for reasonable and legitimate business purposes including fraud prevention, audit and legal compliance and billing disputes.

Non-PII associated with an Amobee ID may be stored in the Amobee DMP up to five years. This information may be used to create advertising segments but will only be used to deliver tailored advertising to active Amobee IDs.

B(8). Third-Party Links and Websites

Advertisements delivered using Amobee advertising technology may contain links to or redirect individuals to other websites, including those of its Business Partners. These websites may use cookies, pixels and/or other data collection tools. Amobee encourages everyone to read the posted privacy policies whenever interacting with any website to learn more about the privacy practices of that website. However, Amobee is not responsible for the privacy practices, policies, or the content of these websites and Amobee does not exercise control over the use of any information by third party websites. Similarly, while Amobee contractually requires its Business Partners to adhere to applicable law and industry self-regulatory codes such as those offered by the Network Advertising Initiative (“NAI”), Digital Advertising Alliance (“DAA”), European Interactive Digital Advertising Alliance (“eDAA”), the Australian Digital Advertising Alliance (“ADAA”) and Digital Advertising Alliance of Canada (“DAAC”), Amobee does not have access to, or control of, the cookies, web pixels and/or other data collection tools that may be placed on any advertisement by a third party. These privacy guidelines do not cover the use of cookies and/or other data collection tools by any third party.

C. Amobee’s Corporate Website and Information Collected Directly from Amobee’s Customers

C(1). What Information Is Collected and How It Is Collected

Amobee operates a corporate website at Amobee.com which is primarily intended to be used by Business Partners. This website also provides information, such as this privacy policy, relevant to consumers.

Amobee collects PII through its corporate website or when a prospective business partner directly contacts Amobee. PII is collected through Amobee’s corporate website only when an individual chooses to provide it to Amobee through a contact form for the purpose of receiving more information about Amobee’s products and services. Examples of PII which an individual may provide to Amobee are that individual’s first and last name, physical address, telephone number or e-mail address. Amobee also collects PII from Amobee Business Partners in the ordinary course of business, including, for example, e-mail addresses, telephone numbers and billing details. Amobee uses this information for its business purposes, such as to maintain customer and supplier accounts, billing, password management and to service other customer needs.

Amobee may also collect non-PII about visitors to its corporate website, including IP addresses, the pages viewed, the browser or other application used, location data, mobile device-specific identifiers, the visitor’s internet service provider, the time/date of the visit and the visitor’s device operating system. Amobee uses this non-PII for internal purposes such as to administer its website, improve and customize it, to help Amobee understand and analyze how it is being used and to evaluate aggregate website usage. Amobee may collect this non-PII using cookies and pixels as described below in Amobee Use of Cookies and Pixels.

C(2). Links on Amobee’s Corporate Website to Third Party Websites

Amobee’s corporate websites may include links that connect individuals to other websites, including those of its Business Partners. Those websites may use cookies, pixels and/or other data collection tools. Amobee encourages everyone to read the posted privacy policies whenever interacting with any website to learn more about the privacy practices of that website. However, Amobee is not responsible for the privacy practices, policies or the content of such websites and Amobee does not control the use of any information by third party websites. Amobee contractually requires that its Business Partners adhere to applicable law and industry self-regulatory codes such as those offered by the NAI, DAA, eDAA, ADAA and DAAC. Amobee is not responsible for the cookies, pixels and/or other data collection tools that may be placed on an advertisement by a third party. These privacy guidelines do not cover the use of cookies and/or other data collection tools by any third party.

C(3). Retention of Business Partner Data

Amobee stores business partner PII as long as relevant for record keeping, business and compliance purposes. The information that Amobee stores may be deleted as space requires or in the normal course of business. To opt-out of receiving more information about Amobee’s products and services, you may send an e-mail to marketing_unsubscribe@Amobee.com.

D. Amobee’s Use of Cookies and Web Pixels

Amobee uses cookies in connection with both its advertising technology and its corporate website.

  • Cookies used on Amobee’s corporate website: Amobee uses cookies to help administer its website. For example, Amobee may use cookies on its website to record browsing sessions or facilitate logins.
  • Cookies used in connection with Amobee advertising technology: Amobee also uses cookies to help it better understand the effectiveness of particular advertisements. For example, Amobee may use cookies to help evaluate how browsers or applications respond to advertisements or any content provided therein, or to help determine the site placement and context in which advertisements are displayed. Amobee’s cookies may also help control the number of times a browser or application is served an advertisement.

If Internet browser settings are used to “clear” or delete cookies, this may inadvertently delete cookies that have been set by websites to honor an “opt-out” status (including the Amobee opt-out cookie).

If you delete Amobee cookies from your browser, that action only deletes the cookies in your browser and does not send any information to Amobee. The next time Amobee is provided the opportunity to set cookies in your browser or app (usually when Amobee places an ad), it will do so. The Amobee ID associated with one or more of the Amobee cookies may or may not be different than the Amobee ID associated with previously deleted Amobee cookies.

If you delete Amobee cookies from your browser, that action also has no impact on the non-PII previously collected and stored by Amobee. Amobee will retain the information as described in the Data Retention for Amobee Advertising Technology section. If Amobee is able to associate one Amobee ID with other Amobee IDs (for example, through the receipt and use of a separate identifier, such as a mobile device advertising identifier, browser’s IP address and user agent string and/or ID syncing), Amobee may transfer the non-PII associated with one Amobee ID to the other Amobee IDs.

Amobee also uses web pixels, in combination with cookies, to analyze usage patterns on its website and through Amobee advertising technology. The use of a pixel allows Amobee to record that a particular device, browser, or application has visited a particular webpage, along with additional non-PII that the website may choose to include with the pixel.

E. E-mail Marketing

E(1). Overview

As part of Amobee’s multichannel service to advertisers, Amobee offers the ability to reach consumers through targeted e-mail advertisements. Amobee’s e-mail channel is not considered part of Amobee’s “advertising technology” as that term is used elsewhere in this policy.

E(2). Information Collected

Amobee may collect PII and non-PII about consumers from third parties. This information may include name, postal address, e-mail address, IP address, categorical attributes and demographic information.

E(3). How Amobee Uses E-mail Information

Amobee uses e-mail information to deliver advertisements to consumers, either directly or indirectly through third-party publishing partners. These publishing partners are contractually obligated to comply with Amobee’s data use and opt-out policy as well as applicable law.

Amobee’s e-mail channel does not combine PII with the Amobee ID. More broadly, Amobee does not merge PII with non-PII for the purpose of interest-based advertising (as the term is defined by the Network Advertising Initiative).

Amobee processes PII related to its e-mail business on servers in the United States.

E(4). Opting Out

Consumers can opt out of Amobee’s e-mail advertising by sending a message to unsubscribe-me@amobee.com.

F. Security, Integrity, Disclosure

F(1). Data Security

Amobee has implemented reasonable security measures to protect the information in its care, both during transmission and once Amobee receives it. This includes, but is not limited to, the use of encryption. No method of transmission over the Internet, or method of electronic storage, is entirely secure, however. Therefore, while Amobee strives to use commercially reasonable means to protect information, Amobee cannot guarantee its absolute security.

F(2). Data Integrity

Amobee processes information in a way that is compatible with and relevant to, the purpose for which it was collected. To the extent necessary for those purposes, Amobee takes reasonable steps to ensure that any information in its care is accurate, complete, current and reliable for its intended use.

F(3). Disclosure of Information to Third Parties, Onward Transfer

Amobee may share information, including any PII collected via its website, with third parties who provide cloud computing services for Amobee. These third parties are prohibited from using the information Amobee provides for purposes other than performing services for Amobee or as contractually agreed. Amobee may also share non-PII, including data collected across applications or devices, with Business Partners. Similarly, Amobee may enhance the non-PII collected via its advertising technology with non-PII collected from Business Partners.

If Amobee uses your PII for a purpose that is materially different from the purposes for which it was originally collected or subsequently authorized, or if Amobee discloses it to a third party acting as a controller not previously disclosed to you, Amobee will offer you the opportunity to opt out of such uses and/or disclosures where it involves non-sensitive information or opt in where sensitive information is involved. Amobee remains responsible under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Amobee proves that it is not responsible for the event giving rise to the damage.

Amobee may be required to disclose information, including any PII collected via its website, to third parties when Amobee reasonably believes it is obligated to do so by law (including to meet national security or law enforcement requirements) and to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to, fraud and situations involving potential threats to the physical safety of any person.

Finally, Amobee may transfer information, including any PII collected via its website, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.

F(4). Accessing, Updating, or Deleting PII

Subject to applicable law, Amobee may recognize an individual’s right to access their PII and allow individuals to request a summary of the PII they have provided to request an update to or deletion of inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where the rights of persons other than the individual would be violated. To update or delete any inaccurate PII provided to Amobee, send a request to amobeeprivacy@Amobee.com. Amobee will process the request within a reasonable period of time after receipt.

F(5). Information Relating to Children

Amobee’s corporate website, advertising technology, business intelligence product and e-mail channel are designed for individuals who are 13 years of age and older. Amobee does not knowingly collect PII from anyone under the age of 13 on its website or via its advertising technology. If Amobee were made aware that it had received PII from someone under 13, Amobee would use reasonable efforts to remove that information from its records.

F(6). Questions and Complaints

Amobee uses reasonable processes to ensure compliance with these privacy guidelines and periodically verifies that they are accurate. Amobee encourages individuals with concerns about its practices to contact Amobee at amobeeprivacy@Amobee.com. Amobee will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information.

F(7). Recourse and Enforcement

Privacy Shield – Amobee complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union member countries and Switzerland. Amobee has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access and Recourse, Enforcement and Liability. Amobee is subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to its adherence to Privacy Shield. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program and to view Amobee’s certification page, please visit https://www.privacyshield.gov.

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield programs, Amobee commits to resolve complaints about your privacy and its collection or use of your personal information. European Union and Swiss data subjects with inquiries or complaints regarding this privacy policy should first contact Amobee via: amobeeprivacy@Amobee.com.

Amobee has further committed to refer unresolved privacy complaints under the EU-U.S. and the Swiss-U.S. Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

F(8). Changes to These Privacy Guidelines

Visit this page periodically to stay aware of any changes to these privacy guidelines, which Amobee may update from time to time. If Amobee modifies these guidelines, Amobee will make the revised privacy guidelines available at the URL of this page and indicate the date of the latest revision.

G. Partnerships and Associations

G(1). Networking Advertising Initiative

The NAI is a coalition of online advertising companies committed to complying with self-regulatory standards that establish responsible business and data management practices. Amobee is a participating member of NAI and is compliant with NAI self-regulatory principles. The NAI offers a tool to express a preference to opt-out of the receipt of tailored advertising and allows you to see whether non-HTTP cookie technologies are enabled for your current browser available here.

G(2). Digital Advertising Alliance

The DAA is a coalition of digital advertising companies that have created a self-regulatory code for online behavioral advertising. Amobee complies with the DAA self-regulatory code. The DAA also offers a tool to express a preference to opt out of the receipt of tailored advertising, available here.

G(3). European Interactive Digital Advertising Alliance

The eDAA has been founded by a European industry coalition representing advertisers, the advertising agency sector, the direct marketing sector, the advertising network sector and the media sector. eDAA’s principal purpose is to license the ‘OBA Icon’ to companies involved in tailored advertising across Europe. The OBA Icon is a consumer-facing, interactive symbol that links consumers to an online portal, www.youronlinechoices.eu, where they can find easy-to-understand information on the practice of tailored advertising as well as a mechanism for exercising informed choice – if they wish to do so, consumers may opt out of tailored advertising by some or all member companies.

G(4). Australian Digital Advertising Alliance

The ADAA is designed to give consumers a better understanding of, as well as greater control over, the ads that are displayed to them based on their online behavior. The ADAA offers a tool to express a preference to opt out of the receipt of tailored advertising, available here.

G(5). Digital Advertising Alliance of Canada

The DAAC is designed to give consumers a better understanding of, as well as greater control over, the ads that are displayed to them based on their online behavior. The DAAC offers a tool to express a preference to opt out of the receipt of tailored advertising, available here.

G(6). Interactive Advertising Bureau

The Interactive Advertising Bureau (“IAB”) is comprised of more than 500 leading media and technology companies. On behalf of its members, the IAB is dedicated to the growth of the interactive advertising marketplace, of interactive advertising’s share of total marketing spend and of its members’ share of total marketing spend. Learn more at www.iab.net.

G(7). Interactive Advertising Bureau Europe

IAB Europe is the voice of digital business. Its mission is to protect, prove, promote and professionalize Europe's online advertising, media, research and analytics industries. Together with its members – companies and national trade associations – IAB Europe represents over 5,500 organizations. Learn more at www.iabeurope.eu.

G(8) Interactive Advertising Bureau UK

The IAB UK trade association for digital advertising, representing most of the UK’s leading brands, media owners and agencies. Learn more at www.iabuk.net.