Equativ (“Dynadmic”) CCPA Product Privacy Policy
Equativ (“Dynadmic”) provides advertising services (our “Services”) to a variety of companies.
Our services are primarily focused on helping advertisers to serve relevant ads to the right audience at the right time. DynAdmic is offering a new targeting concept based on a video content recognition technology that helps identify viewers’ interests to serve the right ad to the right person. (Demo of concept: https://www.dynadmic.com/howitworks.) We use our never-before-seen contextual targeting solution to sell tailored and highly focused branding campaigns to the world’s largest brands and agencies. Our clients include Emirates, Red Bull, Kellogg’s, Audi, etc.
The purpose of this Product Privacy Policy is to inform you, in accordance with The California Consumer Privacy Act of 2018 on the protection of Californian consumers with regard to the processing of Personal Information (hereinafter referred to as the “CCPA”), of our practices concerning the collection, use, sharing, selling and protection of Personal Information that you may provide to us through our Services and the rights you have over your Personal Information.
Categories of Personal Information we receive and collect
We collect your Personal Information when you and others are using browsers and devices while visiting or using websites, apps, and advertisements that use our Services. We collect some of this Personal Information using cookies, web beacons, and similar technologies. Categories of Personal Information we receive depends on how you access and use our Services.
Categories of Personal information we may have collected directly from you withtin the last twelve (12) months may include:
Identifiers:
– Your IP address
Internet activity or other electronic network activity information:
– Your interaction with the websites, apps and others services you use ; the content you view; and your clicks or engagements on ads
– How you access those websites, apps and other services
– Your browser or operating system
– The website you visited before visiting our Services
– The type of device you are using (i.e. i Phone, tablet, Dell desktop) and its language
– The Identifier for Advertisers (IFA or IDFA) of your mobile/tablet device
– Your DynAdmic user ID, an identifier randomly generated by DynAdmic stored as a cookie on your browser
– Header information such as URLs and date/time stamps
Geolocation data
– Your location based on your IP address
– Your location based on the GPS coordinates of your mobile/tablet device
We do not collect personally identifiable information, such as your name or email address.
We use all of the Personal Information we gather to improve and provide our advertising, measurement, and reporting Services.
Categories of Personal Information we may have collected indrectly from you within the last twelve (12) months may include Personal Information from third parties, such as our customers and partners, which includes advertisers, marketing partners, and service providers related to their use and support of our Services:
– Commercial information such as purchase information or interests
– Inferences drawn from Personal Information such as demographics
This Personal Information helps us determine which ads are shown on your browser or device and helps us measure the effectiveness of the ads. The collection and use of that Personal Information is governed by the privacy policy and legal terms of the Personal Information collector and the website using the Personal Information; it is not governed by DynAdmic.
Use of the Personal Information we have
We use the Personal Information we have to find and match appropriate audiences with appropriate advertisements and to serve customized ads to your browser or device. To do this, we may use Personal Information we have about your activities over time and across different websites, apps, browsers, and devices. We may also decide to show an ad based on the website or app you are using, the video content you are watching, things you may be interested in, or requests from our advertising partners, who decide to show ads to a particular audience, sometimes using Personal Information they have on file. We also use the Personal Information we have to optimize ad delivery, such as managing the frequency and the order in which the ads are shown.
To be more efficient, we can use the Personal Information we collected to associate the browsers and devices you use so we can provide better and more consistent experiences across browsers and devices, as well as improve our Services. We also use the Personal Information we have for the following purposes:
– Limiting the number of times you see the same ad
– Measure the effectiveness of the ads we serve
– Provide more effective measurements and reporting Services.
How is this Personal Information shared?
We work with advertisers, partners, service providers and other partners in order to provide and improve our Services. We share Personal Information with these organizations as a part of these efforts.
Here are the types of organizations we can share Personal Information with about you:
– Customers or partners
We may share with advertisers and their partners the Personal Information we collect on their websites and apps or in connection with their advertisements. We share aggregated or other non-personally identifying information with customers and partners that help them place or understand the ad performance. For example, we share non-personally identifiable information with these entities that tells them how many people saw their ad, how many people visited their website or app, the demographics of the audience, and whether the ad served achieved a desired result such as whether those who saw a company’s ad clicked on the ad or purchased the advertised product. We also share aggregated Personal Information that is not connected with a particular ad campaign, such as the number of people we have assigned to general interest categories or segments.
– Service providers, vendors and other partners for business purpose
We share Personal Information that we collect with vendors, service providers, and others who work under our direction in order to help us support, provide, protect our Services and websites globally.
– Protecting you, ourselves, and others
We may use Personal Information to detect, prevent, investigate, and address fraud and other unauthorized or illegal activity; to protect ourselves, you, and others, including as part of investigations; or otherwise to prevent harm.
– Providing and improving Services
We use the Personal Information we have to support our services through activities such as infrastructure monitoring and internal maintenance, analyzation of how our services are used, research and development, and billing.
– Change in control
If there is change in assets or ownership or control of all or part of our Services, we may transfer the Personal Information we have to the new owner.
The Personal Information shared is always with a unique identifier, not personally identifiable information, such as your name or email address.
Sales of Personal Information
As defined by CCPA, sales of Personal Information means selling, renting, releasing, disclosing, dissiminating, making available, transferring, or otherwise communicating orally or in writing, or by electronic or other means, a consumer’s Personal Information by the business to another business or a third party for monetary or other valuable consideration.
In the last twelve (12) months, we have not sold the Personal Information described in the section Categories of Personal Information we receive and collect.
How do we store Personal Information?
Personal Information that we receive may be transferred to, stored, or processed in the United States, Canada, European Union, or any other country globally for the purposes described in this policy. We typically retain Personal Information that we collect through our Services for 12 months, after which we delete and aggregate the Personal Information.
We rely on hosting providers, such as Amazon AWS and OVH, in the European Economic Area (“EEA”), Canada and the United States.
These providers ensure a level of Personal Information protection in accordance with current EEA regulations such as the GDPR, the Privacy Shield, and more.
For more information, you can consult the following links:
https://aws.amazon.com/privacy/ https://www.ovh.com/fr/protection-donnees-personnelles/
Protection of your Personal Information
We take appropriate technical and organizational measures to prevent unauthorized access or modification, disclosure, loss or destruction of Personal Information we receive and collect.
Your rights on your Personal Information
– Right of access and portability:
You have the right to request that we disclose certain Personal Information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data portability request).
– Right to deletion:
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the Personal Information is necessary for us or our service provider(s) to:
• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the Personal Information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that Personal Information that are compatible with the context in which you provided it.
– Right to opt-out of the sale of your Personal Personal Information:
You have the right to opt-out of the sale of your Personal Information. If you do not explicitly opt-out and you are not a minor, your Personal Information may be sold as disclosed in this Product Privacy Policy.
– California’s “Shine the Light” law (Civil Code Section § 1798.83) :
This law permits users of our Sites that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please use the form available below in the CONTACT section.
Exercising your rights
To exercise your access, portability, deletion, « Shine the light law » and opt-out rights described above, please submit a verifiable consumer request to us by using the form available below in the CONTACT section. To opt-out of the sale of your Personal Information you can also follow the instructions in the section « How to opt-out of the targeted ads delivered to you by DynAdmic ».
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
How to opt out of the sale of your Personal Information (using this method you will opt-out of targeted ads delivered to you by DynAdmic)
From a browser (desktop, mobile, tablet):
If you wish not to be exposed to our specific targeted ads displayed from a browser (Internet Explorer, Microsoft Edge, Google Chrome, Firefox, Safari ….) you can opt-out by reaching out to privacy@equativ.com.
Please note that you can also configure your browser to disable the cookies. As this operation depends on the browser, we advise you to consult the Help section of your browser.
From mobile application(s):
You can reset your Mobile Advertising ID and remove some unwanted ads by following the processes:
– for Apple devices visit https://support.apple.com/en-us/HT202074
– for Android devices, visit https://support.google.com/ads/answer/2662922?hl=en
Please note:
– You will still receive advertisements; however, they will no longer be provided by us, nor will they be targeted by our system.
– You will need to repeat this procedure if you delete your cookies, change your computer, or change your Internet connection.
Non discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services or charge you different prices for exercising your rights.
Transparency & Consent Framework
DynAdmic is participating to the Interactive Advertising Bureau (IAB) CCPA Compliance Framework for Publishers & Technology Companies (the “Framework”). This framework has been developped by the IAB in order to facilitate communication between publishers and technology companies engaged in digital advertising with regards to California’s consumers rights. The framework defines how publishers must communicate to consumers important information about their rights at the point of data collection, how publishers can communicate to technology companies that a consumer has opted out of the sale of his/her Personal Information, and how technology companies must operate after a consumer has opted out of the sale of his/her Personal Information.
In addition, DynAdmic has signed the accompanying Limited Service Provider Agreement which imposes strict limitations on data use by publishers and technology companies to only those specific and limited business purposes that are permitted under the CCPA. As such, DynAdmic is part of the Signatory Identification List.
DynAdmic is also referenced on the list of vendors adhering to the IAB Transparency & Consent Framework (https://vendorlist.consensu.org/vendorlist.json). The IAB Transparency & Consent Framework has a simple objective to help all parties in the digital advertising chain ensure that they comply with the EU’s General Data Protection Regulation and ePrivacy Directive when processing personal data or accessing and/or storing information on a user’s device. This includes cookies, advertising identifiers, device identifiers, and other tracking technologies.
The information published by DynAdmic is as follows:
– Purposes for which consent is required:
o Information storage and access: The storage of information, or access to information that is already stored, on your device such as advertising identifiers, device identifiers, cookies, and similar technologies.
o Ad selection, delivery, and reporting: The collection of information—and the combination with previously collected information—to select and deliver advertisements for you and to measure the delivery and effectiveness of such advertisements. This includes using previously collected information about your interests to select ads, processing data about what advertisements were shown, how often they were shown, when and where they were shown, and whether you took any action related to the advertisement (i.e. clicking an ad or making a purchase). This does not include personalization, which is the collection and processing of information about your use of this service to subsequently personalize advertising and/or content for you in other contexts, such as websites or apps, over time.
– Purposes for which the legitimate interest is invoked, no consent required:
o Personalization: The collection and processing of information about your use of this service to subsequently personalize advertising and/or content for you in other contexts, such as on other websites or apps, over time. Typically, the content of the site or app is used to make inferences about your interests, which inform future selection of advertising and/or content.
o Content selection, delivery, and reporting: The collection of information—and the combination with previously collected information—to select and deliver content for you and to measure the delivery and effectiveness of such content. This includes using previously collected information about your interests to select content, processing data about what content was shown, how often or how long it was shown, when and where it was shown, and whether the you took any action related to the content, including for example clicking on content. This does not include personalization, which is the collection and processing of information about your use of this service to subsequently personalize content and/or advertising for you in other contexts, such as websites or apps, over time.
– Use or collection of data to achieve several purposes/objects:
o Matching Data to Offline Sources: Combining data from offline sources that was initially collected in other contexts.
o Precise Geographic Location Data: Processing a user’s precise geographic location data in support of a purpose for which that certain third party has consent.
Data Controller and Data Protection Officer
The data controller is:
Equativ
66 rue de la Chaussée D’Antin
75009 Paris, France
How to contact us?
If you have questions or concerns about this Privacy Policy, your rights, or about our Services, please send us an email at privacy@equativ.com
