Last updated: August 30, 2018
The purpose of this Privacy Notice is to explain what information we gather, how we use it, what we do to protect it, and your choices regarding how we gather and use information about you.
If you have questions or concerns regarding our Privacy Notice or practices, please see the “Contact Us” section below. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
About Our Advertising Services
RadiumOne provides online display, mobile, video, and social advertising services. In order to provide our services, we buy advertising space from hundreds of websites and mobile applications around the world and resell it in targeted packages to advertisers and agencies (“Targeted Advertising”). Targeted Advertising is displayed (a) on the browsers of devices such as computers, laptops, tablets or smartphones or (b) inside mobile applications. Users benefit from Targeted Advertising by receiving advertisements (“ads”) which are more interesting and relevant than untargeted ads, while advertisers benefit through the more efficient delivery of ads to interested Users.
Targeted Advertising is based on data that does not directly identify you and is collected from your devices as described below in “What Information We Collect”. Data used in Targeted Advertising may range from your (i) interests, (ii) similarities to other Users, (iii) general demographic information, and (iv) general geographic location. This non directly identifiable information is also known as pseudonymous data and may be used to classify Users who are most likely to respond to an ad. We do not intentionally collect information that identifies you (such as your name, address, phone number, or email address), and we prohibit our partners from sharing this information with us.
What Information We Collect
The information we collect falls into two categories – Browser-Based Data and Mobile App-Based Data.
For information about opting out from the collection of Browser-Based Data and Mobile App-Based Data, please visit our Opt Out page by clicking here.
- Ad Serving and Web Navigation Information. We may collect browser-based information regarding how you use the Platform and how you interact with the ads that the Platform displays (together, “Ad Serving and Web Navigation Information”). This Ad Serving and Web Navigation Information may include the following: (i) technographic data related to the browser, operating system, and device, such as the name and version of your browser, (ii) connection data (such as the device’s current IP address), (iii) the current website visited, (iv) the website visited before the current website, (v) search terms, (vi) the date and time of the website visit. (vii) whether the User has clicked on the ad of a RadiumOne advertiser, visited this advertiser’s website, or undertaken a transaction with this advertiser.
- Po.st Information. Developers of Web sites may choose to implement our Po.st technology, which facilitates the sharing of Web content. When you use the Po.st services, we may receive Ad Serving and Web Navigation Information, including the URL content shared by a user (together, the “Po.st Information”). We can also discern which channel was used for sharing or receiving content (e.g. a social network or email). In addition, if you use Po.st to send an URL link to another user, and the user clicks on the sent URL link, we may also receive Ad Serving and Web Navigation information related to this user.
- RadiumOne Engage Information. Developers of Web sites may choose to implement our RadiumOne Engage technology, which facilitates in-game advertising. When you use RadiumOne Engage advertising services, we may receive Ad Serving and Web Navigation Information, including (i) information about the game in which the advertising offer was placed, (ii) whether the User has clicked on the advertising offer, and (iii) whether the advertising offer was completed by the User (together, the “RadiumOne Engage Information”).
Mobile Application-Based Data
- Device IDs. If you are using the Platform via a mobile application, we may use the Apple IFA, Android Advertiser ID, or other device information that uniquely identifies a mobile device (collectively, “Device IDs”) in order to match certain information that we collect via the mobile application.
- Ad Serving Information. We may collect mobile-application-based information about how you interact with the ads that the Platform displays (together, “Ad Serving Information”). This Ad Serving Information may include the following: whether the User has (i) clicked on the ad of a RadiumOne advertiser, (ii) installed this advertiser’s application, or (iii) undertaken a transaction with this advertiser inside the downloaded application.
- API or SDK Information. Developers of mobile applications may choose to implement our application programming interfaces (“APIs”) and software development kits (“SDKs”), such as RadiumOne Connect, which delivers push messages to consumers and provides developers with mobile analytics, geo-fencing capabilities, and advertising campaign attribution; and RadiumOne Engage, which delivers advertisements within mobile gaming applications (together, the “RadiumOne Software”). When a User accesses an application that implements the RadiumOne Software, we may collect certain User data, including: (i) technographic data related to the device (such as Apple IFA or Android Advertiser ID, device model, and operating system), (ii) information related to the application that implements the API or SDK (such as the version of the third party application, the SDK or the API being used), (iii) certain information relating to the applications installed on a mobile device (such as a list of the applications installed on the device), (iv) connection data (such as the IP address and mobile country or network code used to access the API or SDK), and (v) various data relating to the User (such as latitude and longitude, language preferences, or self-reported demographic data, including age, income, education or ethnicity).
- iBeacons. We may collect information about your location through the use of iBeacon technology, an indoor positioning system that can notify nearby smartphones or other devices of their presence.
Other Sources of Information
- We may acquire, use or re-sell to our self-service clients information from third party sources that may be used as is or in combination with Browser-Based Data and Mobile App-Based Data to optimize the delivery of digital advertising to Users. We require these third party sources to comply with applicable legal and industry standards.
- We collect personal information from Web site visitors who sign up for our newsletter or submit their contact information. We do not use this information to deliver Targeted Advertising. Please see the section below entitled “RadiumOne Site Privacy Practices” for more details.
- In providing our advertising services, RadiumOne collects information for and on behalf of its Clients and, to the extent that it processes personal information, RadiumOne has no direct relationship with the individuals whose personal information it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients. If you wish to access, correct, amend, port or delete inaccurate personal information you should direct your query to RadiumOne’s Client (the data controller). If you address such requests to us, we will respond within a reasonable timeframe.
How We Use and Disclose Information
How We Use and Disclose Information In General. RadiumOne uses the information collected by the Technology to tailor advertising to you more effectively. The aim is to show you ads in which you are more likely to be interested. We do this by comparing the information in a pseudonymized User profile against our selection of ad campaigns and choosing the most relevant ad for you. Data used in your User profile may range from your (i) interests, (ii) similarities to other Users, (iii) general demographic information, and (iv) general geographic location. This data is collected from your devices as described above in “What Information We Collect.”
- Cross-App Advertising, Ad Delivery and Reporting. When you use a mobile device, we may use the information collected by the Technology regarding your use of the apps on your device to deliver Targeted Advertising based on the interests that we infer from your use of the mobile apps on the device (“Cross-App Advertising”). We may also use the information collected about the device for the purpose of delivering ads or providing related services such as delivering ads on the basis of a particular time of the day, optimizing the placement, performance, reach and frequency of our ads, and for statistical reporting and analytics purposes (“Ad Delivery and Reporting”).
- Please note that we do not sell or transfer ownership of Browser-Based Data and Mobile App-Based Data to third parties.
Legal basis for processing personal information (EEA Users only)
If you are a User from the European Economic Area, our or our customer’s legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Technology and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our Technology, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact Us” heading below.
Disclosure of Information to Third Parties
We may share information, including personal information collected via our Site, with trusted third parties that provide services for RadiumOne such as hosting and Internet connectivity. We may also share pseudonymous information with business partners in order to enhance our products and services. These third parties are prohibited from using the information we provide for purposes other than performing the services we prescribe. If you do not want us to share your information with these third parties, please contact us at firstname.lastname@example.org.
Browser-Based Data Collection
You can opt out from receiving RadiumOne Targeted Advertising based on data collected via your browser by doing one of the following:
- Visiting our Opt Out page by clicking here. Please note that if you disable all cookies via your browser settings (see below), change the browser on the device from which you opted out of RadiumOne Targeted Advertising, or use a different device, you will need to opt out again from receiving cookies.
- Visiting opt outs of standards bodies. RadiumOne is a member of the Network Advertising Initiative (“NAI”), the Digital Advertising Alliance (“DAA”), the Digital Advertising Alliance of Canada (“DAAC”), the European Interactive Digital Advertising Alliance (“EDAA”), the Internet Advertising Bureau (“IAB”), and JICWEBS DTSG and adheres to each organization’s principles (the NAI Codes of Conduct, the DAA Self-Regulatory Program for Online Behavioral Advertising, the Canadian Self-Regulatory Principles for Online Behavioural Advertising, the EDAA Principles, IAB Europe’s Self-Regulatory Principles for Online Behavioral Advertising, and the JICWEBS DTSG Good Practice Principles, respectively). You can opt-out of RadiumOne Targeted Advertising based on data collected via your browser by using (a) the NAI’s opt-out tool, which can be found here; (b) the DAA’s opt-out tool, which can be found here; (c) the DAAC’s opt-out tool, which can be found here; or (d) the EDAA’s opt-out tool, which can be found here.
When you opt out, we will stop (a) collecting information about your interests via your browser and (b) serving you Targeted Ads based on the data collected via your browser.
We will subsequently place a piece of data in your browser’s cookie that tells us that you have opted out of RadiumOne; it does not contain any data about you except for the fact that you have opted out. We need this cookie in place so that we know not to collect information about your interests and serve you interest-based targeted ads in the future.
Mobile Application-Based Data Collection
Open the Google Settings app on your device
Devices with iOS 6 and above use Apple’s Advertising Identifier. To learn more about limiting ad tracking using this identifier, visit the Settings menu on your device as follows:
iOS 7 or higher – Choose Settings > Privacy > Advertising
iOS 6 – Choose Settings > General > About > Advertising
Please click here for an even more comprehensive and up-to-date description of how to opt out from your particular device.
When you opt out, we will stop (a) collecting information about your interests via your mobile applications and (b) serving you Targeted Ads based on the data collected via your mobile applications.
Please note that opting out of either Browser-Based or Mobile Application-Based Data Collection does not mean you will not see ads online from RadiumOne or other digital advertising companies, but only that RadiumOne will not tailor ads based on your interests.
RadiumOne uses Browser-Based Data and Mobile App-Based Data for Targeted Advertising for no more than 13 months. We maintain ad server log data and stored data for a period of up to 18 months in order to comply with audits, court order or law enforcement inquiries. After 18 months, all of the stored data is destroyed. Summarized data is kept indefinitely. Summarized data is aggregated statistical data (impressions, clicks, and conversions) used for financial reporting purposes. If we hold personal information about you as described in the “RadiumOne Site Privacy Practices” section below, we will only keep it for as long as it is necessary for the purposes of (a) collecting and processing it and (b) complying with our legal obligations, resolving disputes, and enforcing our agreements.
Our Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.
Your data protection rights
If you are a resident of the European Economic Area, you have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “Contacting Us” heading below.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contacting Us” heading below.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “Contacting Us” heading below.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area are available here – http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm .
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. As explained above, it may be for our client to respond to your request to exercise a data protection right.
We put in place appropriate technical and organizational measures to preserve the integrity and security of User information and to prevent the unauthorized or unlawful processing of personal information and the accidental loss, destruction, or damage to personal information. These measures include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store data.
In the Event of Merger or Sale
In the event that RadiumOne is acquired by or merged with a third-party entity, we reserve the right to transfer or assign the information that we have collected from Users as part of such merger, acquisition, sale, or other change of control. With regard to any personal information we collect via the Sites as described in the “RadiumOne Site Privacy Practices” section below, we will notify you via email and/or prominent notice on our website of any change in ownership, uses of your personal information, and choices you may have regarding your personal information.
RadiumOne’s websites, products, and services are neither developed for, nor directed at, children under the age of 13. With respect to the Children’s Online Privacy Protection Act (COPPA), RadiumOne does not knowingly collect personal information from nor employ or offer targeting towards children under the age of 13. If you believe your child, who is under the age of 13, has provided RadiumOne with personal information or registered at one of RadiumOne’s websites, please contact us at email@example.com, and we will use reasonable efforts to remove that information from our records.
RadiumOne Site Privacy Practices
The Site is generally intended for use by businesses, advertisers, and potential partners interested in learning more about RadiumOne.
You may provide to RadiumOne the following personal information:
- Contact Information such as name, email address, and phone number;
- Business Information such as your job title and company name.
We use this information to:
- Fulfill your requests;
- Contact you regarding your inquiries;
- Send you newsletters;
- Assess the needs of your business to determine suitable products;
- Send you requested product and service information.
If your personal information changes, or if you no longer desire our service, you may correct, update, port or delete it by contacting us at firstname.lastname@example.org. We will respond to your request within a reasonable timeframe and in accordance with applicable data protection laws.
If you no longer wish to receive our newsletters, you may opt out by following the unsubscribe instructions located at the bottom of each communication.
We use the following tracking technologies to optimize the Site for visitors and monitor your use of the Site.
Performance and functionality cookies.
Description: These cookies are used to enhance the performance and functionality of our website but are non-essential to their use. However, without these cookies, certain functionality (like videos) may become unavailable.
Who serves them: Vimeo (www.vimeo.com)
Analytics and customization cookies..
Description: These cookies collect information that is used either in aggregate form to help us understand how our websites are being used or how effective are marketing campaigns are, or to help us customize our Sites for you.
Who serves them: Google (www.google.com), Leadlander (www.leadlander.com), Marketo (www.marketo.com), ScorecardResearch (www.scorecardresearch.com)
Disclosure by Legal Necessity
RadiumOne may disclose your personal information if: (i) required by law, lawful request by public authorities (including to meet national security or law enforcement requirements), or in the good-faith belief that such action is necessary to comply with applicable laws; (ii) we believe, in good faith, that such action is appropriate or necessary to take precautions against liability; or (iii) such action is necessary to protect our, our Users’ or third parties’ rights. In such circumstances we may disclose your personal information to public authorities, law enforcement agencies, regulatory organizations, courts or other public authorities.
Links to Other Websites
Our Site may also contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with RadiumOne. Linked websites may have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content, your use, or the privacy notices of such websites.
Social Media Applications
Our Sites include Social Media Applications, such as the Facebook Like button or the Twitter Share button. These Applications may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Application to function properly. These Applications are either hosted by a third party. Your interactions with these Applications are governed by the privacy statement of the company providing it.
Your Privacy Rights
You may ask us at any time to provide you a copy of the personal information that we hold about you (if any) by emailing us at email@example.com or by writing to us using the contact details provided below. We may need to apply a charge to cover the cost of dealing with a request to provide you a copy of your personal information.
If you believe that we hold inaccurate personal information about you, please email us at firstname.lastname@example.org or write to us using the contact details below, so we can correct it.
If you are based in the United States or a country outside Europe:
601 Montgomery St.
San Francisco, CA 94111
If you are based in Europe or Australia:
RadiumOne UK Ltd.
20 Garrick Street
London, WC2E 9BT