Purposes of this Policy
This Policy sets out how MediaPal collects and processes personal data about you when you visit the Website, and when we engage in marketing activities based on contact information you provide to MediaPal through other means described in this Policy. It also sets out our practices regarding our use of such data, the steps we take to protect it, the parties (if any) with whom we share it, and the choices and rights that you have regarding how we collect and process personal data about you.
You should read this Policy carefully so that you are fully aware of how and why we are using your personal data.
MediaPal is an advertisement network that bridges the gap between publishers and advertisers by bringing advertisers to publishers (websites). As a Demand-Side Platform, our clients, which include advertisers and agencies, use our technology to purchase advertising, including display, video, native, and mobile ads, in an automated fashion.
MediaPal complies with the DAA “Self-Regulatory Principles for Online Behavioral Advertising”, their “Application of Self-Regulatory Principles to the Mobile Environment, and the “2018 NAI Code of Conduct”. We believe that these programs’ principles help protect user privacy.
How to contact us
If you have any questions about this Policy, including any request to exercise your legal rights, please contact us via email to [email protected]
You have the right to lodge any complaints you have regarding our processing of your personal data with a regulatory authority. We care about your privacy, and we appreciate the chance to address your concerns before you do so.
Changes to the Policy
MediaPal may from time to time revise this Policy. If we make revisions that materially change or affect whether or how we collect or use personal data, we will notify you by email (if, as a user of our Website or recipient of our marketing communications, you have provided us your email address) or by means of a notice on our Website prior to the change becoming effective. If you would like to stay up-to-date on our most current policies and practices, you should review the Website periodically.
The date of the last update can be found at the top of the Policy.
Data pertaining to children
MediaPal’s products and services are not designed for children, and we do not knowingly collect personal data from or about any children. If we are made aware that we have received personal data from or about a child, we will use reasonable efforts to remove that data from our records.
Links, other websites and other third parties
2. The data collected via the Platform
We may assign a unique identifier or ID to your browser, mobile device, or connected television when we serve an ad to it or you use it to access a client’s digital properties, including their websites, emails, apps, and websites, emails, and apps where their ads appear (“Digital Properties”). The unique ID enables MediaPal to determine within a reasonable level of confidence that a computer or device is the same as one previously interacted with. In some cases, based on third-party data, we are able to infer within a reasonable probability that a particular computer or device should be associated with the same unique ID. Also, our partners may provide us with associations that they have made based on data they collect from you. Where we are able to make such inferences, we may use this information to deliver targeted ads across multiple computers or devices. This is sometimes referred to as *cross-device advertising.
The unique ID can be a cookie ID (a unique ID assigned randomly by MediaPal to an unrecognized browser), a mobile advertising ID (a unique ID assigned by the mobile operating system, e.g. Apple ID for Advertising or Android Advertising ID), an OTT TV Device Identifier for Advertising (a unique ID assigned by an OTT TV provider, e.g., Roku ID for Advertising), or a statistical ID (created by MediaPal). We use information about your computer or device to generate the statistical ID, including your operating system, user-agent string, Internet Protocol (“IP”) address, installed fonts, and similar information. This information makes your computer or device distinct enough for our systems to determine within a reasonable probability that they are encountering the same computer or device over time, including in environments where MediaPal cookies are not supported.
Your unique ID is associated with other categories of personal data that we collect about you. These categories include the following:
- Bid Request Data and Impression Data: MediaPal collects personal data about you when we have the opportunity to show you an ad on Digital Properties and when we deliver an ad. We refer to this data as Bid Request Data and Impression Data, and we receive this data from media supply sources, such as publishers (i.e. organizations who operate Digital Properties) and exchanges or supply-side platforms who display ads on publishers’ Digital Properties. This data includes: your imprecise location (e.g., country, region, postal code), browser type (e.g., Chrome or Internet Explorer); operating system (e.g., Mac OS or Windows); browser language (e.g., English or Spanish); IP address; Internet Service Provider and either a unique ID or an ID that one of our partners may assign to your browser or device, which we may associate with the unique ID that we assigned to your browser or device. It also may include Precise Location Data, such as GPS-level latitude-longitude coordinates or location-based radio frequency signal triangulation. When we process Precise Location Data, the mobile app publisher or other media supply source is responsible for enabling you to provide or withdraw consent with respect to the collection and use of your Precise Location Data. Please check the settings of the mobile app and your device if you would like to change your preferences in relation to Precise Location Data.
- Pixel Data and Other Client Data: MediaPal clients may collect data regarding your interactions with them when you visit their Digital Properties. We also may collect the same data when you visit the Website. This includes information such as the time you visited the site, the page URL, your IP address, your browser type (e.g., Chrome or Internet Explorer), the operating system (e.g., Mac OS or Windows), the type of device you use (e.g. laptop or desktop), and data regarding your activities on the Digital Properties. MediaPal clients also mayalso collect hashed personal data that (if unhashed) would reveal your real-world identity, such as hashed email addresses. We refer to everything described above as Pixel Data. Clients also may import data that they have obtained outside the Platform, such as segments that our clients create or obtain independently from other third-party sources. Clients also may import data that they may possess or independently obtain offline, such as data regarding a purchase you made in the client’s store. The client’s offline data is first processed by a third party, which removes any data that reveals your real-world identity, appends a unique ID, and transmits the file to MediaPal for processing. We refer to this data as Other Client Data.
- Third-Party Segment Data and Other Third-Party Data: When they choose to provide it to us, we also receive personal data from third parties. We work with data providers who create and provide us with segments for our clients to use for advertising purposes. We refer to this as Third-Party Segment Data. We also send personal data to and receive personal data from third-party partners that allows them and/or us to associate the unique ID with those partners’ identifiers (through a process called “cookie syncing”) as well as data that associates your different devices with each other. We refer to this data in the Policy as Other Third-Party Data.
- Special or Sensitive Categories of Personal Data: We do not knowingly collect any special categories of personal data about individuals in the EEA, including: personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; personal data concerning your health, sex life, or sexual orientation; and genetic or biometric data. MediaPal also does not knowingly collect any data about other sensitive categories such as personal data about children, financial account numbers, insurance plan numbers, and criminal convictions or offenses.
3. How data is collected
Information you provide
When you provide your personal data to MediaPal on the Website or through other means described in this section, including, for example, when you attend an event hosted by MediaPal, we may use the data for the following purposes:
- To respond to your inquiry;
- To understand your business and offer you potential business opportunities;
- To know or infer your interest in marketing products and services;
- To enrich certain personal data you provide, for example your IP address or company information with information obtained from third parties;
- To segment (group) you with similar individuals;
- To provide you with information and offers about MediaPal products and services, information resources (e.g. whitepapers, reports and webinars), industry news and opinions, and announcements about MediaPal;
- To inform you about and invite you to events, educational opportunities, or training opportunities;
- To ask you to share MediaPal information, offers, and invitations with other people; and
- To attribute your responses or actions to specific marketing campaigns, activities, and channels.
As mentioned above, you may choose to stop receiving marketing communications at any time by following the unsubscribe instructions included in any marketing communications we send you or by contacting us via email at [email protected]. You also may request removal of your personal data from our blog, community forum, or our marketing database by contacting us the same way. We may not be able to remove your personal data from publicly accessible blogs on the Website, but we will let you know if that is the case.
Information collected automatically
MediaPal uses information from the Website log files for troubleshooting and security purposes. We use the Pixel Data that we collect from you on the Website for the purposes described above. For example, we may use Pixel Data that we collect from you on the Website to deliver ads to you when you visit other Digital Properties, and we may collect additional personal data from you on those Digital Properties, such as Bid Request or Impression Data. We use other data that is collected on the Website using cookies and pixels to determine how you found out about us, what your interests are regarding our services, and how to further improve the functionality of the Website and our service towards you as well as to analyze trends and administer the Website. For further information on the cookies and pixels we use on the Website and how you can opt out, please see our Cookie Notice.
4. How we use the data
We use the personal data that we collect to deliver more relevant ads to you. We also use it to improve our products and services that we provide to our clients and partners, and to create new products and services. We have set out below a description of specific ways we use your personal data.
- Enabling MediaPal clients to create marketing campaigns;
- Collecting information about a browser or device;
- Creating segments;
- Setting, reading and modifying a MediaPal cookie, reading a mobile advertising identifier, or generating a statistical ID;
- Making decisions related to the opportunity to display an ad (e.g., deciding which clients’ campaigns are a good match for a bid opportunity and what price to bid in each case) and placing the bid;
- Delivering ads based on your interests or activities on Digital Properties;
- Measuring the effectiveness of those ads and attributing your activities to
- Facilitating our partners’ collection of personal data, including by placing partners’ pixels or tags on our clients’ Digital Properties;
- Honoring opt-out requests for users who have opted out.
- Associating multiple browsers and devices with each other; and
- Development, management, and commercialization of MediaPal’s identify management mapping that associates your different devices with each other.
Creation of segments
As described above, a segment is a grouping of users who share one or more attributes. Our clients may use health-related segments about non-sensitive conditions such as an inferred interest in health and wellness or cough medicine and allergy medications.
While MediaPal does not knowingly create segments that are based upon what we consider to be sensitive information (for example, we do not create segments of EEA users based on personal data considered to be sensitive in the EEA, such as personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, personal data concerning your health, sex life or sexual orientation, or genetic or biometric data), our clients may use the Platform to process some sensitive data, which may come from our clients’ Digital Properties or our partners. We take steps designed to ensure that this is done in compliance with applicable laws and self-regulatory guidelines, including through our contracts and policies with our clients and partners.
Automated decision-making and profiling
MediaPal uses proprietary algorithms to make decisions about whether or not to bid on opportunities to serve you ads and, if so, how much to bid. The ads you see are the result of client campaigns that specify how much to spend and on what basis to spend combined with the use of our algorithms. The ways in which we use algorithms to determine bid prices may be considered automated decision-making in certain jurisdictions. Additionally, these processes, in combination with client campaigns described below, may constitute profiling in certain jurisdictions.
As explained above, we assign a unique ID to your browser or device. Using proprietary technology, we associate data that we collect about you with this unique ID and create segments using inferred details about certain of your preferences, behaviors, and demographic information. Many of our clients’ campaigns rely on such segments. If MediaPal receives an opportunity to show you an ad on a publisher’s website or in a publisher’s app, that client may be one of the many who are eligible to bid to serve an ad to you.
The automated processes that we use do not affect your legal rights (such as your right to vote, take legal action, or freely associate with others) or your ability to receive social benefits or obtain citizenship, nor do they have legal effects on you. Also, we do not knowingly process or make automated decisions about EEA users based on any data that falls into special categories in the EEA. As described below, you have the right to object to this automated processing at any time and you may have additional rights.
Legal basis for processing
Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we process it. However, we will normally collect personal data from you only where the processing is in our (or a third party’s, such as our clients’) legitimate interests and not overridden by your rights, such as your right to opt out. If we collect and use your personal data in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate the Platform and serve you ads on behalf of our clients. We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.
Opt-out and choice mechanisms
If you want to limit the data MediaPal collects and processes about you and want us not to target ads that are based on your interests to your browsers or devices, you may opt out from MediaPal tracking and interest-based advertising at any time. If you opt out, you will still see ads, but those ads are not likely to have anything to do with products or services you care about. With interest-based advertising, you receive ads and offers that are more likely to be useful to you.
If you use multiple browsers or devices and wish to limit the data MediaPal collects and processes and do not wish to receive MediaPal interest-based advertising on any of them, you must opt out from each browser and device individually.
Opt out in a browser
You may opt out if you are using a browser by “Clicking here to opt out”. Please note that if cookies are not enabled in your browser, including if third-party cookies are disabled, or if you use certain ad-blocking tools, our opt-out mechanism may not work properly. Please also note that deleting your cookies does not opt you out. Please be aware that if you clear your cookies, or if you use a different browser or device, you will need to renew your opt-out choice.
Opt out in the mobile application environment
You may opt out in mobile app environments using the “AppChoices” mobile application, where applicable, which you can download to your mobile device from your App Store or via the Digital Advertising Alliance AppChoices page here.
Other ways to opt out
You may learn more about interest-based advertising and opt out of interest-based advertising from MediaPal and other online advertising companies that are also members of applicable self-regulatory organizations by visiting their opt-out links:
- Network Advertising Initiative — http://optout.networkadvertising.org/
- Digital Advertising Alliance (DAA) — http://optout.aboutads.info/
- Digital Advertising Alliance Canada — http://youradchoices.ca/choices
- Digital Advertising Alliance EU — http://www.youronlinechoices.com/
- DAA AppChoices page — http://www.aboutads.info/appchoices
Other ways to limit ad tracking in the mobile and OTT TV Device application environment
You also may limit ad tracking in mobile app environments on your mobile device as well as on your OTT TV Device. For the most effective and up-to-date methods for doing so, you should consult instructions provided by those device manufacturers. We offer the following information solely for informational purposes, and we cannot guarantee that the methods below are the most current:
- Apple instructions for how Opt out of interest-based ads
- Google instructions for how to express choice on Android devices
- Roku’s instructions for how to express choice on Roku devices
Where MediaPal receives a signal to limit ad tracking, we will collect and process data from your device only as needed to honor your choice and for limited research and development purposes to improve our device-recognition technology, which also helps to improve our ability to honor your choice. Where MediaPal receives a signal to limit ad tracking, MediaPal also will not serve interest-based advertising in the apps on your mobile device.
If you have questions about how to opt out or limit ad tracking, please contact us at [email protected].
5. Disclosure of data from Website
We may share your personal data with the following categories of third parties for the purposes set out above:
- With our clients, resellers and partners where this is necessary in order to operate the Platform and the Website, to provide our products and services, to improve our products and services, and to create new products and services. These partners include but are not limited to segment providers, any provider with whom we synchronize cookie IDs, and partners who receive data exported from the Platform at our clients’ request.
- With media supply sources such as publishers (i.e. organizations who operate Digital Properties) and exchanges or supply-side platforms who display ads on publishers’ Digital Properties in connection with the opportunity to purchase advertising inventory.
- With third parties with whom we contract to help with the operation of the Website, the provision of our products and services and our business operations. Services provided in connection with the Platform include data storage and computing infrastructure, content delivery, dynamic creative optimization, ad measurement, audience modeling, data enrichment and the AdChoices icon. Services provided in connection with the Website and our marketing activities include email services, event management, maintenance of our marketing database, web analytics, recruitment, management of marketing and customer relationship and social media.
- With third parties when we consider this to be necessary: to establish or protect the legal rights of MediaPal or its employees, agents and contractors, as well as the legal rights of its clients or other third parties; to protect the safety and security of users and visitors to our Website; to protect against fraud; or to comply with the law or legal process.
- When we are required to or allowed to do so by law (for example in response to subpoenas, to comply with a binding court order, legal process, or government requests, including in response to a public authority to meet national security or law enforcement requirements).
We require third parties to respect the security of your personal data and to treat it in accordance with applicable laws. We also define the permissible scope and, where appropriate, restrict the use by third parties of your personal data. We require our third parties who provide us services to only use the information that we provide to them in connection with the services they perform for us and in accordance with our instructions.
We also may publish or otherwise make public anonymous, aggregate, or summary information regarding campaigns run on behalf of our clients. For example, we may publish a report that reflects aggregated statistics regarding seasonal trends in shopping patterns or geographic differences in advertising impression opportunities.
6. Data security and integrity
MediaPal implements appropriate technical and organizational measures to safeguard personal data in our possession against being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. No transmission of data over the Internet, however, is guaranteed to be completely secure. It may be possible for third parties not under the control of MediaPal to intercept or access transmissions or communications unlawfully. While we strive to protect your personal data, we cannot ensure or warrant the security of any data you transmit to us or that we collect about you. We have procedures in place to address any suspected personal data breach, and if we are required by law, we will notify you of any such breach.
MediaPal processes information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current, and reliable for its intended use. If you have any questions about security on the Website, you can contact us at [email protected]
7. Data retention
If you provide us with your personal data on our Website or through other means described above in Section 5, we will retain your information for as long as it is necessary for our legitimate business purposes. For example, if you sign up for an account or request information on the Website, we will retain the data you provide for as long as we think you may have an interest in receiving information from us. Similarly, we retain log files for as long as it is necessary for our legitimate business purposes.
We will retain all other categories of personal data that we collect or receive, including Bid Request Data and Impression Data, Pixel Data and Other Client Data, and Third-Party Segment Data and Other Third-Party Data, for no longer than thirteen months, and we retain much of this data for shorter periods of time. Furthermore, we may delete personal data in response to a request from a user under applicable law or when contracts with our clients end. Also, most cookies expire within thirteen months, while certain cookies that are not used for tracking are refreshed for as long as such cookies are necessary for our legitimate business purposes.
8. Your legal rights
MediaPal acknowledges that in some circumstances, you have certain rights under data protection laws in relation to your personal data. Depending on where you are located, these may include the right to access your personal data, correct certain personal data, erasure of your personal data, object to certain processing of your personal data, restrict certain processing of your personal data, personal data portability and not be subject to decisions based solely on automated processing. To the extent required and permitted by applicable law, we will provide you access to the personal data we hold about you and also allow you to correct inaccurate information in certain situations (e.g., if you submit your email address on the Website), delete your personal data, object to processing, restrict certain processing of your personal data, port your personal data or elect not to be subject to decisions based solely on automated processing. If you would like to exercise any of these rights, please send your request to us at [email protected] and we will respond to your request in accordance with applicable laws.
We may need you to provide additional information to allow us to confirm your identity in order to process your request. We do this as a security precaution and to ensure that we do not disclose personal data to the wrong person.
Unless otherwise indicated in the Policy, we try to fulfill legitimate requests within 30 days. If it will take longer, we will notify you and keep you updated.