Effective as of September 30, 2016
MediaMath is a global provider of digital advertising media and data management technology. MediaMath’s TerminalOne™ Marketing Operating System (the “Platform”) activates data, automates execution, and optimizes advertising interactions across addressable media — delivering greater performance, transparency, and control to marketers and a better experience to consumers.
In this Policy, we use the terms “MediaMath“, “our“, “us” and “we” to refer to MediaMath, Inc. and our affiliates.
MediaMath is committed to protecting the privacy of consumers when we process information about them via our Platform and the users of our Website. We adhere to applicable industry guidelines, and will continue to review and update our Policy and procedures to ensure the safety and protection of personal information.
MediaMath is an active member of the industry associations that govern the policies around online consumer privacy in the context of interest-based advertising, including: the Digital Advertising Alliance (DAA) in the US, EU, and Canada; the Direct Marketing Association in the US and the UK; the Interactive Advertising Bureau (IAB) in Australia, Brazil, Canada, Europe, Germany, Italy, Mexico, Singapore, the US and the UK; and the Network Advertising Initiative (NAI) (www.networkadvertising.org). MediaMath complies with the DAA Self-Regulatory Principles for Online Behavioral Advertising and their Application to the Mobile Environment, and the 2015 NAI Code of Conduct. We believe that these programs’ principles help protect individual consumer privacy.
The MediaMath Platform
Data Collection and Use
The information MediaMath collects includes common information found in every communication sent over the Internet, from which we infer such things as: browser type (e.g., Chrome or Internet Explorer); operating system (e.g., Mac OS or Windows); browser language (e.g., English or Spanish); Internet Protocol (IP) address; Internet Service Provider (e.g., Comcast or Verizon); and mobile advertising identifier, for mobile devices such as smartphones and tablets.
MediaMath may also collect data regarding your interactions with our clients and partners, including your use of our clients’ sites and mobile apps, the sites and apps our clients advertise on, and other pages on the Internet. We may also capture additional data in order to calculate a statistical ID, as described below.
We may also receive Precise Location Data (as defined by the NAI) generated from your use of your mobile device, such as the latitude/longitude coordinates provided by a mobile app publisher or other media supply source in conjunction with the opportunity to purchase advertising inventory. MediaMath may transfer such Precise Location Data to clients and partners, including for use in targeting ads based on the current location of the device. 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.
We and our clients and partners use the information we collect to create data segments, and these data segments are generally based upon your interactions with our clients or other third party media suppliers, such as the websites that you visit and the mobile applications that you use.
We also receive pseudonymous information from third parties, when they choose to provide it to us. This information may include identifiers (like mobile advertising IDs) and interest-based advertising data tied to those identifiers, including segments provided by third-party data providers for our clients to use in targeting ads through the Platform. MediaMath does not use this data to personally identify you.
We may assign a MediaMath ID to your browser, computer or mobile device when we serve an ad to it or we identify it on a client’s website or mobile app. The MediaMath ID may be stored in a cookie on your computer or mobile device. It helps us understand your interests and deliver more relevant ads to you. The MediaMath ID and other information collected via the Platform can also help our advertising clients measure your activity on their sites and determine the effectiveness of advertisements delivered via the Platform. This information can then be used by our advertising clients to better cater to your needs and deliver ads to you for the types of products and services in which you might be interested. None of these technologies enable us to personally identify an individual. Instead, they enable the Platform to determine within a reasonable level of confidence that a computer or device is the same as one with which the Platform has previously interacted. For instance, the Platform can determine that a computer or device to which we served an ad on Monday may be the same computer or device for which we observed a purchase on Tuesday.
In some cases, MediaMath is able to infer within a reasonable probability that a particular computer or mobile device should be associated with the same MediaMath ID that we have previously assigned to another computer or mobile device. In other words, in such cases we are able to infer that a device (e.g. your computer) and another device (e.g. your smartphone) are used by the same user. Where we are able to make such inferences, we may use this information to deliver targeted ads across multiple computers or devices, and to improve the services we provide to our clients. This is sometimes referred to as cross-device advertising.
We use the information that we collect directly and the information that we obtain from third parties to create segments, run analytics, target ads, and measure the effectiveness of ads on behalf of MediaMath’s clients. We also use it to improve our Platform and the products and services that we provide to our clients, and to create new products and services. For these purposes we may share information with our clients, partners and service providers.
MediaMath does not knowingly collect data or create data segments that are based upon what we consider to be sensitive information (for example, we don’t create any data segments to determine credit worthiness, for insurance underwriting or similar purposes, nor do we create segments of EU consumers based on personal data considered to be sensitive in the EU, e.g. information about physical or mental health or condition, sexual orientation, race or ethnic origin, political opinions, religious or similar beliefs). Clients may use health-related segments (which are not comprised of sensitive health data) such as an inferred interest in health and wellness or cough medicine and allergy medications. Click here for a list of the standard health-related segments provided by third-party data providers that may be used in MediaMath’s Platform.
Cookies, Web Beacons, and Other Ad Targeting Technologies
Like most digital marketing platforms, MediaMath uses “cookies”, mobile advertising identifiers, and other technologies to enhance users’ experiences on the web, to deliver more relevant ads, and for ad delivery and reporting via the Platform.
We use these technologies to help recognize a computer or device so that we and our clients are able to deliver relevant advertising to you, measure the impact of that advertising and better understand and recognize digital media usage patterns.
The types of technologies used via the Platform include:
- Mobile Advertising Identifiers – Mobile advertising IDs (e.g., Apple’s IDFA or Google’s AAID) are unique IDs that are associated with individual mobile devices and that do not reveal your real world identity. They usually are user-resettable.
- Statistical IDs – Statistical IDs are created via an algorithm using pseudonymous information about your computer or device, including your operating system, user-agent string, IP address, Internet browser, 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, including in environments where MediaMath cookies are not supported.
These technologies are used to identify a computer or device within a certain level of confidence that enables the Platform to function and serve more relevant ads.
Data Retention on the Platform
We retain the MediaMath ID and, where applicable, its association with other devices for as long as this is necessary for our legitimate business purposes.
Cookies set via the Platform expire within 13 months. MediaMath also expires within 13 months the browsing data tied to your MediaMath ID (e.g., records of when we served an ad to your browser or identified it on a client’s website or mobile app).
You may opt out from receiving MediaMath interest-based advertising at any time through one of the ways described below. If you wish to opt out of MediaMath tracking and interest-based advertising on both internet browsers and mobile applications, you need to opt out separately for each browser or device via the methods described below.
Two Reasons You May Not Want to Opt Out
Advertising supports the free Internet. It is the primary way that most website and app publishers make money in order to produce the content consumers want. Not all advertising shown to consumers is relevant to their interests, though. Interest-based advertising is advertising that tries to make the ads you see more interesting and relevant to you based on the types of sites you visit online and other information that does not personally identify you. We conduct interest-based advertising on our Website, and work with our clients to help them do the same on their websites and apps.
Without interested-based advertising, 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.
There is also a second benefit to you: companies that create websites and apps rely on the revenue from interest-based advertising to support the rich array of content they produce. Without that revenue, the content would either be unavailable or consumers would have to pay for it.
What does it mean to opt-out?
In general, “opting out” means that you don’t want MediaMath to deliver ads that are targeted to your interests on your computer or device. If you use multiple browsers, computers or mobile devices and do not wish to receive MediaMath interest-based advertising on any of them, you must opt out from each browser, computer, and mobile device individually. Please note that if cookies are not enabled in your browser, 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.
Opt out of interest-based advertising on this browser (if using a browser)
Your current interest-based advertising status with MediaMath in this web browser is:
When you opt out, we record the opt-out on our servers and in browser environments will attempt to place an HTTP opt-out cookie onto your computer or device. When you opt out, MediaMath stops serving interest-based advertising in that browser. In many instances, even if you delete your cookies, we are able to maintain a record of your opt-out on our servers. Nonetheless, please note that if you clear your cookies, or if you use a different browser or device, you may need to renew your opt-out choice.
Opt out of mobile application-based data collection
You may opt out of interest-based advertising in mobile app environments using the “AppChoices” mobile application, which you can download to your mobile device from your App Store or via the Digital Advertising Alliance App Choices page here.
Please note that you will still see ads if you opt out. The ads delivered via MediaMath will just not be as relevant to you. When you opt out, MediaMath stops serving interest-based advertising in mobile apps on that device.
Other ways to opt out
You may learn more about interest-based advertising and opt out of interest-based advertising from MediaMath and other online advertising companies that are also members of applicable self-regulatory organizations by visiting their opt-out links:
- Network Advertising Initiative (NAI) – http://www.networkadvertising.org/choices/
- Digital Advertising Alliance (DAA) – http://www.aboutads.info/choices/
- Digital Advertising Alliance Canada (DAAC) – http://youradchoices.ca/choices
- Digital Advertising Alliance EU (EDAA) – http://www.youronlinechoices.com/
- DAA AppChoices page – http://www.aboutads.info/appchoices
Other ways to exercise choice
You may also limit ad tracking in mobile app environments on your 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 to Limit Ad Tracking on devices such as iPhones and iPads
- Google instructions for how to express choice on Android devices
Where MediaMath receives a signal to limit ad tracking, we will not serve interest-based advertising in the mobile app environment of that device.
If you have questions about how to opt out or limit mobile tracking, please contact us at email@example.com.
The MediaMath Website, www.mediamath.com
Data Collection and Retention on our Website
MediaMath collects personal information on the Website when visitors choose to reveal it to us. For example, when you contact us to request a demonstration of our products or services or to otherwise send us questions, we will collect personal information such as your name and email address. MediaMath uses information from the Website log files to determine how you found out about us, what your interests are regarding our services, and how to further improve our site and our service towards you.
If you create an account on our Website, we will retain your information for as long as your account is active with us or for as long as you are receiving our services. After you have closed your account with us or ceased to use our services, we may retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Communications From the Site
When you sign up for our services on our Website, we will use your name and email address to send newsletters to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us via email at firstname.lastname@example.org.
You may also provide us with your personal information on the publicly accessible blogs on our Website. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
We display testimonials from satisfied clients on the Website in addition to other endorsements. We will obtain our client’s permission before we place these testimonials on the Website. If you are a client who wishes to update or delete your testimonial, please contact us at firstname.lastname@example.org.
Social Media Features and Widgets
When you sign up for our services on the Website, we may provide your personal information to companies that provide services to help us with our business activities, such as an email service provider to send emails on our behalf or a recruitment partner to process job application data. These companies are authorized to use your personal information only as necessary to provide these services to us.
Information Collected Automatically
As is true of most websites, we gather certain information automatically and store it in log files. This information may include IP address, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you. We collect information automatically through the use of various technologies including cookies. For further information on the cookies we use on the Website and how you can opt out, please see our Cookie Notice.
Additional information applicable to both our Website and Platform
Links and other websites
Information Pertaining to Children
MediaMath’s products and services are designed for those 13 years of age and older. We do not knowingly collect personal information from anyone under the age of 13. If we are made aware that we have received personal information from someone under 13, we will use reasonable efforts to remove that information from our records.
Data Security and Integrity
MediaMath implements technical and organizational measures to safeguard data in our possession against loss, theft, and unauthorized use, disclosure, or modification. 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 MediaMath to intercept or access transmissions or communications unlawfully. While we strive to protect your information, we cannot ensure or warrant the security of any information you transmit to us. MediaMath 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 or through the Platform, you can contact us at email@example.com.
Data Sharing and Disclosure
We may publish or otherwise make public anonymous, aggregate, or summary information regarding campaigns run on behalf of our clients.
We may share information (including personal information):
- With our group companies.
- With clients and partners, where this is necessary in order to operate the Platform and the Website, to provide our products and services, to improve our Platform, products and services and to create new products and services.
- With service providers who help with the operation of the Platform, the provision of our products and services and our business operations. We require our service providers to only use the information that we provide to them in connection with the services they perform for us.
- With third parties when we consider this to be necessary: to establish or protect the legal rights of MediaMath 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).
- If MediaMath sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, we may transfer or assign the information to a third party as part of that transaction.
International Data Transfers
The information that we collect from you and about you may be transferred to and stored in a country other than your country of residence, such as the USA, which may not offer the same level of protection of personal information as your country of residence. However, we will take contractual and/or other measures to ensure your personal data is protected.
In addition to the above, we adhere to the principles of the EU-US Privacy Shield and the US-Swiss Safe Harbor Principles.
EU-US Privacy Shield
When we process any personal information originating from the European Union (EU) in the USA, MediaMath, Inc. has certified its compliance with the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from EU member countries. MediaMath, Inc. has certified that for all personal information it receives from the EU, it will adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfers, Security, Data Integrity & Purpose Limitation, Access, and Recourse, Enforcement and Liability.
To find out more about the Privacy Shield, access the Privacy Shield List, and find details of our certification, please visit: https://www.privacyshield.gov/list.
Under the Privacy Shield, MediaMath, Inc. may remain liable if its third-party service providers process your personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.
Residents of the EU who believe that their personal information has not been processed in compliance with the Privacy Shield Principles may raise their complaint in the following ways:
- You can contact MediaMath, Inc. directly using the details in the “Contact Us” section below. We will respond to your complaint within 45 days of receipt.
- We have further committed to refer unresolved privacy complaints under the Privacy Shield via the Better Business Bureau, an alternative dispute resolution provider located in the United States. If you do not receive a timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint directly with the BBB.
- Further, your complaint can be made or referred to the U.S. Department of Commerce or the Federal Trade Commission for further investigation.
- For residual disputes that cannot be resolved by the methods above, you may be able to invoke a binding arbitration process under certain conditions. To find out more about the Privacy Shield’s binding arbitration scheme, please see: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
The Federal Trade Commission has investigation and enforcement authority over our compliance with the Privacy Shield.
US-Swiss Safe Harbor
In respect of personal information originating from Switzerland, MediaMath, Inc. has certified its compliance with the US-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce. This means that for all personal information originating from Switzerland, MediaMath will adhere to the Swiss Safe Harbor Principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement when processing the Personal Data in the USA. To learn more about the Swiss Safe Harbor program and to view our certification page, please visit: https://safeharbor.export.gov/swisslist.aspx.
MediaMath has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism 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 https://www.auto.bbb.org/EU-Safe-Harbor-Complaint-Form/ for more information and to file a complaint.
If you are from the European Union or Switzerland and would like to gain access to, or request amendment, correction or deletion of information that MediaMath, Inc. holds about you, please contact us using the details in the “Contact Us” section below. We will consider and respond to your request in accordance with, as applicable, the Privacy Shield or US-Swiss Safe Harbor Principles, and any applicable laws.
MediaMath acknowledges the individual’s right to access their personal data and will provide you access to the personal information we hold about you to the extent it is reasonably available and allow you to correct, amend, or delete inaccurate information, as required and permitted by applicable law. If you’d like us to correct, amend, or delete any other personal information that you have provided to us, please send your request to us at firstname.lastname@example.org and we will respond to your request within 30 days.
You may request that we cease sending you any marketing communications (including by email and SMS) at any time by notifying us in writing using the contact details provided below or following any “unsubscribe” instructions included in any marketing communications which we send to you.
MediaMath has implemented processes to ensure compliance with this Policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible, and in conformity with the NAI Code of Conduct. We encourage interested persons to raise any concerns by emailing email@example.com and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information.
To address any issues regarding our compliance with the NAI Code of Conduct, MediaMath, along with the NAI and other NAI members have created a compliance program that incorporates attestation reviews, a consumer complaint process, sanctions, and annual reporting to help ensure that member companies keep their promises to you and abide by the NAI Code of Conduct. Please refer to the NAI site for more information.
From time to time MediaMath may revise this Policy. The date of the last update can be found at the top of this Policy. If we make revisions that materially change or affect whether or how we collect or use personal information we will notify you by email (if, as a user of our Website, you have provided us your email address) or by means of a notice on our Website prior to the change becoming effective. Therefore, you should review the Website periodically so that you are up-to-date on our most current policies and practices.
If you have any questions about this Policy, please contact us as follows.
- If you are based in Europe:
By email at firstname.lastname@example.org or by post to MediaMath, Attn: Melinda Clemans, Remo House, 310-312 Regent Street, London, UK W1B 3AU.
- If you are based in the USA, Asia or elsewhere outside Europe:
By email at email@example.com or by post to MediaMath, Inc, Attn: Alice Lincoln, 4 World Trade Center, 45th Floor, New York, NY 10007.