We think that everyone has a fundamental right to privacy. We also believe that respect for privacy rights & consumer choice can coexist with an advertising ecosystem that is built on consented information about consumer interests and behavior. This data-driven ad ecosystem supports millions of small, medium, and enterprise-sized publishers that create valuable content and monetize it through advertising. The more relevant that advertising is, the more revenue these publishers generate, and the more free content they can create. Further, this advertising ecosystem creates highly skilled jobs not only at publishing & media companies, but also data & technology companies, and brands. If executed well, there is a clear path for the ad ecosystem to benefit consumers, publishers, and brands, in a privacy-centric way. We were excited to build our business when the Mobile Advertising ID (MAID) was first introduced because it offered a privacy-safe way to map data to consumers. It gave consumers the flexibility to stop ad tracking or reset their MAID anytime they wanted. It was a needed and positive evolution from the privacy-fraught cookie infrastructure of web browsers. As part of our commitment to privacy rights, VentiveIQ welcomes the new crop of privacy regulations that started in Europe, California and are now moving across the globe. We are advocates for national comprehensive privacy regulations, especially for the United States. Improved privacy regulations create a brighter future for those who create and consume content online. Consumers will be better informed about and have more control over how information about them is used. With clear and uniform privacy regulations, companies also benefit from shared rules of the road for operating and planning their businesses.
1.VENTIVEIQ’S SERVICES
VentiveIQ Solutions, Inc. (“VentiveIQ”) is a technology company that provides clients with proprietary data solutions, including those that help publishers drive ad revenue and brands find great customers. VentiveIQ works with co-op providers (“Providers”) such as app publishers, brands, marketers, and data and technology companies that generate information about people and devices, such as app ownership, and app usage. VentiveIQ offers data and technology solutions to publishers, brands, and other companies that use data for Advertising Services (defined below), Data Modeling (defined below), analytics, and other related purposes; as well as for non-advertising research and analysis of consumer behavior (“Customers”). Collectively, these activities are referred to as the “VentiveIQ Services” or the “Services.”
2. SCOPE OF THIS PRIVACY POLICY
This VentiveIQ Privacy Policy (“Privacy Policy”) covers the information that we collect or receive from the following sources:
- Across the internet, offline sources, and through internet-connected devices from Providers
- Information we collect or receive from visitors to our website at ventiveiq.com (the “Site”)
- Information provided by individuals who interact with us at events, conferences, and related activities (“Events”). Data request form and web portal: DO NOT SELL MY PERSONAL INFORMATION PAGE Please note: third parties have their own privacy policies and this Privacy Policy does not apply to their chosen policies related to collection, use, storage, destruction, disclosure, and/or processing of any information the third parties handle.
3. SOME HELPFUL TERMINOLOGY
We use some phrases in this Privacy Policy that are unique to our business or the technology underlying our data engine. Here are definitions of some of the key terms that you’ll need to know to make it easier to understand this Privacy Policy.
Advertising Services
Data services to marketers, brands, and other companies that use the information collected by VentiveIQ for ad targeting, audience creation, measurement, analytics, and other purposes associated with advertising (regardless of medium or channel) via online or offline channels including display, mobile, social, email, direct mail, and video.
CCPA
The California Consumer Privacy Act (California Civil Code 1798.100-1798.199), a California state law now in effect that addresses the privacy rights of California consumers.
Personal Information
“Personal information” is the meaning employed by CCPA, which is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include certain de-identified or aggregated information, information publicly available in government records, or certain other information excluded from the CCPA’s scope.
Email Addresses
We collect versions of email addresses that consumers have entered on our Partners’ registration, checkout, or other such forms. In most cases these are encrypted or hashed versions of the users email, though in some cases they may be stored in clear text, however with strict access control.
Mobile Advertising ID
A “mobile advertising ID” or “MAID” is a unique identifier of a mobile device used in the mobile advertising ecosystem. This can be Android’s Ad ID (AAID) or Apple’s Identifier for Advertisers (IDFA).
Data Modeling
“Data Modeling” is a process that includes a broad set of probabilistic, inferential, or mathematical techniques used to turn raw data into useful insights, intelligence, scores, or predictions.
4. TYPES OF DATA WE COLLECT
We collect data, including Personal Information in some cases, from the following categories of sources.
A. From Your Internet-Connected Devices
When Providers we work with integrate our technology with their devices, apps, sites or services, we collect the following types of data about you and your device through those partners.
- Device Data. Device data includes details about the device(s) you use, such as its manufacturer; model; registered country code; mobile carrier; operating system and version; crash data (if applicable); and what settings and permissions you’ve enabled. Your device and software settings affect what information your device makes available to us such as the language you prefer to use on your mobile device; mobile applications you install on your device and purchase you make in those mobile applications; bluetooth or wireless preferences; and the like. We may collect this information from mobile devices, internet-connected televisions, desktop and laptop computers, and/or other internet-connected devices.
- Identifiers. We collect identifiers such as mobile advertising IDs, IP addresses, cookies, and other identifiers from your device, and clear or hashed email addresses, names, phone numbers, or other identifiers that you voluntarily provide when you register, checkout, or otherwise enter data into an online or app form.
- App and Site data. We collect information about the specific apps & sites you may use and/or visit on your device(s), such as the names of those apps, sites, and other relevant metadata.
- Geolocation Data. We collect location data such as latitude, longitude, and timestamps directly from your device or other sources as mentioned above and from our Providers.
- Demographic Data. We collect information such as your age or gender that you voluntarily provide when you register or make a purchase on an app, website, or other such event. In some cases, this may be considered information about “protected classifications” under the CCPA.
- Inferences. We may draw inferences from the information we collect from mobile devices to create audience segments reflecting consumer preferences and characteristics. Note that some of our data may fall into more than one of the above categories. For example, an IP address is both a unique identifier and device data.
B. From Third Parties and Aggregated Public Sources:
We may collect information from public and private sources of aggregated data (e.g. the Apple App Store and the Android Play Store), website crawling, or from other third parties or public sources that we use in providing the VentiveIQ Services:
- Metadata about mobile apps
- Point of Interest data such as an identifier for a commercial location and relevant metadata(e.g. a retail store or a coffee shop)
- Census data and other publicly available data sources
- Other sources of behavioral, purchase, demographic information, and/or identifiers
C. In Our Corporate Capacity and From our Site
People who visit VentiveIQ’s Site are generally representatives of businesses (such as for our Providers or our clients) that are interested in VentiveIQ’s Services, not individual consumers. When individuals visit our Site, they may choose to provide information to us, such as when they create or log in to their account with us, to contact us to request or provide information, or apply for a job. In addition, when you interact with our Site, we (and third parties) may collect technical information from your browser or device by automated means such as pixels, cookies, web beacons, local storage, JavaScript, API, and other similar technologies. We may also collect this kind of information when you interact with email messages we have sent you. As we and our service providers develop other technologies, we may also gather information through other methods. We may collect the following categories of information from our Site:
- Full name
- Email address
- Phone number
- Terrestrial Address
- Account username and password
- Professional and employment-related information
- Cookie IDs
- Information about your device and operating system
- System activity and settings
- Information about your internet connection, including IP address and carrier.
We may also sometimes collect information through business channels and Events such as trade shows, or through marketing platforms that help us identify new customers.
5. HOW VENTIVEIQ USES THE DATA WE COLLECT
- To provide the Advertising Services and associated analytics.
- To facilitate research and analysis of consumer habits.
- To make inferences about consumer interests.
- To perform Data Modeling for quality control on our data solutions.
- To establish probable connections among different browsers, devices, and internet identifiers to associate them with the same user or household, and to otherwise create linkages between different data elements (e.g., establishing that a hashed email address is associated with a certain device ID, or that a mailing address is associated with a device ID). For instance, when a user visits or logs in to a website (or engages in a particular type of transaction), we might use the information we collect to help a business send advertising or content to the user across a different channel or device (such as mobile, TV, email or direct mail).
- Our internal business purposes such as the development, enhancement, improvement, and release of new products and services. This allows us to create technology products that we license or sell to Customers. These products help our Customers understand their end users better in order to create enhanced experiences for them.
- To maintain and enhance VentiveIQ Services, for example, to debug or research technical issues and resolve them.
- To maintain the security of our systems and to prevent fraud.
- When users submit contact information to us in connection with an inquiry or request, to verify and respond to those inquiries or requests.
- For legal or regulatory compliance or to assert or protect our rights.
- To create aggregate data (which is not personal information) to run analytics on certain customer segments, advertising campaigns, or other datasets.
- To provide, maintain, and improve the Services (including our website) for VentiveIQ Customers and prospective customers
- For our own advertising and marketing purposes.
- For individuals who apply for jobs through our website, to evaluate them as candidates for employment with VentiveIQ.
6. DATA SHARING
As to the personal information that we collect in the course of operating our Services, we may share and disclose such information as follows:
- With our Customers, Licensees and with our Providers: We provide VentiveIQ Services to our Customers, Licensees and Providers that include agencies; brands; third party marketing partner; company operating in ad tech sector; digital advertiser; mobile app publishers; and other companies and not for profit organizations that use data for Advertising Services such as targeting; audience creation; measurement; analytics; advertising optimization; create linkages/models and other purposes associated with advertising via online or mobile channels including display, mobile, social, email, and video; as well as for purposes conducting research and analysis of consumer behavior.
- With our Service Providers: Service providers are companies that provide VentiveIQ with special business, technical, and operational services; and are different from Providers of data. We may also share your personal information with service providers and/or data processors to help us operate, provide, improve, understand, customize, support, and market our Services. For example, we use service providers for business operations such as Site and data hosting. We may also use service providers to assist us with providing our VentiveIQ Services to Customers or Providers, or to assist us in marketing to our finding new customers. Our service providers are contractually required to use personal information only to provide their service to us, and are contractually prohibited from using or disclosing personal information for their own purposes.
- With your consent: We may share information about you with third parties at your direction or with your consent.
- In Connection with a Financing or Sale of Our Business: If a third party invests in, or acquires, some, or all, of our business or assets, we may disclose your information in connection with the sale (including during due diligence in preparation for the transaction).
- In Connection with Legal Obligations: We may disclose your personal information as required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights; protect your safety or the safety of others; investigate fraud; or respond to a government request. In certain situations, VentiveIQ may also be required to disclose personal data in response to lawful requests by public authorities.
- We may share and disclose the information we collect in our corporate capacity in most of the above ways as well: we may share them with our service providers, with consent, in connection with financing or sale, or to exercise our legal obligations.
7. HOW TO CONTROL DATA COLLECTED ABOUT YOU
We recognize that your privacy is important to you, so we offer the following ways to give you control over the data that we collect from you. Opting out of Tailored Advertising: We use and share information we collect from both online and offline sources to inform the advertising you see online and to tailor it to your interests. This may include using information collected across the online applications you use, or information associated with hashed email addresses or other hashed identifiers.
The Network Advertising Initiative (NAI) maintains a site with tools and instructions for how to opt out of Tailored Advertising by NAI member companies. VentiveIQ adheres to the NAI Code of Conduct. To opt out of Tailored Advertising by VentiveIQ and other NAI member companies, please visit: https://optout.networkadvertising.org
Further, we also support our own VentiveIQ Opt-Out process. If you use multiple devices or multiple email addresses, make sure you apply the opt out or data control mechanisms provided to all of the web browsers, internet-connected devices, and email addresses you use for a complete opt-out. Opting out using a single browser, device, or email address will not automatically opt out all browsers, devices, or email addresses you use.
Other companies’ opt outs or data control mechanisms may function differently than ours. Note that when you opt out of Tailored Advertising, you may continue to receive contextual ads which are ads based on the content of the web page or app on which they appear.
We honor the mobile device settings for Android and Apple iOS devices. To exercise this opt-out, please visit the privacy settings of your Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest-based ads” (Android). For devices where we are able to see that such a selection has been made, we will not use information collected from that device to deliver targeted advertising. Also, please visit https://youradchoices.com/appchoices to download the AppChoices Tool to control interest-based advertising on apps on your mobile device and https://thenai.org/opt-out/mobile-opt-out/ for more information and instructions on opting out on mobile devices.
California Residents:
If you are a California resident, you may have additional rights in connection with the data we collect about you. To learn more about these rights and how to exercise them, please refer to section 11 of this Privacy Policy.
8. DATA RETENTION
We may retain data for use with the VentiveIQ Services for up to 30 months from the most recent date of receipt. We may archive and store backups of those data for up to 10 years.
9. SECURITY MEASURES
VentiveIQ uses security controls to protect information from loss, misuse, and unauthorized access. We take steps to help ensure that the data we possess is housed and transmitted securely. We use multiple types and layers of physical and electronic security, including firewall protections, encryption of data during transfer, and strict access controls to personal information. While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, and thus, VentiveIQ cannot guarantee the absolute security of your information. We make substantial efforts to ensure that this does not occur.
10. CHANGES TO THIS PRIVACY POLICY
Changes to this Privacy Policy will be posted on this page. If we make a material change to our privacy practices, we will provide notice on our Site or by other means as appropriate. If we are required by applicable data protection laws to obtain your consent to any material changes before they come into effect, then we will do so in accordance with law.
11 RIGHTS FOR CALIFORNIA CITIZENS
Under the CCPA, California residents have certain rights around VentiveIQ’s collection, use, and sharing of their personal information.
The below chart summarizes the categories of personal information we collect when we act as a “business” under the CCPA, where we collect it from, how we use it, and who we share it with. This chart is updated in an annual review and reflects the prior twelve (12) months from the date of last review.
| CATEGORIES COLLECTED | EXAMPLE DATA ELEMENTS | SOURCES WE COLLECT FROM | PURPOSES BEHIND COLLECTION, USE, AND SHARING | CATEGORIES OF THIRD PARTIES WE DISCLOSE TO |
|---|---|---|---|---|
| IDENTIFIERS | IP ADDRESS EMAIL ADDRESS NAME (FIRST AND LAST) MAILING ADDRESS UIDV2.0 PHONE NUMBER COOKIES, COOKIE IDS, AND OTHER SIMILAR ONLINE IDS= | YOUR DEVICE OUR PROVIDERS | ADVERTISING SERVICES ANALYTICS DATA MODELING LEGAL FRAUD OR DECEIT DETECTION | CUSTOMERS OUR PROVIDERS |
| DEMOGRAPHICS | AGE GENDER LANGUAGE EDUCATION EMPLOYMENT ETHNICITY HOMEOWNER HOUSEHOLD INCOME AND SIZE EMPLOYMENT RELATED INFORMATION INDUSTRY MARITAL STATUS PRESENCE AND NUMBER OF CHILDREN TIMEZONE | YOUR DEVICE OUR PROVIDERS | ADVERTISING SERVICES ANALYTICS DATA MODELING | CUSTOMERS OUR PROVIDERS |
| GEOLOCATION DATA | LATITUDE LONGITUDE TIMESTAMP COUNTRY CODE ADDRESS ALTITUDE SSID/WIFI ACCELEROMETER | YOUR DEVICE OUR PROVIDERS | ADVERTISING SERVICES ANALYTICS DATA MODELING | CUSTOMERS OUR PROVIDERS |
| DEVICE & SITE DATA | DEVICE CHARACTERISTICS APP INSTALL DATA SITE VISITATION DATA TIMESTAMP PRIVACY SIGNALS AMBIENT SIGNALS | YOUR DEVICE OUR PROVIDERS | ADVERTISING SERVICES ANALYTICS DATA MODELING | CUSTOMERS OUR PROVIDERS |
| COMMERCIAL INFORMATION | PURCHASE & TRANSACTION DATA | YOUR DEVICE OUR PROVIDERS | ADVERTISING SERVICES ANALYTICS DATA MODELING | CUSTOMERS OUR PROVIDERS |
Your Specific Rights Under the CCPA
The CCPA grants certain rights to residents of California regarding their personal information. If you are a natural person who resides in California (a “Consumer”), this section of the Privacy Policy applies to you. If you are not a Consumer, this section does not apply to you and you should not rely on it. These rights are not absolute and may be subject to exceptions and verification. VentiveIQ may be required or permitted by law to decline any request. Only you, a person that you authorize to act on your behalf, or an entity registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to accessing or deleting your personal information.
- A. Right to Access: You can make a request to access the categories or specific pieces of personal information VentiveIQ collected, used, or shared about you in the past twelve (12) months. Along with your verified request, we will give you any categories of sources from which the personal information is collected; the purpose for collecting, selling, or sharing; and any categories of third parties with whom we share such personal information.
- B. Right to Delete: You can make a request to delete any personal information VentiveIQ has collected from you. Upon receiving a verified request, VentiveIQ will notify you once your information has been deleted. We will also communicate your deletion request to our Customers and direct them to delete your personal information.
- C. How to Exercise your Access and Deletion Rights: There are two ways to submit a request to access or delete your personal information. First, you may submit a request at ACCESS OR DELETE MY DATA PAGE.To protect the privacy and security of your personal information, we will attempt to verify your identity before acting on your request. Your request must include details sufficient for us to properly understand, evaluate, and respond to the request. To verify your request to know or delete, we may need to request additional information from you, and, in certain circumstances, we may ask you to verify your identity and proof of California residency, which may include a signed declaration under penalty of perjury that you are the individual whose personal information is the subject of the request.
- D. Right to Opt-Out of Sale: California Consumers have the right to opt-out of “sales” of their personal information.The CCPA’s broad definition of “sale” may include using services to deliver targeted advertising on other sites or applications. This means that if you make a request to opt-out of VentiveIQ’s “sales” of personal information, it will likely have a direct impact on the types of advertisements you see online. VentiveIQ will honor requests to opt-out of “sales” of your personal information.There are two ways to submit a “request to opt-out of the sale” of your personal information. First, submit a request at DO NOT SELL MY PERSONAL INFORMATION PAGE. Second, you can submit your request through the email at [email protected]. In the subject line, include “CCPA Consumer Request,” and note in the body of the email that you would like to opt out of sale.
- E. Right to Non-Discrimination: VentiveIQ values giving consumers control over their privacy and personal information. If you choose to exercise any of your rights under the CCPA, we will not differentiate our services as a result of your decision. We also do not offer any financial incentives to opt-in to sell your personal information.
- F. Use of an Authorized Agent: You can appoint a person or a business entity registered with the Secretary of State to act on your behalf. In order to do so, you must provide the authorized agent with written permission to do so, and a power of attorney that fulfills the requirements of the CCPA. VentiveIQ may request more information from the authorized agent (or from you) if needed to verify the authorized agent’s identity or to avoid any breach of security or instances of fraud.
- G. Minors: We do not knowingly collect personal information of minors under the age of 16, nor are our Sites or Services developed for, offered to, or directed at children under the age of 16. If you believe that we have collected information of a child under the age of 16, please contact us and we will take appropriate action.
- H. VentiveIQ as a Service Provider: Sometimes we act as a “Service Provider” to other companies — for instance, when we help other businesses use their own customers’ information for marketing, analytics, or other services. As to personal information that we hold as a “Service Provider,” you would generally need to reach out to the business (our customer) to exercise your CCPA rights.
12. INFORMATION FOR NEVADA RESIDENTS
Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law). If you are a Nevada resident, you may submit a request to opt out of sales under Nevada law by filling out this “opt-out” form. Opting out will ensure that the provided information and associated information will not be shared or made available in our products and services. Please note we may take reasonable steps to verify your identity and the authenticity of the request.
13. INFORMATION FOR INTERNATIONAL RESIDENT
Individual Rights. Local laws in the EEA, the UK, Switzerland, and some other jurisdictions (such as Canada and Brazil) may permit you to:
- obtain confirmation of whether we hold personal information about them, and receive information about how it is used and disclosed;
- obtain a copy of the personal information, and in some cases, receive it in a structured, commonly used and machine-readable format, or have it be transmitted to a third party in such form;
- update, correct or delete the information;object to the use or disclosure of the information;
- withdraw consent previously provided for the handling of the information (without affecting the lawfulness of prior use and disclosure of the information); and
- obtain a restriction on the use of the information.
Individuals whose personal information is subject to the GDPR also have a right to “opt-out” of our handling of their personal information for direct marketing purposes.
Data Transfers. We are headquartered in the United States, and recipients of the data disclosures described in this Privacy Policy are located in the United States and elsewhere in the world, including where privacy laws may not provide as much protection as those of your country of residence. Per applicable law, we will ensure that transfers of personal information to such recipients are subject to appropriate safeguards.
14. Grounds of Processing
In technical legal terms we process personal data under the ground of “legitimate interest”. VentiveIQ’s legitimate business interest is the supply of commercial data (and the marketing of our business). The purpose of this processing is to enable businesses to manage their financial risks, protect against fraud, know who they are doing business with, meet compliance and regulatory obligations and better understand organisations, industries and markets.
15. Updates to this Privacy
We may update this Privacy Policy from time to time, such as to describe new types of data we collect or services that we offer. If you are interested in our data collection, use and sharing policies, we recommend that you check back to review these updates, as they occur.
Contact VentiveIQ
If you have any questions regarding our Privacy Policy or our privacy practices, or about VentiveIQ generally, you can contact us by any of the following methods:
Via regular mail at the following address:
VentiveIQ LLC.
103 carnegie center dr suite 300 Princeton NJ 08540
Or, Via email at [email protected].