Non-Personally Identifiable Information Privacy Policy | Retargeting | Chango

Privacy Policy

Last Updated 8/10/2015

The Rubicon Project Chango, Inc. (“Chango”) is committed to transparency, and we want you to fully understand how we may collect, use, and share data relating to you, and the choices that are available to you. This privacy policy governs Chango’s collection and use of data on websites that use our technology to purchase and deliver ads, and to the collection and use of data on Chango’s website.

Data We Collect
Using our Advertising Technology

When you visit a website that displays an ad using our technology, we do not collect any information that identifies you. Instead, we may collect certain non-personally identifiable information about you and your device (“User Data”). Some of this User Data, including for example your IP addresses and certain unique device identifiers, may identify a particular computer or device, and may be considered “personal data” in some jurisdictions in the European Union and elsewhere, but none of this data identifies you individually.

User Data that we may collect includes: IP address, domain, browser type and language, referring website addresses, date/time of visits, page view data, search keywords, visitor activities and actions on publisher’s sites, browser history, Internet service provider, referring/exit pages, platform type, date/time stamp, geolocation (including city, country, and zip code), click data, types of advertisements viewed, and information about visitor’s device including device make, device model, device operating system, device operating system version, and data connection type. To be clear, we do not collect any “sensitive personal data” as defined in the European Union.

We collect User Data using the following standard web technologies:

  • “Tags and Pixels” are blocks of code that we and our customers may use to track your navigation of websites or apps using our technology, and your browsing behavior. We use pixels to coordinate User Data with our customers and other third parties.
  • “Cookies” are data files that often include an anonymous unique identifier, and are placed on a visitor’s device or computer. We use cookies on our customers’ websites in order to operate our technology and collect User Data. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
  • We work with Tapad, Inc., a technology company that may use information about your visits to various websites or applications across multiple devices in order to provide you with content of interest to you across those devices. To learn more about Tapad, Inc., and how to opt out of their cross-device technology on your desktop or mobile devices, please visit their privacy policy at http://www.tapad.com/privacy-policy/.

We additionally obtain User Data from various vendors and third parties that have collected that data independently. This privacy policy does not cover the collection of User Data by such third parties, but does cover our usage of such data.

On our Website

When you visit our website, you may optionally choose to sign-up on our Web forms and provide us with personally identifiable information you knowingly choose to disclose that is collected on an individual basis. Additionally, we collect certain non-personally identifiable information about how you use our website. Together, we refer to this data as “Website Data.”

PERSONALLY IDENTIFIABLE INFORMATION (“PII”)

When requesting market reports or requesting additional information or contact from RChango, our customers may be asked to provide the following: Name, Company Name, Mailing Address, Email Address, Phone Number, Basic Site Information (URL, Channel, Impression Traffic), Username, Tax I.D. Number and Password. In addition, if you choose to correspond with us through email or blog postings, we may retain the content of your email messages together with your email address and our responses.

NON-PERSONALLY IDENTIFIABLE INFORMATION (“NON-PII”)

Similar to other commercial websites, we collect information about how our website is used. Some of this information, including for example your IP addresses and certain unique device identifiers, may identify a particular computer or device, and may be considered “personal data” in some jurisdictions in the European Union and elsewhere even though it does not identify you individually. Non-PII collected may include the following: IP address, domain, browser type and language, referring website addresses, date/time of visits, page view data, and search keywords. We collect this data using Cookies and Web Beacons, which are discussed in more detail above.

How We Use Data

We use User Data and Website Data to deliver consumers more relevant advertising, including by helping our customers conduct Online Behavioral Advertising (OBA), which delivers you targeted advertising based on information that we believe will be of particular interest to you. For more information about how OBA works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

Our other uses of User Data and Website Data may include, for example, to:

  • Operate and improve our technology;
  • Conduct research and development;
  • Create profiles and infer demographic and interest-based information about consumers, and to place each user into interest-based segments that are targetable in our ad platform;
  • Enable standard advertising controls;
  • Prepare reports that summarize visitor activity;
  • Report on ad performance, campaign reporting, and campaign forecasting;
  • Determine non-personally identified user response to advertisements and promotions; and
  • Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
Data Retention

We may store User Data for up to 30 days. After that period, User Data may be anonymized and aggregated into summary reports that may be stored for longer than 30 days.

Sharing of Data

We may share User Data and Website Data with others, including advertisers, and website and app publishers for a variety of reasons. For example:

  • We may share User Data or Website Data with our customers to help them deliver target advertisements to you;
  • We may share User Data or Website Data for the purposes of a business deal (or negotiation of a business deal) involving sale or transfer of all or a part of our business or assets. Business deals may include any merger, financing, acquisition, or bankruptcy transaction or proceeding;
  • We may share User Data or Website Data for legal, protection, security, and safety purposes, including:
    • To comply with laws or regulatory requirements and to respond to lawful requests and legal process;
    • To protect the rights and property of Chango, our agents, customers, and others, including enforcing our agreements, policies, and terms of use and protecting our network and physical assets; and/or
    • In an emergency, including protecting the safety of our employees and agents, our customers, or any person.
  • We may share information with parties who may use that information to provide us with services or do work for us.
Your Choices

There are many ways to opt-out of OBA we may conduct using our technology. If you opt-out of OBA, we will continue to collect the same User Data and Website Data described above. However, this information won’t be used to target you with interested based ads.

First, you can visit our opt-out page, at http://www.chango.com/privacy/opt-out/. Second, because we are a member of the Network Advertising Initiative (“NAI”) and adhere to the NAI’s code of conduct, you can opt-out of OBA by participating companies, including Chango, at http://www.networkadvertising.org/choices/. Third, because we adhere to the Digital Advertising Alliance’s Self-Regulatory Principles, you can visit the Digital Advertising Alliance’s opt-out page at http://www.aboutads.info/choices/.

Please note that these opt-outs operate by placing a cookie on your device that is unique to the browser and device you use to opt-out. If you change browsers or computers, or delete the cookies on your computer, you will need to opt-out again. You also can set your browser to notify you when a cookie is being set and to block most cookies, including ours.

Security

We use many different measures to help protect information transmitted over or stored on our systems. No transmission of information, however, is guaranteed to be completely secure. In particular, we cannot guarantee that your data will not be disclosed, altered, or accessed accidentally, or through unlawful or unauthorized acts of others.

Changes

We reserve the right to modify this privacy policy at any time. If we make material changes to this policy, we will notify you here or by means of a notice on our home page.

U.S.-E.U. Safe Harbor

Chango’s parent entity, The Rubicon Project, Inc. (“Rubicon Project”) is a participant in the U.S.-E.U. Safe Harbor, and in this regard, we may transfer certain personal data about you to or from Rubicon Project in compliance with the Safe Harbor Privacy Principles. For more information about the U.S.-E.U. Safe Harbor, please visit http://export.gov/safeharbor/.

In accordance with the Safe Harbor Privacy Principles, Rubicon Project has designated JAMS, Inc. as its independent recourse mechanism to mediate any disputes or compliance regarding compliance with the Safe Harbor. Such mediation will be governed by the JAMS International Mediation Rules. To submit a complaint to JAMS for mediation, please visit http://www.jamsadr.com/file-safe-harbor-claim/.

Contact Us

For more information, if you have questions, or if you would like to make a complaint, please contact us at:

Chango
c/o Rubicon Project
Attn: Privacy Officer, Legal Department
12181 Bluff Creek Drive, 4th Floor
Playa Vista, CA 90094
Phone: 310.207.0272
Contact us by e-mail at privacy@rubiconproject.com