Last modified on December 29, 2023 (previous versions)
This Services Privacy Notice (this “Notice”) describes how Lotame receives, handles, and processes your Personal Data on behalf of our Business Customers and Data Partners. We receive Personal Data from our Business Customers in connection with their use of our Services and from Data Partners, which we license to Business Customers.
Lotame does not generally interact directly with individuals like you unless you are interested in using our Services, are an employee of a Business Customer, Data Partner, or Service Provider, applying for employment with Lotame, are an employee of Lotame, or interact with Lotame for other internal business operations. This Notice does not cover any Personal Data we collect or process through our corporate website or for the reason specified in the previous sentence, which is covered by our Corporate Privacy Policy.
In the sections below we describe:
Lotame operates a platform (“Spherical Platform”) that provides technology, services, and tools to provide audience management, identity, and data monetization services (our “Services”) to our Business Customers (and their customers) and Data Partners.
The table below lists the categories of Personal Data that Lotame collects in the course of operating the Spherical Platform and providing our Services, and the sources from which we obtain that Personal Data. Please refer to Section 4 for details about the purposes for which we collect Personal Data.
Lotame Personal Data Categories | Sources |
---|---|
Pseudonymous IDs | Business Customers, Data Partners, and Graphing Partners |
Declared IDs | Business Customers, Data Partners, and Graphing Partners |
Behaviors | Business Customers and Data Partners |
Internet Log Data | Business Customers and Data Partners |
Event Data | Business Customers and Data Partners |
Non-Precise Geolocation Data | Business Customers and Data Partners |
How We Collect Personal Data
We collect Personal Data for or from our Business Customers and Data Partners using the following methods:
For web-based Digital Properties, we use Cookies in conjunction with Tags and Pixels to store certain information necessary to provide our Services. These Cookies contain our Cookie ID and other information that does not identify you or allow you to be identified without additional information. Our use of Cookies on the Digital Properties of our Business Customers and Data Partners is governed by their cookie or privacy policy, notice, or statement.
Please visit Cookies & You to learn more about cookies and hot to control and disable the cookies you don’t want.
Collection of Sensitive Personal Data
Lotame does not knowingly collect or process Sensitive Personal Data and contractually prohibits its Business Customers and Data Partners from providing Lotame with any Sensitive Personal Data.
Collection of Personal Data of Minors
Lotame does not knowingly collect Personal Data of minors under 16 years of age (18 in India). Lotame contractually prohibits its Business Customers and Data Partners from providing Lotame with any Personal Data of minors under 16 years of age (18 in India).
Lotame sells or discloses Personal Data to or shares Personal Data with the following categories of third parties. Please refer to Section 4 for details about the purposes for which we sell, disclose, or share Personal Data with third parties.
Lotame Personal Data Categories | Third Parties |
---|---|
Pseudonymous IDs | AdTech Platforms, MarTech Platforms, Business Customers, Data Partners, Graphing Partners, and Service Providers‡ |
Pseudonymous IDs | AdTech Platforms, MarTech Platforms, Business Customers, Data Partners, Graphing Partners, and Service Providers‡ |
Behaviors | Business Customers and Service Providers‡ |
Internet Log Data | Service Providers‡ |
Event Data | Business Customers, Graphing Partners, and Service Providers‡ |
Non-Precise Geolocation Data | Business Customers, Data Partners, and Service Providers‡ |
We collect, sell, share, and disclose your Personal Data to deliver our Services. The purposes for which we collect, use, sell, or share Personal Data depends on, among other things, our relationship or interaction with our Business Customers, Data Partners, AdTech Platforms, and MarTech Platforms to which we sell or share Personal Data. The table below lists and describes the purposes for which we collect, use, sell, or share Personal Data.
Purpose | Explanation |
---|---|
Audience Analytics | Discovery, segmentation, and optimization of Audiences to understand and develop insights about customers and visitors to/users of Digital Properties to increase reach for Tailored Advertising and improve Content Personalization. |
Audience Creation | Creation of Audiences using Business Customer Data and Third Party Data, including Modeled Audiences. |
Campaign Analytics | Measuring and reporting on how advertisements and content was delivered and interacted with by individuals to understand the individual’s path to conversion and facilitate smarter marketing spend decisions. |
Content Personalization | Tailoring and delivery of content based on an individual’s profile or preferences. |
Cross-ID/Device Linking | Determining probabilistically, and in certain cases, deterministically that two or more Pseudonymous IDs, Declared IDs, or Devices belong to the same individual or household. |
Profile Creation | The creation or editing of a personalized advertising and content profile by combining it with Behaviors previously collected, including from across unaffiliated Digital Properties and Devices, for use by third parties (such as our Business Customers) in Tailored Advertising and Content Personalization. |
Tailored Advertising | See Tailored Advertising on our Definitions page for further information about Lotame’s role in Tailored Advertising. Lotame itself does not engage in Tailored Advertising or Content Personalization. |
We also may share any of the Personal Data we collect as follows:
Sharing With Service Providers: We share your Personal Data with our Service Providers so that we can provide our Services to our Business Customers. Our Service Providers process the Personal Data we share with them on our behalf and in accordance with our instructions. Service Providers are contractually prohibited from using the Personal Data we provide to them for purposes outside of our instruction or contract.
Sharing for Legal Purposes: We may share Personal Data with third parties in order to: (a) comply with legal processes or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our agreements; and (c) respond to claims that any content violates the rights of third parties.
Sharing In Event of a Corporate Transaction: We may also share Personal Data in the event of a corporate transaction, for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.
The retention periods for your Personal Data that we process varies based on the type of Personal Data and who provided your Personal Data to us. As such, we are unable to list a precise retention period in this Notice. However, in general, the retention periods for your Personal Data are specified in the table below.
Lotame Personal Data Type | |
---|---|
Pseudonymous ID | 90 days after the Pseudonymous ID is no longer associated with any Behaviors or Event Data. |
Declared IDs | 13 months measured from the time the Declared ID was last received. |
Behaviors Campaign Data Non-Precise Geolocation Data | Configurable by Business Customer: default is 9 months, maximum can be set to 13 months. When provided by a Data Partner: 9 months. Retention period is measured from the time the Behavior/Campaign Data/Non-Precise Geolocation was last received. |
Event Data | No longer than 12 weeks. Retention period is measured from the time the Event Data was received. |
Internet Log Data | No longer than 2 weeks. |
You may have the right to obtain access, rectification, erasure, restriction of Personal Data, portability of Personal Data and to object to the processing of Personal Data (“Privacy Rights”) under Data Protection and Privacy Laws in various countries and jurisdictions. You can make a request to exercise your Privacy Rights by submitting your request using our Privacy Manager, by using the alternative methods identified below, or by contacting us at [email protected]. Due to the nature of the Personal Data we process and the need to verify certain types of Privacy Rights requests, using email is not the best method to submit your Privacy Rights request. Using the alternative methods identified below are the easiest ways to exercise your Privacy Rights and using our Privacy Manager instead of email is the best way to submit your request.
If you are not a resident of a country or local jurisdiction that currently has an effective Data Protection and Privacy Law that offers you Privacy Rights, you may submit a request and we may process it as described in our Privacy Manager even though no Data Protection and Privacy Law requires us to do so. However, we reserve the right to change or stop the practice of accepting requests from individuals who are not resident of a country or local jurisdiction that does not have a Data Protection and Privacy Law in effect that provides for Privacy Rights.
Alternative Methods to Exercise Your Rights
Browser Opt-Outs
In the United States, you can use the Digital Advertising Alliance’s WebChoices Tool or the Network Advertising Initiative’s (NAI) Browser Opt-Out Tool.
In Europe, you can use the opt-out tool available at the European Interactive Digital Advertising Alliance’s Your Online Choices.
In Canada, you can use the tools available at Digital Advertising Alliance of Canada’s AdChoices.
If you would like to opt-out of the collection or use of your Personal Data with respect to non-cookie IDs, for example, a mobile advertising ID or a connected TV ID, you can use the procedures described below.
Mobile Applications Opt-Out
To opt-out of the collection and use of Personal Data for interest-based advertising on your mobile device, you can modify the settings on your mobile device. Please note that the specific opt-out instructions for each device may differ depending on which version of the operating system software you are running. Instructions on how to opt-out from many mobile operating systems are available at the NAI’s Learn About Mobile Device Opt-Outs.
Alternatively, you may wish to download the TrustE mobile application or the Digital Advertising Alliance “AppChoices” mobile application and follow the instructions provided. You may opt-out of the collection and use of data by Lotame specifically, or by all companies that offer a mobile application opt-out via the TrustE or AppChoices app. Your opt-out choice is applied only to the collection of data from applications on the device from which you opt-out.
Television Opt-Out
Lotame licenses television viewership data from third parties that offer smart TVs and video streaming devices. Instructions on how to opt-out from many popular smart TVs and video streaming devices are available at the NAI’s Learn About Internet Connected TV Choices.
Certain countries or local jurisdictions have requirements for us to provide you with information specific to that country or local jurisdiction. Additionally, your Privacy Rights may vary within these areas based on the Data Protection and Privacy Laws in effect. Where required, we maintain the following privacy notice supplements for those countries and or local jurisdictions.
You can contact us via email at [email protected] or regular mail to the address below:
Lotame Solutions, Inc.
c/o Privacy Team
8890 McGaw Road, Suite 250
Columbia, MD 21045