Advertising Privacy Policy

Last Updated: July 1st, 2024

This policy explains how Altavara LLC. (“Altavara,” we” or “us”) collects, uses and discloses information about you when you interact with Digital Media Properties (defined below) that use our advertising technology platforms and related services to deliver you ads (collectively, the “Services”).

Please note:
This privacy policy does not govern (i) the collection and use of information about visitors to our website, https://www.altavara.co/, (ii) information collected in the course of our sales and marketing activities (iii) the collection, use and disclosure of information by our clients through their Digital Media Properties, which is governed by their own privacy policies and practices; or (iv) any activities where we act as a service provider to our clients rather than a data controller.

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ABOUT US

Altavara provides Services that connect buyers of advertising inventory (advertisers) with sellers of advertising inventory (publishers) (in other words, the opportunity to display a buyer’s advertisement on a seller’s Digital Media Property). In this policy, we refer to our buyers and sellers collectively as “clients”.

For example, advertisers use our technology to buy inventory to display advertising across publishers’ websites and applications on Internet-connected devices and platforms, including mobile devices, computers and internet-connected TVs (which we collectively refer to as “Digital Media Properties”).

When an advertiser serves an advertisement on a publisher’s Digital Media Property, the advertisement will be displayed to you in connection with the content that you view. For example, if you visit a video-streaming Digital Media Property and click on a video that you want to stream, then an advertisement may appear before the video is shown because the advertiser successfully purchased the opportunity to display.

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INFORMATION WE COLLECT

When you visit a Digital Media Property that uses our Services, we collect certain information about you and your device (collectively, “User Information”). User Information does not include information that directly identifies an individual, such as name, address, phone number, or email address. However that information may be considered “personal data” or “personal information” under applicable privacy or data protection laws.

In particular, we collect identifiers such as your IP addresses, cookie identifiers, and device identifiers, and may also assign identifiers to your device based upon these identifiers and other device-related information we collect as described below. These identifiers help us to recognize a particular browser, computer, mobile device, Internet-connected television or other device without knowing the identity of the user of that device. We also collect information about the web page URL or app in which you are viewing content and other data that the Client makes available to us, which helps us, our clients, and our partners (such as third party advertising platforms) select appropriate advertisements to display to you.

When you visit Digital Media Properties that use our technology, we collect the following information about you:

Usage Information: including information about the domain, topic or name of the property, the date/time of visits, the search terms you enter, visitor activities and actions, viewability data, the video title, video player size, description or category being displayed, click data, types of advertisements viewed
Log Information: including information about the type of browser you use, app version, access times, pages viewed, and the page you visited before navigating to the Digital Media Properties

Device Information: including information about the computer or mobile device you use, including, device make, device model, device operating system, device operating system version, and data connection type;
Location Information: We may derive the approximate location of your device from your IP address (geographic region or state). In accordance with your device permissions, we may also receive information about the precise location of your device but only if our clients pass it to us. Precise location may be deemed as sensitive personal information in some jurisdictions.
Internet service information: including information about which Internet Service Provider (ISP) you use;
Deidentified information: We may process certain other deidentified data that enables us to serve you with advertisements, such as encrypted or hashed forms of your email address if our clients pass these to us. In cases where we may de identify User Information, we commit to not re-identifying that information.
Derived information: We may also receive information from third parties at the instruction or for the benefit of our clients that provide user demographics and information with respect to a user’s preferences, patterns, click and video interactions, behaviors or interests, as well as advertisers and advertising platforms that provide information to us in order to match an ad opportunity offered by our clients with the right advertisement.
Altavara and our clients may collect and store inferences about user activity using our Services.

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HOW WE COLLECT USER INFORMATION

We (and our service providers) use different technologies (collectively “Tracking Technologies”) to collect information, including cookies and other similar technologies to collect information automatically from your device when you visit with a Digital Media Property that uses our technology.

Tracking Technologies help to match client’s advertising opportunities with the right advertisements. To do so, we may perform cookie syncing between publisher client cookies, Altavara cookies, third party data provider cookies and/or advertiser client cookies. This cookie synching process allows the parties to map their respective cookie information (for example, if publisher A sets a cookie on a user’s device with an ID 12345 and advertiser B sets a cookie on the same user’s device with an ID 67890, cookie synching would enable publisher A and advertiser B to recognize that ID 12345 and ID 67890 relate to the same user’s device). In the case of advertisers, the cookie sync may influence its decision to bid on advertising opportunities, because it may recognize that the cookie ID sent to it as an opportunity to bid on relates to a user they already know (perhaps because they already targeted advertising to the user when they previously visited a Digital Media Properties in the past).

We also use Tracking Technologies for frequency capping, i.e., to ensure that the same user is not served the same advertisement repeatedly, to assist with the delivery of ads, provide reporting to our Clients, and to understand and measure the user’s interactions with ads and their effectiveness.

Services provided by others: We also work with third-party for analytics and advertising services that separately collect and use User Information to enable our Clients and their customers to deliver targeted advertisements using our advertising technology. As an example, we work with third-party advertising companies that use information about your visits to various websites or applications across multiple devices in order to provide you with content and ads of interest across devices that they think are associated with you or your household, including web browsers, mobile apps, and internet-connected televisions. We, and our advertiser clients may use this third-party data in combination with the User Information we collect to deliver you targeted ads across multiple devices or our publisher clients may use this third-party data in combination with the User Information we collect to offer groupings of audiences, commonly known as audience segments, on the Digital Media Properties as advertising opportunities.

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USE OF USER INFORMATION

We and our clients use User Information in order to inform their decisions regarding buying and selling advertising space on Digital Media Properties. In particular, we and our clients use information we collect, in conjunction with other information they have independently collected or received from third-party advertising platforms, to deliver end users targeted advertising that our clients believe will be of particular interest to those users. This processing may constitute “targeted advertising” under some laws and the “sale” or “sharing” of personal information under other laws. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work .

We also use the User Information we collect for the following purposes:

To enable our clients to offer and buy advertising opportunities on Digital Media Properties;
To operate and improve our technology;
To compile statistics and conduct research and development for our internal business purposes;
To prepare reports of visitor activity;
To enable standard advertising controls;
To analyze and report on ad performance (such as tracking views of ad, ad fill rates, as well as click-through rates on ads), campaign reporting, and campaign forecasting;
To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.

To deliver end users targeted advertising;
To create profiles of end users for targeted advertising;
To create audience segments as advertising opportunities

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DISCLOSURE OF USER INFORMATION

We disclose User Information that we collect as follows:

Clients: We disclose User Information with our advertiser clients to help them identify and buy advertising on publishers’ Digital Media Properties. Advertisers may use this information in conjunction with other information they have independently collected to provide you targeted advertising and to help them evaluate whether a particular ad campaign may be of interest to you.
Business Transfers: We may disclose User Information in connection with an actual or proposed sale or transfer of all or a part of our business or assets, corporate merger, consolidation, or bankruptcy.
Vital interest, legal rights and compliance with laws. We may disclose User Information with law enforcement, regulatory authorities, courts with competent jurisdictions, emergency services or other necessary third parties for legal, protection, security, and safety purposes, including:some text
- to comply with laws or regulatory requirements and to respond to lawful requests and legal process;
- to protect the rights and property of Altavara, our affiliates, agents, customers, and others, including enforcing our agreements, policies, and terms of use and protecting our network and physical assets; and/or
- to protect the safety of our employees and agents, our customers, or any person.
Vendors, and other service providers: We may disclose User Information with our vendors, and service providers who perform functions on our or our clients’ behalf and require access to such information to provide us with services or do work for us. Examples include: analyzing data, reporting, fraud prevention, hosting or providing data, auditing, engaging technical support for our technology platform, and performing analysis related to our technology platform and related services.
Partners: We may disclose User Information with partners, including third party advertising platforms. These partners use the information we provide to provide services to us and our clients, and may use the data for their own purposes.

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Information Our Clients and Vendors Collect

Our clients, our vendors, and our clients’ vendors who use our technology may use their own tags, pixels, cookies, or other similar technology (or those of their other affiliates) within advertisements and on certain Digital Media Properties. We are not responsible for our clients’, vendors’ and/or our clients’ vendors’ use of such tracking technologies or for their privacy practices.

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YOUR PRIVACY RIGHTS AND CHOICES

Opt-Out

Depending upon where you live, certain activities described in the sections above may constitute “sharing” “selling” or processing of User Information for purposes of “targeted advertising” as such terms are defined under certain privacy laws. You may opt out of these activities, as well as certain processing of sensitive personal information we may undertake by following the instructions by emailing us at [email protected].

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Access, Correction, Deletion

In addition, depending on where you reside and other legal limitations, you may have the right to (1) request to know more about and access the categories and specific pieces of personal information we collect, use, and disclose, (2) request deletion or restriction of your personal information, (3) request correction of inaccurate personal information, (4) obtain your User Information in a portable format.

If you would like to exercise any of these rights, please email us at [email protected] for instructions on how to do so.

We will not discriminate against you for exercising your privacy rights. Note that when you exercise your rights, we may ask for additional information to verify your request. If we deny your request, you may have the right to appeal our decision. If you have concerns about the results of an appeal, you may contact the attorney general in the state where you reside.

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Information Retention

We store the User Information we collect for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

We typically store the User Information we collect from your device, such as IP address and other information described above, in our systems for up to 90 days before we anonymize and aggregate that data into summary reports.

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SECURITY

We use industry-standard technical and organizational security measures to help protect information transmitted over or stored on our systems. Please note, however, that no transmission or storage of information can ever be guaranteed to be completely secure, though we do take all reasonable precautions to protect against security incidents.

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Additional Information for California Residents

If you are a resident of California, please review the additional privacy disclosures in this section, which apply where we collect and disclose information as a “business” under California law. These disclosures do not apply to the extent we act as a service provider to our clients. In such cases, you must visit the privacy policies of our clients to understand how data is processed about you and to exercise your rights.

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Information About Our Data Processing

California law requires us to disclose the categories of personal information we collect and how we use them, the categories of sources from which we collect personal information, and the third parties to which we disclose personal information. We collect personal information from the sources described in the “Information we Collect” section above.

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Do Not Sell or Share My Personal Information & Limit Use of Sensitive Information

Altavara’s disclosure of User Information, may sometimes constitute a “sale” or “sharing” under California law or the use of sensitive information for purposes that require offering consumers the ability to limit our use of such information, and our clients may use our technology for these purposes as well. You may opt out of the “sale”, and “sharing”, of your personal information as well as the use of sensitive information for advertising purposes by emailing us at [email protected]. Note that because these opt outs are specific to the device or browser on which they are exercised, you will need to opt out on each browser and device.

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Your Rights

Under California law, you have the right to access, correct, and request deletion of your data. To exercise these rights, please see the Your Privacy Rights & Choices section above.

Additional Information for EEA, UK, and Switzerland End Users

If you are an end user located in the EEA, the UK, or Switzerland, please read these additional disclosures below.

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Your Rights
You have the right to access, correct, and request deletion of your personal data and to object to certain processing, including profiling. You also have the right to receive personal data concerning yourself in a machine readable format. If you would like to exercise your rights, please email us at [email protected].

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Legal Basis for Processing
Our legal basis for collecting and using the User Information described above will depend on the User Information concerned and the specific context in which we collect it.

In all situations where you have been specifically asked by our partners or by us for your consent prior to processing, we may rely on that consent until you withdraw it. If we rely on consent to collect and/or process your User Information, we will obtain such consent in accordance with applicable law. In some cases, we need to process your User Information because we have a legal obligation to do so.

In some cases we may need to process your User Information because we are required to do so by law.

In all other cases we may rely on our legitimate interests to collect User Information from you, except where such interests are overridden by your data-protection interests or fundamental rights and freedoms. Where we rely on our legitimate interests to process your User Information, they include the interests described in the section headed “How We Use User Information .”

If you have questions about or need further information concerning the legal basis on which we collect and use your User Information, please contact us using the contact details provided under the “Contact Us” heading below.

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Right to Lodge a Complaint
You have the right to lodge a complaint about our processing of personal data with a European Data Protection Authority. For contact details of EU data protection authorities, please see here:‍ https://edpb.europa.eu/about-edpb/about-edpb/members_en. The Swiss data protection authority can be contacted at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html. The UK data protection authority can be contacted at https://ico.org.uk

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CHANGES TO THIS POLICY

We may update this policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. If we make material changes to this policy, we will notify you of any material changes by posting the revised policy on this website, and where necessary, by any other means required by applicable law.

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CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact Altavara by email at [email protected] or by post using the details provided below:

Altavara LLC.
Attn: Privacy Team
33 Irving Place, New York, NY 10003

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