Services Privacy Notice

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:

1. Our Services – the services we offer and to whom we provide those services.
2. Our Collection of Personal Data – the types of Personal Data that we collect, the types of sources we collect it from, and how we collect Personal Data.
3. Our Sale, Sharing, and Disclosure of Personal Data – the types of recipients to whom we may disclose, share, or sell your Personal Data.
4. Our Purposes for Collecting, Selling, Sharing, and Disclosure of Personal Data – our business purposes for processing your Personal Data.
5. Retention Periods for Personal Data – for what periods of time we retain your Personal Data.
6. Your Privacy Rights and Choices – what rights you have under Data Protection and Privacy Laws, for instance, to request that we not sell or share your Personal Data, and how to exercise your right to opt out of sale or sharing, right to request access or correction, and right to request deletion.
7. Country-Specific Privacy Notice Supplements – additional information that is specific to the country in which you reside.
8. Contact Us – how you may contact us.

1. Our Services

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.

• Our Audience Management Services facilitate the delivery of personalized marketing, advertisements, and content to you by Publishers and Advertisers.
  • Publishers and other operators of Digital Properties that have space to show an ad want those ads to be relevant to their readers, which helps them to offer content to you for no cost or lower cost. Advertisers, advertising agencies, and others that want to show an advertisement want to use their advertising dollars efficiently by reaching the right individuals, and by measuring the effectiveness of their ad campaigns. To accomplish those goals, our Business Customers use our Services to recognize and organize their customers or visitors to their Digital Properties, and to help them personalize advertisements and content to their customers or visitors, such as through website and email personalization or dynamic marketing and advertising optimization.
  • Our Services are also used for the analytics and measurement of advertising campaign performance of our Business Customers. For example, our Services can help analyze how many ads were viewed and clicked, and if the consumer purchased any of the advertiser’s products.

• Our Identity Services enables our Business Customers to connect an individual’s preferences across the various browsers and Devices. Our Identity solutions allow our Business Customers to display targeted advertisements and other personalized content of interest to you no matter what Device you use.
• Our Data Monetization Services enables our Business Customers and Data Partners to extract value from the Personal Data they collect about you.
  • The Lotame Data Exchange is one of the world’s largest marketplaces for third-party data and the standard for premium quality data at flexible and fair pricing, and scale that is unmatched in the industry. This data is cultivated from industry leading branded and unbranded Data Partners giving our Business Customers access to over a billion profiles across 30,000 Behavior categories that can be leveraged for Tailored Advertising, site optimization, custom segmentation and more to deliver the most relevant experiences to individuals at every touch point.
  • Lotame Collaborate is a service that allows our Business Customers to sell or share Audiences created using their First Party Data with other companies on other AdTech Platforms.

• Some of Lotame’s Services can be enabled through AdTech Platforms and MarTech Platforms that offer online marketplaces for on-demand web applications that run on or are offered through that platform (for example, Adobe Connections Manager). In cases where our Services are provided through such platforms, this Notice applies; however, those platforms may also collect Personal Data from you, in which case the privacy policy, notice, or statement of those platforms will apply.

2. Our Collection of Personal Data

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.

How We Collect Personal Data

We collect Personal Data for or from our Business Customers and Data Partners using the following methods:

• Tags and Pixels
• Software Development Kit
• Server-Side Data Transfer
• Application Programming Interface

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).

3. Our Sale, Sharing, or Disclosure of Personal Data

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.

4. Our Purposes for Collecting, Selling, Sharing, and Disclosure of Personal Data

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.

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.

5. Retention Periods for Personal Data

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.

6. Your Privacy Rights and Choices

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 privacy@lotame.com. 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.

7. Country-Specific Privacy Notice Supplements

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.

• GDPR Countries
• The United Kingdom Privacy Notice Supplement
• U.S. Privacy Notice Supplement

8. Contact Us

You can contact us via email at privacy@lotame.com or regular mail to the address below:

Lotame Solutions, Inc.
c/o Privacy Team
8890 McGaw Road, Suite 250
Columbia, MD 21045