Last Updated: September 12, 2014
Effective Date: October 12, 2014
Lotame operates two principal business lines that are discussed in this policy:
(1) Data Management Platform: Lotame licenses its Data Management Platform software to online publishers, marketers, agencies and other companies for their use in collecting, organizing and activating data for their marketing purposes.
(2) Lotame Data Solutions: Lotame aggregates and licenses non-personal data segments to our clients and other third parties, through the Lotame Data Solutions division.
Participation in Industry Self-Regulation: Lotame adheres to both the DAA Self-Regulatory Principles and the EDAA’s European Principles for Online Behavioral Advertising. Lotame is also a member of the NAI and adheres to the NAI Code of Conduct. Please visit our Memberships, Affiliations and Oversight page to learn more about Lotame’s participation in the EDAA, DAA, NAI and other self-regulatory organizations.
Data Our Clients Collect through the Lotame Data Management Platform (“DMP”): Our technology platform, the Lotame DMP, enables our client companies to deliver more relevant advertising and content to consumers across digital channels, including desktop and mobile channels, by gathering data about your visits to, and use of, their digital properties. Lotame DMP is licensed to our customers (i.e., website publishers and marketers) for their own purposes. These customers have their own policies that govern how they collect, use, and share data, which may differ from Lotame’s own data collection, usage, and sharing policies for the Lotame Data Solutions described below. Please consult the privacy policies of the websites you visit and apps you use to become familiar with their privacy practices.
To learn about and exercise any choices that may be offered by individual Lotame clients so that you may opt-out of their data collection through the DMP, you can consult the privacy policies of these Lotame clients. Alternatively, if you would like to opt-out across all DMP clients, you can follow the instructions below in the section on “Your Choices.”
Other than the “Your Choices” section, the remainder of this policy discusses Lotame’s practices for our Data Solutions and our corporate website.
Data Lotame Collects:
Data Collected and Used Through Lotame Data Solutions: To deliver our Data Solutions services, we collect, organize, and use non-personal information reflecting your interactions with a variety of websites and applications. This information includes, for example, items such as the date and time of visits to a website, browser information, IP address, browsing behavior, mobile device identifiers, information about use of mobile applications, and the geographic location of a device. We may also collect, organize, and use other non-personal information you voluntarily provide, such as your age and gender. We may also supplement the information we collect with additional non-personal or de-identified information we obtain from other companies. We analyze this non-personal information and organize it into user groups and audiences, based on factors such as age, gender, geography, interests and online actions. We and our partners then use these user groups and audiences, along with information about the possible relationships among different browsers and devices, to design and deliver customized advertising campaigns or other relevant content. This is called Interest-Based Advertising. We also use this data for other related purposes (for example, to do research regarding the results of online advertising campaigns or to better understand the interests or activities of website visitors). To enable these services, Lotame uses technology including browser cookies, device identifiers, and other similar technologies to recognize a particular browser or device over time, to predict possible relationships among different browsers and devices and to then relay this information to our servers when you visit websites and applications that are affiliated with our partners or clients.
The behavioral categories we use to customize the ads you may see or for related purposes do not include personal information such as your name, address, e-mail address, birth date or social security number.
Lotame does not create or share audience segments through Lotame Data Solutions that are classified by the Network Advertising Initiative (“NAI”) as Sensitive Information (as defined in the NAI Code of Conduct). To learn about the non-sensitive health-related segments we offer through Lotame Data Solutions, click here.
Data Collected through the Lotame.com Website: Lotame collects non-personally identifiable usage data via cookies and similar technology at lotamecorp.wpengine.com, which we use to improve our website and services. Lotame receives personally identifiable information, such as names and personal contact information, only when you choose to submit this information to us. If you would like to update, delete, or revise any personal information you submitted to us through lotame.com, please send your request to firstname.lastname@example.org.
Your Choices: We provide you with the ability to opt-out of the collection and use of your information for Interest-Based Advertising through the Lotame DMP and Lotame Data Solutions. To opt-out of the collection and use of data for Interest-Based Advertising on your browser (including a mobile browser if third-party cookies are enabled in your browser), you can click here and follow the instructions provided. Your opt-out choice is applied only to the browser from which you make the choice.
Even after you opt-out of the use of your information for Interest-Based Advertising through the Lotame DMP and Lotame Data Solutions, Lotame (and our clients using the DMP) may continue to collect and use such information for other purposes including analytics and research. Should you elect to opt-out, you will still receive ads, but these ads may be less relevant to your interests.
In addition to Lotame’s opt-out above:
● You can opt-out of the collection of data across unaffiliated sites over time for Interest-Based Advertising and other purposes from companies participating in the Digital Advertising Alliance Consumer Choice Page at www.aboutads.info/choices and from members of the Network Advertising Initiative via www.networkadvertising.org/choices.
● For those in Europe, you can opt-out via the IAB Europe’s industry opt-out at www.youronlinechoices.eu.
● You may be able to set “ad limit tracking” on various iOS devices, please click here to learn more.
● You may be able to opt-out of interest-based ads on Android via your device settings: open your Google Settings app > Ads > Enable “Opt-out of interest-based advertising”.
Note that after choosing to opt-out via any of the methods above, if you use a different device or a different browser, or if you delete browser cookies, you may need to repeat the opt-out steps for that particular device or browser. In addition, if you block cookies on your browser or if third-party cookies are blocked by default, the opt-out tools above may not function.
We also provide you with the ability to view and remove some of the information in our systems associated with your desktop browser. Through use of the Lotame Data Solutions Preferences Manager, you may be able to remove certain segments associated with your browser in order to influence the ads Lotame displays. You can access Lotame’s Data Solutions Preference Manager by clicking here.
Lotame’s Data Sharing and Onward Transfer:
This section describes how Lotame shares the data we collect through the Lotame Data Solutions business or the lotame.com website.
For European Union Residents: Lotame transfers data identified with residents of the European Union to unrelated third parties in accordance with the Safe Harbor Privacy Framework. Lotame complies with the US-EU Safe Harbor Framework, as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Lotame has certified that it adheres to the Safe Harbor Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Lotame’s certification, please visit http://www.export.gov/safeharbor/.
Sharing of Non-Personal Information: When you visit a website or mobile application that shares non-personal information about your activity with Lotame Data Solutions, we will use that information to help our clients to deliver more relevant advertising to you at the websites and mobile applications you visit, and for other purposes including research and analysis. We may also share the non-personal information we collect through our Data Solutions services and the lotame.com website with other companies such as advertisers, agencies, ad networks, or exchanges to enable them to analyze user behaviors or to customize the ads that you encounter.
Other Information Sharing: There are other circumstances in which we may share data collected through Lotame Data Solutions or on the lotame.com website, including personally identifiable information. We may provide access to the information we collect to service providers who may utilize the information only to provide their services to us. If our company is sold, assigned, transferred, merged, files for bankruptcy protection, sells all or a portion of its assets, or undergoes some other change to its corporate form, information may be transferred as part of that transaction or change. We may also release information in order to comply with requests from law enforcement, government agencies, and similar entities, or to otherwise protect Lotame, our clients and users.
Data Retention: Lotame retains the non-personal user data we collect through Data Solutions for purposes of Interest-Based Advertising for up to nine (9) months from the date of its collection.
Security: Lotame has implemented security measures which are reasonably designed to help protect the data which Lotame collects through Data Solutions and the lotame.com website from unauthorized access, disclosure, or modification.
Lotame has further committed to refer unresolved privacy complaints under the US-EU Safe Harbor Principles to an independent dispute resolution mechanism, the DMA Safe Harbor Dispute Resolution Program, administered by the U.S. Direct Marketing Association (DMA). If you do not receive timely acknowledgment of your complaint, or if Lotame does not satisfactorily address your complaint, you can reach the DMA Safe Harbor Program for more information and to file a complaint at:
Attn: Safe Harbor Line
Direct Marketing Association
1615 L St, NW Suite 1100
Washington, DC 20036-5624
Contact Us: To contact us with any questions, comments, or suggestions, please email us at email@example.com or write to us at the address below.
Lotame Solutions, Inc. Suite 2000 8850 Stanford Blvd. Columbia, Maryland, 21045, Attention: Legal Department.