Privacy Principles

These Privacy Principles have been adopted by Lotame’s leadership and will be reviewed at least annually and updated as needed, with respect to changes in our industry.

Lotame processes Personal Data to help our Business Customers conduct business, serve their customers, and deliver targeted advertising or personalized content, and to help our Data Partners monetize their data, all without sacrificing personal privacy. These Privacy Principles are our underlying guidelines that we follow to govern our services development, collection, use, storage, and disclosure of Personal Data. You can learn more about Lotame’s privacy practices with respect to our Services in our Services Privacy Notice and for our corporate function in our Corporate Privacy Notice.

1. Transparency: Our Privacy Notices will clearly explain the types of Personal Data we collect, why we are collecting that Personal Data, how we use that Personal Data, and to whom we may share or sell Personal Data.
2. Purpose Limitation: We will process Personal Data in the manner and for the purposes described in our Privacy Notices and in the contracts with our Business Customers and Data Partners.
3. Lawful Basis: We contractually require our Business Customers and Data Partners to obtain the appropriate legal basis for the processing of the Personal Data they provide to Lotame for the purposes set forth in our agreements. When we interact directly with individuals, we will seek their consent to collect, use, and disclose their Personal Data for the purposes stated in our Corporate Privacy Notice.
   
4. Collection Limitation: We only collect Personal Data that is relevant for the purposes we have explained in our Corporate Privacy Notice, our Services Privacy Notice, and in the contracts with our Business Customers and Data Partners.
5. Data Minimization: We dispose of Personal Data when we no longer need it for the purposes we have explained in our Corporate Privacy Notice, our Services Privacy Notice, and in the contracts with our Business Customers and Data Partners.
6. Security: We take reasonable steps to safeguard Personal Data, such as maintaining internationally recognized certification of our information security management system.
7. Individuals’ Privacy Choices: We honor any rights an individual may have under Data Protection and Privacy Laws to access, delete, opt-out, etc. their Personal Data.
8. Sensitive Personal Data: We limit our collection of Sensitive Personal Data, including information about children. And when we do process Sensitive Personal Data, we will do so in compliance with applicable Data Protection and Privacy Laws.
9. Prevention and Accountability: We will comply with the policies, practices, and procedures we have developed that are designed to create a robust privacy program that complies with applicable Data Protection and Privacy Laws. We adhere to the principles of Privacy by Design and Privacy by Default in designing, building, and delivering our Services.

Last updated on: July 1, 2023