This policy explains how Altavara LLC. (“Altavara,” “we,” or “us”) collects, uses, and discloses information about you when you interact with Digital Media Properties that use our advertising technology platforms and related services to deliver you ads (collectively, the “Services”).
This policy does not govern (i) the collection and use of information about visitors to our website, www.altavara.co, which is covered by our Website Privacy Policy; (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.
About Us
Altavara provides Services that connect buyers of advertising inventory (advertisers) with sellers of advertising inventory (publishers) — the opportunity to display a buyer's advertisement on a seller's Digital Media Property. We refer to our buyers and sellers collectively as “clients.”
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 (collectively, “Digital Media Properties”).
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, it 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.
The information we collect may include:
- Usage information: including information about the domain, topic, or name of the property, date/time of visits, search terms, viewability data, video title and player size, click data, and types of advertisements viewed.
- Log information: including browser type, app version, access times, pages viewed, and the page visited before navigating to the Digital Media Properties.
- Device information: including device make, model, operating system, OS version, and data connection type.
- Location information: approximate location derived from IP address. With your device permissions, we may also receive precise location information if our clients pass it to us. Precise location may be deemed sensitive personal information in some jurisdictions.
- Internet service information: including your Internet Service Provider (ISP).
- Deidentified information: including encrypted or hashed forms of your email address if our clients pass these to us. Where we deidentify User Information, we commit to not re-identifying it.
- Derived information: user demographics, preferences, click and video interactions, behaviors, or interests received from third parties at the instruction or for the benefit of our clients, 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 also collect and store inferences about user activity using our Services.
How We Collect User Information
We (and our service providers) use different technologies (collectively “Tracking Technologies”) to collect information automatically from your device when you visit a Digital Media Property that uses our technology, including cookies and other similar technologies. Tracking Technologies help match client 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 advertiser client cookies.
This cookie-syncing 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 syncing 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 their decision to bid on advertising opportunities, because they may recognize that the cookie ID sent to them as an opportunity to bid on relates to a user they already know.
We also use Tracking Technologies for frequency capping (i.e., to ensure the same user is not served the same advertisement repeatedly), to assist with the delivery of ads, to provide reporting to our clients, and to understand and measure interactions with ads and their effectiveness.
Services provided by others: We also work with third-party analytics and advertising service providers that separately collect and use User Information to enable our clients and their customers to deliver targeted advertisements using our advertising technology. For 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 to offer groupings of audiences (commonly known as audience segments) on the Digital Media Properties as advertising opportunities.
Use of User Information
We and our clients use User Information to inform their decisions regarding buying and selling advertising space on Digital Media Properties, and to deliver end users targeted advertising. This processing may constitute “targeted advertising” under some laws and the “sale” or “sharing” of personal information under others. For more information about how targeted advertising works, you can visit the Network Advertising Initiative's (NAI) educational page at networkadvertising.org.
We also use User Information to:
- Enable our clients to offer and buy advertising opportunities on Digital Media Properties;
- Operate and improve our technology;
- Compile statistics and conduct research for our internal business purposes;
- Prepare reports of visitor activity;
- Enable standard advertising controls;
- Analyze and report on ad performance — ad views, ad fill rates, click-through rates, campaign reporting, and forecasting;
- Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
- Create profiles of end users for targeted advertising;
- Create audience segments as advertising opportunities.
Disclosure of User Information
- Clients: We disclose User Information to our advertiser clients to help them identify and buy advertising on publishers' Digital Media Properties.
- Business transfers: We may disclose User Information in connection with an actual or proposed sale or transfer of all or part of our business, merger, consolidation, or bankruptcy.
- Legal rights and compliance: We may disclose User Information with law enforcement, regulatory authorities, courts, or other necessary third parties for legal, protection, security, or safety purposes.
- Vendors and service providers: We may disclose User Information with vendors who analyze data, provide reporting, prevent fraud, or otherwise support our technology platform.
- Partners: We may disclose User Information with partners, including third-party advertising platforms, who may use the data for their own purposes.
Information Our Clients and Vendors Collect
Our clients and vendors who use our technology may use their own tags, pixels, cookies, or other similar technology within advertisements and on certain Digital Media Properties. We are not responsible for their use of such technologies or for their privacy practices.
Your Privacy Rights and Choices
Opt-out
Depending upon where you live, certain activities described 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, by emailing us at privacy@altavara.co.
Access, correction, deletion
Depending on where you reside, you may have the right to (1) request to know 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; and (4) obtain your User Information in a portable format. Please email privacy@altavara.co for instructions.
Information retention
We store User Information for as long as necessary for the purpose(s) for which we originally collected it or for other legitimate business purposes. We typically store information like IP address in our systems for up to 90 days before we anonymize and aggregate it into summary reports.
Security
We use industry-standard technical and organizational security measures to help protect information transmitted over or stored on our systems. No transmission or storage can ever be guaranteed completely secure, but we take all reasonable precautions.
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.
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, and the third parties to whom we disclose personal information. We collect personal information from the sources described in the “Information We Collect” section above.
Do Not Sell or Share My Personal Information
Altavara's disclosure of User Information may sometimes constitute a “sale” or “sharing” under California law. You may opt out of the “sale,” “sharing,” and use of sensitive information for advertising purposes by emailing us at privacy@altavara.co. Opt-outs are specific to the device or browser on which they are exercised.
Additional Information for EEA, UK, and Switzerland End Users
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. To exercise your rights, please email privacy@altavara.co.
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 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, they include the interests described in the section headed “Use of 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.
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. Contact details for EU data protection authorities are available at edpb.europa.eu. The Swiss data protection authority can be contacted at edoeb.admin.ch. The UK data protection authority can be contacted at ico.org.uk.
Changes to This Policy
We may update this policy from time to time to reflect changes to our practices or for other operational, legal, or regulatory reasons. If we make material changes, we will notify you by posting the revised policy on this website and, where necessary, by any other means required by applicable law.
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 at privacy@altavara.co or by post:
Altavara LLC.
Attn: Privacy Team
33 Irving Place, New York, NY 10003