This Privacy Policy describes the steps taken by AdTheorent, Inc. to safeguard the privacy rights of Web site visitors who receive mobile advertisements through publishers and media supported by our Mobile Demand-Side Platform (MDSP) and related services (Users). As a leading MDSP provider, our mission is to purchase media (in real time) from our inventory sources, and to serve mobile advertisements through such media on behalf of our advertiser clients in an intelligent manner. In our pursuit of these business objectives we adhere to the fundamental principles of transparency, user control and data security. AdTheorent is a member of the Internet Advertising Bureau and adheres to the IAB/DAA's Self-Regulatory Principles for Online Behavioral Advertising, including the unique principles applicable to the mobile environment.

This Privacy Policy describes the types of data that we do and do not receive through our MDSP, and the services we provide to our clients generally. This Privacy Policy is subject to change from time to time, in which case we will post an updated version on the Privacy section of our Web site. Changes to this Privacy Policy will take effect 30-days after the updated Privacy Policy is posted to our Web site's privacy page, located at www.adtheorent.com/privacy.php.

We Do Not Collect Personally Identifiable Information or Sensitive Consumer Information

We do not collect Personally Identifiable Information ("PII") or Sensitive Consumer Information ("SCI") about individual Users for any purpose. In other words, our MDSP does not target ads or otherwise use PII or SCI, nor do we seek to obtain PII or SCI from any vendors or partners. For purposes of this Privacy Policy, (i) PII means any information that could be used to identify the User, such as the User's name, Social Security Number, physical address, phone number (fixed or mobile), email address, credit card information, or any other data that could be used to personally identify the User; and (ii) SCI means sensitive information about a User such as financial account numbers, insurance plan numbers, or information about medical conditions. To the extent any of our Partners (as defined below) gather PII, their privacy policies will govern its use, but we do not ask for or receive any PII or SCI from any of our Partners. For purposes of this Privacy Policy PII and SCI are referred to collectively as PII.

How We Use Non-PII Data To Make Advertisements More Relevant to Users

When we serve mobile advertisements on behalf of our advertiser clients we endeavor to make the ads relevant to Users. We accomplish this by matching ads with relevant non-PII characteristics about the User and the mobile publication that the User has visited, such as the time of day, content on the site or app, carrier network, type of mobile device/mobile browser, IP address, as well as other non-PII data provided through our Partners. In other words, although we may serve an ad to a User based on certain demographic information about the Users (e.g., female in New York between the ages of 35 and 50), our MDSP does not know who that user is, or any information that would allow us to identify who the User is.

Currently we obtain certain device IDs (Android ID, Apple IDFA) in some cases to verify a User election, such as a User-requested app install request. In those cases we obtain the device ID not to track the User, but rather to substantiate for our advertiser clients whether the User installed the app.

Our MDSP does not currently use or seek to obtain information about a User's browsing history (i.e, web sites visited) or Web-based purchasing history. In addition, we will not use a User's current GPS geographic location to target an ad unless we or one of our Partners have previously obtained permission to do so. If we intend to obtain or use this information in the future we will update our Privacy Policy accordingly, as described above, to clearly delineate a User's rights; provided, however, that any User is free to Opt Out of any such future practice or use of User-specific behavioral or interest-based targeted advertising by clicking here.

Through our MDSP, we work with a broad network of publishers, carriers, networks and advertisers ("Partners"). Our Partners may have certain rights to the data we collect on their behalf, and each of our Partners maintains its own privacy policy. We may share aggregated data, or non-personal data with third parties.

Our clients are corporate organizations and businesses and our services are not directed at or developed for persons under the age of 13.

How We Collect Non-PII Data

We collect non-PII data both from our Partners and by looking at the non-PII information that comes to our servers from a User's device, such as a mobile phone, during an ad view. This information enables our MDSP to deliver the most relevant and useful advertisement given the non-PII data available about the media "impression." We currently do not store any cookies on User devices to identify any User.

How We Safeguard the Security of Aggregate User Data

Data collected by our MDSP is only retained in an aggregated form, so that information about an individual User cannot be retrieved. All the data we hold is protected by multiple layers of physical, electronic and administrative safeguards, to secure it against accidental, unauthorized or unlawful access, use, modification, disclosure, loss or destruction.

From time-to-time we may share the aggregated, non-individual specific, data we hold with Publishers and Networks for reporting and accounting purposes, as well as other unaffiliated third parties for various purposes such as statistical or educational analysis. In these cases we work with organizations we believe to have appropriate safeguards in place to protect data at the levels we require. In situations where we are obligated by law, we may also disclose information in order to investigate, prevent or take action regarding suspected or actual prohibited activities, included but not limited to, fraud and situations involving potential threats to the physical safety of any person.

How We Meet Our Obligations Under Laws, Regulations and Standards Intended to Safeguard Children

AdTheorent takes various steps to ensure compliance with the federal Children's Online Privacy Protection Act (COPPA) as well as voluntary industry frameworks such as the Children's Advertising Review Unit (CARU), administered by the Council of Better Business Bureau's, Inc., including the following:

  • We do not perform behavioral targeting as performed by many "first generation" ad networks; AdTheorent predictive modeling does not entail targeting of individual users.
  • We do not store data regarding users under age 13 (per COPPA); when an impression is flagged indicating a pre-13 child user, AdTheorent does not collect data from that impression or otherwise model off that data.
  • We work with responsible Publishers and App Partners who take seriously their responsibilities under applicable laws and FTC regulations. Such publishers have their own incentives not to make COPPA-governed data/information available to ad networks such as AdTheorent.
  • We utilize IAB brand safety categories in filtering impressions on which to serve advertisements, including filtering by the IAB category "any other content you wouldn't show your children."
  • Our in-house creative team monitors and ensures that all AdTheorent-prepared creative is consistent with the CARU General Guidelines.
  • Our clients are high-integrity brands with an appreciation forand understanding of the importance of CARU's standards.

Contact Us for Further Information

If you have any questions about this Policy or our privacy practices, please email us at legal@adtheorent.com.

This Privacy Policy was last updated in January, 2014.