We Do Not Collect Personally Identifiable Information or Sensitive Consumer Information
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 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 firstname.lastname@example.org.