[m]PLATFORM Privacy Policy

Effective Date: March 22, 2017

 

This Privacy Policy is intended to explain clearly how we collect information from web sites, applications and other digital properties (we refer to all of these below as “Sites”) for use in our “Platform” and “Services”. We also explain how information in our Platform is used to provide our Services, and how individuals can manage choices related to [m]PLATFORM Services.

 

Please note that because of the changing nature of privacy laws and regulations, digital technologies, and our business, we may modify this Privacy Policy from time to time. Please review this Privacy Policy periodically to become aware of any changes that may have occurred. If you continue to engage with [m]PLATFORM Services after any change in this Privacy Policy, we will take this as an indication that you have accepted the updated terms.

 

If you have any questions or comments regarding this Privacy Policy, please email us at

mplatformprivacy@groupm.com or write to us at [m]PLATFORM, c/o GroupM, 498 7th Avenue, New York, NY 10018, Attn: Privacy.

 

Who are we? 

[m]PLATFORM is a business in the GroupM media investment group; GroupM is part of the WPP, plc group of companies. This Privacy Policy applies only to [m]PLATFORM and not to any other GroupM or WPP group company or business.

 

What are our Services? 

[m]PLATFORM owns and operates a technology platform (the “Platform”) that provides various advertising-related services for its clients. Our clients include other GroupM and WPP group companies, which in turn perform advertising-related services for their own clients. This Privacy Policy outlines how and why [m]PLATFORM collects, uses, and shares data within the Platform. It also outlines how individuals can manage choices related to [m]PLATFORM “Services”.

 

We provide our clients with such services as: data management; audience and media insights, creation, modeling, planning and activation; analytics and attribution; visualization and reporting; and consultative services in connection with the foregoing (collectively, “Services”). Our clients use our Platform and Services, on their own behalf and/or on behalf of their own clients, in order to deliver useful and relevant advertising to users and to determine and improve the effectiveness of that advertising.

 

A customary use of our Platform and Services is to enable the delivery of customized advertising based on demographic information (such as age, gender, education, income and household status (e.g., number of children)), interests, prior activity and similar information (“User Information”). We call this type of advertising “Interest-Based Advertising”.

 

How do we collect information? 

We may collect information through the use of cookies, advertising IDs, pixels, and other technologies.

 

Cookie

a small alphanumeric text file that is stored in a browser by a web site or by a third-party ad server or other third party which allows that web site or third party to recognize that browser and remember User Information and other information. Our targeting cookie, which is named “Mookie” and operates on the mookie1.com domain, contains a unique randomly-generated value that is associated with User Information and other information. The Mookie cookie, together with such associated information, is used in the performance of our Services, and in particular Interest-Based Advertising activities.

Advertising ID

an alphanumeric identifier made available by a platform or operating system (such as Apple iOS or Google Android) that allows application developers and third parties to recognize a particular device in an application environment and remember User Information and other information.

Pixel

a line of code that is used by a Site or third party to assign online activities to a device or browser, or more specifically to the applicable cookie or advertising ID. The use of a pixel allows us to record, for example, that a device or browser has visited a particular Site or page.

 

We may associate the information collected over a period of time and from different Sites and across different devices and browsers. We may also integrate (and use in the same way) similar information obtained from other companies. We make use of our own holistic identifier to associate information relating to devices and browsers that we have reasonably linked to the same user, in order to help provide more useful and relevant advertising regardless of device or browser.

 

What types of information are collected and utilized by [m]PLATFORM? 

We may collect through our Services information regarding individuals’ browsing, usage and interactions when they view and interact with Sites and with advertisements where our Services are utilized. We may also collect information that identifies browsers and devices with which we have interacted previously. Such information may include the type of Internet browser, browser language, and operating system, specific device’s Internet protocol address (“IP address”), unique identifiers available at or pertaining to a specific device, connection type (wired or Wi-Fi), region where the device is located, network to which the device is connected, longitude/latitude of a (mobile) device, mobile carrier (if available), the Site and page the device came from before, and visited after, viewing an advertisement, and information related to the Site and page being viewed (i.e., in order to ascertain interests). Devices include computers, mobile phones, tablets, e-readers, or other digital devices capable of maintaining an Internet connection.

 

We may also receive information from other companies, including our clients, that is collected outside the Services and is provided to us for use in our Services and may be integrated into the Platform.

 

When do we share information? 

[m]PLATFORM may share Platform information with clients for purposes of Interest-Based Advertising, analytics and reporting, and other online advertising activities. We may also share information with third-party service providers that perform services and functions on our behalf and/or on behalf of our clients or their respective clients.

 

If we reasonably believe we are obligated by law or legal process to disclose information to a third party (including law enforcement), then we will do so. In addition, may disclose information to a third party (including an auditor or other service provider) in order to investigate, prevent, or take action regarding suspected or actual prohibited activities and/or in order to review, evaluate, or address the integrity or security of our Platform and Services. We may also provide to third parties (including our clients and their clients and potential clients) aggregated statistical data showing general usage patterns and statistics about Sites, interactions, and transactions; this aggregated data does not personally identify any user or provide specific information about individual usage.

 

Enhanced Notice 

 

interest based advertising icon

We are a member of the Digital Advertising Alliance (DAA) and the European Interactive Digital Advertising Alliance (EDAA), we adhere to the DAA’s self-regulatory framework and the IAB Europe EU Framework for Online Behavioural Advertising, respectively, in those markets where such applicable self-regulatory framework applies, and we support deployment of the Advertising Option icons (AdChoices and AppChoices). Advertisements that are provided by organizations that participate in these frameworks display the icon shown below when technologically feasible. Clicking on such icon provides you with information about Interest-Based Advertising.

 

Opt Out 

You may opt out of [m]PLATFORM Interest-Based Advertising through several mechanisms.

 

You may choose not to receive customized third-party advertisements via [m]PLATFORM targeting cookies on the browser you are using by clicking below, in which case the [m]PLATFORM targeting cookie will be replaced with an “opt-out” cookie and the Interest-Based Advertising data previously collected or received in association with the replaced [m]PLATFORM targeting cookie will not be used for Interest-Based Advertising on any other device or browser that we have reasonably linked to the browser where the information was collected. In addition, if we have actual knowledge that another device or browser is linked to your opted-out browser, that other device or browser will also be opted out from receiving Interest-Based Advertising via [m]PLATFORM.

 

To opt out of data collection via cookies from [m]PLATFORM please click here.

 

Our opt-out cookies are programmed to expire ten years after they are initially issued. If you buy a new device, upgrade or change web browsers or delete this opt-out cookie, you will need to perform the opt-out process again. In order for the opt-out process to work, your browser must be set to accept third-party cookies.

 

In browser environments, you may also refuse or remove cookies from both [m]PLATFORM and other service providers, via the following methods:

 

  • Adjusting your browser settings to refuse or remove cookies, which would result in the cessation of Interest-Based Advertising via cookies from [m]PLATFORM and from other providers. However, by doing so, you may not be able to use certain features on certain web sites or take full advantage of all web site offerings and Interest-Based Advertising. You may refuse or remove cookies by following the directions provided in your browser settings. Further information about cookies is available at www.aboutcookies.org, www.youronlinechoices.com and www.aboutads.info/consumers#cookies.

     

  • Adjusting the cookie settings at the level of the web site owner where you granted us consent to our cookie usage; cookie settings options may vary by web site owner.

     

  • Opting out of Interest-Based Advertising via our targeting cookies, as well as the targeting cookies of other service providers, at the following web sites:

     

     

In mobile app environments, you may opt out of Interest-Based Advertising from just [m]PLATFORM or from both [m]PLATFORM and other service providers, via the following methods:

 

  • Selecting “Limit Ad Tracking” via your device settings, which will result in the elimination of Interest-Based Advertising via the applicable advertising ID from [m]PLATFORM and from other providers.

     

  • Opting out of Interest-Based Advertising via the applicable advertising ID from [m]PLATFORM and/or other providers via the AppChoices app. Please note that, in order for the AppChoices app to function properly, the “Limit Ad Tracking” device setting must not be selected. Interest-Based Advertising data previously collected or received in association with the replaced advertising ID will not be used via [m]PLATFORM for Interest-Based Advertising on any other device or browser that we have reasonably linked to the mobile app environment where the information was collected. In addition, if we have actual knowledge that another device or browser is linked to the opted-out mobile app environment, that other device or browser will also be opted out from receiving Interest-Based Advertising via [m]PLATFORM. Additional information regarding the AppChoices app is available at http://www.youradchoices.ca/choices/.

 

Children’s Privacy 

[m]PLATFORM’S Services are not directed at children (as defined by applicable law) or at Sites primarily directed to children. [m]PLATFORM does not knowingly collect information from children. If you believe a child has provided us with personal information and would like to have the information removed, please contact us at mplatformprivacy@groupm.com.

 

Transfer of Data in the Event of Acquisition 

In the event that another company acquires all or substantially all of our assets or all or substantially all of the assets of our Platform business through a consolidation, merger, asset purchase, corporate reorganization, or other transaction, we reserve the right to transfer all information or all Platform information, as applicable, that is in our possession or under our control to the acquiring party.

 

Information Security 

We follow generally accepted online advertising industry standards to protect against unauthorized access to, unlawful processing of, unauthorized retention of, and unauthorized disclosure of data. These standards include undertaking necessary physical, electronic, and management activities required to protect data integrity, access, and use. Please keep in mind, however, that despite these efforts to protect data on our servers, no method of transmission over the Internet is guaranteed to be secure. Therefore, while we strive to protect such data at all times, we cannot guarantee its absolute security and shall not be liable for any breach of security in relation to any such data.

 

[m]PLATFORM Services and the Platform are used globally and therefore we may transfer data to countries around the world, including countries outside your country or continent. We will, where necessary, put in place appropriate safeguards to ensure such data is protected.

 

Data Retention 

We generally maintain the information we collect through our Services in non-aggregated form for a period of not more than 13 months. This data may include Sites visited, content viewed, ad interactions, IP addresses (please see the “IP Address” subsection below for additional information), browser type and language settings.

 

We may maintain information we collect through our Services in an aggregated form for a period longer than 13 months.

 

IP Address 

Please note that in some countries an IP address is considered personal data by applicable law. If we collect information from any such country and we know that you are located in that country, we will treat your IP address as personal data.

 

For those countries we interpose a “black box” that is operated by an independent third party and that separates your IP address from other data we collect. As a result of this black box, IP addresses for those countries do not touch [m]PLATFORM’S systems and are not processed by [m]PLATFORM in connection with the provision of Services.

 

California 

Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of personal information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. To request a list of companies, if any, to which [m]PLATFORM has provided personal information for its own marketing purposes, please contact us via the email alias or address stated in “Questions or Comments about this Privacy Policy” below. Please allow 30 days for a response.

 

California law requires us to disclose how we respond to browser “Do Not Track” signals or other choice mechanisms relating to Interest-Based Advertising. We have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.

 

We are committed to honoring privacy choices. For more information on opting-out of Interest-Based Advertising, please see the “User Choice” subsection above.

 

Information Received from Market Research Companies in the Netherlands 

If you have provided consent to market research companies in the Netherlands to disclose your panel data to [m]PLATFORM, then, based on the scope of such consent: we may receive User Information and other information, including panel IDs, from such companies; and we may use this information only for purposes of research and analysis, campaign optimization, advertising customization, and reporting on the effectiveness of online advertising campaigns.

 

How to Obtain a Copy of Your Information 

You are entitled to know what personal information we hold about you and to have any inaccuracies in your personal information corrected. For these purposes, please contact us at mplatformprivacy@groupm.com. You should also contact us at that email alias if your personal information or preferences change, if you don’t want us to send you the information you previously requested, or if you have any queries about how we use your personal information.