Privacy Policy

Viant EEA Privacy Notice

Data Controller: Viant UK Limited, a private limited company organised under the laws of England & Wales (company number 10184350) with a registered address at 16 Dufours Place 3rd Floor, London, United Kingdom, W1F 7SP.

About this Notice
Viant UK Limited (referred to in this notice as “Viant UK”) is a member of the  , which also includes Viant Technology LLC and Viant US LLC   (the “Viant Group”).  The Viant Group offers its services in several different countries that each have their own privacy laws. This European Economic Area Privacy Notice (“Notice”) applies to the Viant Group’s collection, use, sharing and other processing of personal data received from the European Economic Area (“EEA”).  This Notice supplements the Viant Group’s general Privacy Policy, and if there is a conflict between anything in the Viant Group’s general Privacy Policy and this Notice, this Notice will take precedence with respect to any personal data from the EEA.  This Notice contains links that you can click on to get further information or exercise the options you have about your data.  To make this Notice more reader-friendly, we use everyday words such as use, transfer and storage to describe what we do with your personal data – but this Notice covers processing of any kind that is subject to EEA data protection law.  Click here to learn more about how certain words used in this Notice correspond to EEA legal terminology.  Viant UK is the EEA personal representative for Viant Group members that are not established in the EEA.  Please note that this Notice does not apply to Myspace, which has its own privacy policy (available here), or to Xumo LLC, which has its own privacy policy (available here).

This Notice may change
We may revise this Notice from time to time.  We will notify you when we change this Notice via a banner, pop-up box or another easy-to-spot notice when visit the Viant UK home page and the home pages of other members of the Viant Group.

 Our business focus and your data
We are in the online advertising business. Many free services on the web (including free mobile apps) use revenue from third party advertising to pay for the cost of providing the free services to you.  Online advertisements can be randomly generated without knowing anything about the user who will see the adverts, but these days a lot of online advertising is targeted in some way so users see adverts that are more likely to interest them.  We use your personal data to deliver targeted advertising to you on websites and in apps on behalf of our customers.  These advertisements may be selected for you based on your location and/or usage of third party websites or services.  We use technologies to limit the information that we acquire about you, as described further below.

What data we collect
The personal data that we collect and use in our business falls into two different broad sets: consumer data and customer data.  Customer data is the personal data of our actual or potential business customers for advertising services, such as the representatives of companies that engage us to provide advertising services, or individuals who agree to provide their business contact information to us in order to download our white papers or other publications, or access demonstrations of our advertising services.  Our customers enter into contracts with us that address how we deal with their representatives’ personal data, so this Notice focuses on consumers.  Consumer data is data about the people who see the adverts that we display.

We also collect data via automatic means (described below in “Cookies and other Web Technologies”) when you access Viant Group websites or receive or click on adverts that we place on websites on behalf of our customers.  Some of this information relates to the devices that you use, such as a computer, mobile phone, tablet, smart TV or other electronic device.  (We use the term “Device” in this Notice to refer to any of these.)

The information we collect automatically may include:

We also obtain personal data from third parties – and we require those third parties to confirm to us that they have the right to provide personal data to us.

Cookies and other Web Technologies
We use a number of technologies that store information on your Device and read and update that information later for purposes of displaying advertisements to you on behalf of our customers (all described further below in “What we do with your data”).  These information storage technologies include cookies, unique identifiers, pixels, and embedded scripts.  New technologies that perform similar functions may be developed.  If we adopt new technologies that are not already descripted in our Cookies & Web Technologies Notice, we will update that Notice to let you know.

Cross-Device Linking and Tracking
We use web technologies to collect information to let us understand which Devices all belong to you, so we can offer seamless cross-Device advertising services.  For example, we match hashed versions of mobile IDs to de-identified data that resides in our platform in order to target advertising to users on mobile devices.

Moreover, we may use data collected from one or more of your browsers or devices in connection with data collected from your other browsers or devices, where such browsers and/or devices are shown to be linked or related to each other, for the purposes described in the Privacy Policy.

What we do with your data
We use your personal data, and some de-identified data derived from your personal data, to deliver targeted advertising.  If you visit any Viant Group website, we may use the data we gather about your use of that website, along with aggregated data from many other users, to improve the content of our website or make them easier to use.

How we protect your privacy when targeting adverts to you
To display adverts that are more likely to interest you, we may cross-reference information that we hold about you with information that others hold about you.  For example, we may use software that checks several customer databases (like the Myspace user database, a separate video service database and a particular loyalty card database) to see which users appear in all three, and then target adverts just to those users.   Information held in a particular database about a specific person is often referred to as that person’s “profile.”

When we or our affiliates use your personal data to deliver targeted advertising to you, we use  advert delivery technologies that encrypt information that would otherwise identify you to prevent the third party advertiser from knowing who you are.  The encryption technologies that we use convert data that identifies you (like a registered account name or e-mail address) into a string of characters that cannot be turned back into information that identifies you.  So the third party that has engaged us to display adverts to you will know that the advert is being displayed to someone with certain characteristics (e.g., a woman in her early twenties who likes to listen to Rihanna and go to music festivals in the UK) but the third party won’t have your name, e-mail address or any other information that would allow them to identify you specifically.   We add information about the adverts that have been shown to you and information about devices, purchasing or online behavior associated with a particular encryption-generated identifier to create a profile for that identifier.  This profile helps us to better match adverts to your interests and avoid showing you the same adverts too many times.

You have choices about your data

You have choices about how your data is used and shared.  You can always contact us to find out the personal data we have about you, request a correction, deletion or other change, or make a complaint at privacy@viantinc.com.

How to opt-out of targeted advertising
If you do not want us to use your data to provide targeted advertisements to you, or allow others to do that, you can let us know at privacy@viantinc.com.  For additional information on options for opting out of advertising by third parties, please visit www.youronlinechoices.com.  It’s important to understand that if you opt out of targeted advertising, you will still see adverts when you use the Internet and apps – the adverts may just be less relevant to you.

How we may share your data
We may share your data within our corporate group, and particularly with our affiliates Viant Technology LLC, Viant US LLC and Viant UK Limited for uses consistent with this EEA Privacy Notice, including for targeted advertising.

We may share your data with our contractors and business partners for the purposes described in this EEA Privacy Notice, including for targeted advertising.

Viant UK and other Viant Group members that have a copy of your personal data may disclose your data in the event we file for bankruptcy, or in connection with certain types of business transactions that result in a change in who owns our Viant Group companies or our assets.  We may disclose your data to enforce or protect our legal rights, or in response to a court order or other request that we are required by law to comply with.

More details about how we share your data are available here.

How we secure your data
The Viant Group uses various security measures, including server firewalls and SSL encryption for data that is in transit, to protect the integrity and security of any personal data that we hold.  We periodically evaluate available security technologies and change our security measures as we think appropriate in light of the risks to your data.  Please click here for more information about security.

How long we keep your data
As described above in the section “How we protect your privacy when targeting adverts to you”, we try to minimize our access to personal data in the course of providing our targeted advertising services.   Any personal data used to provide targeted advertising is retained for the minimal time necessary to complete a given advertising campaign.

You can always ask us to delete your data by e-mailing us here.

Your data will be transferred to the US and possibly other countries
Some members of the Viant Group are based in the USA, and the data that we collect from you may be transferred to, and stored and used in, the USA. We may also transfer your data to other countries outside the EEA for processing by staff operating outside the EEA who work for us or for one of our contractors.  For example, our customer support may be provided by contractors located in the Philippines.  The laws of the USA and other countries outside of the EEA may not protection your data to the same level as the laws of the EEA, or give you the same rights that you would have in the EEA (including rights relating to access to personal data by law enforcement or national security/intelligence agencies).  If you have provided your personal data directly to any member of the Viant Group, you consent to the transfer of your data outside of the EEA.  If we obtain your personal data from a third party to provide targeted advertising services, we take additional steps (which may include using the EU-approved standard clauses, or consent obtained during the original collection of your personal data) to ensure that the transfer complies with EU data protection laws.

 

Terminology

A quick word about terminology:  European Union data protection law covers the “processing” of personal data in a range of situations.  “Processing” is defined by the EU Data Protection Directive (Directive 95/46/EC) to mean “any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.”  To make this Notice more reader-friendly, we refer to processing by simpler terms such as use, transfer and storage – but this Notice covers all kinds of processing that’s subject to EU data protection law.  Also, when we refer to “data” in this Notice, we mean your “personal data” as defined in the Directive (“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity”).  The Directive is due to be replaced by the EU’s General Data Protection Directive (“GDPR”) on May 25, 2018, and when that happens, the terms used in this Notice should be interpreted to correspond to the GDPR.

 

 

This privacy policy was last revised on October 18, 2016.

Viant is a digital media company comprised of a family of companies that includes the Viant, Vindico, Specific Media and Site Meter businesses (collectively, “Viant,” “we,” or “us”). This Privacy Policy explains the information we collect, how we use that information and the choices we offer, including how to opt-out of certain collection and use of that information. The Viant family of companies also includes Myspace. This Privacy Policy does not apply to Myspace. The privacy policy for Myspace is located here.

We take the issue of user privacy on the internet very seriously. The following is intended to be a plain English explanation of our practices.

This Privacy Policy describes key aspects of our privacy practices, including:

If you are not familiar with terms like cookies, IP addresses and pixels, we suggest that you read about these and other key terms first.

We always welcome comments and questions on our Privacy Policy, so please do not hesitate to contact us with any comments or questions atprivacy@viantinc.com.

Please note that this Privacy Policy does not apply to the practices of third parties that own or operate the websites and other internet connected platforms where any of our advertisements are displayed or that otherwise utilize our services, or any third party websites and platforms that are linked to from our websites or services. Please be aware that we are not responsible for these third party sites and platforms in any way including without limitation, the privacy practices of these websites and platforms (and/or their third party owners or operators). For information about those third parties’ practices, we encourage you to carefully review the privacy policies governing those websites and platforms.

I. Information we collect

We receive and collect information in order to provide and improve our services, such as to serve ads or provide content that is more relevant to users.

We collect information in a number of ways, including the following:

II. How we use the information we collect

A.     Personal information you give us

Personal information you provide to us through the use of our corporate websites – for example, in order to sign up for an email distribution, inquire about or sign up for our services or to apply for a job with us – is generally used for the purpose for which it was provided. We may also use yourpersonal information in order to send you emails from time to time about our services, respond to your inquiries or in order to provide our vendors and subcontractors your personal information in connection with performing services for us. Additionally, we may use your personal informationfor other purposes permitted under this Privacy Policy, such as to protect or comply with legal rights and obligations, to complete a merger or sale of assets or for additional purposes with your consent. We may also collect personal information on behalf of a partner that has been identified to you. In such instances, we will collect and use that information in accordance with the privacy policy that is posted at the point of collection and we will not be liable for usage of that information made by the applicable partner.

B.     Information that we collect through your use of our and our affiliates’ services and the internet or that we otherwise receive from our affiliates and third parties

We use the information we collect to improve our services and to deliver a more personalized web experience. This includes providing advertising and content that we believe is more relevant to you and providing more accurate analytics and reporting to our clients and partners.

The information that we collect and receive may be used for purposes including:

Additionally, information we obtain from third parties (including our affiliates) about you may be appended to information that we otherwise have about you for the purposes described in this Privacy Policy. For example, we match hashed versions of mobile IDs to de-identified data that resides in our platform in order to target advertising to users on mobile devices.

Moreover, we may use data collected from one or more of your browsers or devices in connection with data collected from your other browsers or devices, where such browsers and/or devices are shown to be linked or related to each other, for the purposes described in this Privacy Policy.

Because our services continually are evolving, we reserve the right to use the information that we collect for other legal purposes that are consistent with this Privacy Policy, even if not specifically described herein. We retain the right to use and disclose information that is not personal information or combined with personal information for any purpose.

C. Public Information

If you choose to submit content to any public area of our websites or services, your content will be considered “public” and will be accessible by anyone, including us, and will not be subject to the privacy protections set forth in this Privacy Policy unless otherwise required by law. We encourage you to exercise caution when making decisions about what information you disclose in such public areas.

III. How we use and share your information

A. To deliver services

In order to facilitate our delivery of advertising, analytics and other services, we may use and/or share the information we collect, includinginterest-based segments and user interest profiles containing demographic information, location information, gender, age, interest information and information about your computer, device, or group of devices, including your IP address, with our affiliates and third parties, such as our service providers, data processors, business partners and other third parties.

B. With third party clients and partners

Our online advertising services are used by advertisers, websites, applications and other companies providing online or internet connected advertising services. We may share information, including the information described in section III.A. above, with our clients and partners to enable them to deliver or facilitate the delivery of online advertising. We strive to ensure that these parties act in accordance with applicable law and industry standards, but we do not have control over these third parties. When you opt-out of our services, we stop sharing your interest-based data with these third parties. Click here for more information on opting out.

C. To protect or comply with our legal rights and obligations

In addition to any other uses permitted in this Privacy Policy, there may be instances when we may use and/or disclose information we collect and receive where we have, in our discretion, a good faith belief that such use and/or disclosure is necessary in order to: (i) protect or defend our or your legal rights or property or those of our affiliates, employees, agents and contractors (including enforcement of our agreements); (ii) protect the safety and security of members of the public, including responding to emergencies where there appears to be a danger of death or injury to any person; (iii) protect against fraud or for risk management purposes and to investigate potential related issues; or (iv) comply with the law, law enforcement, or legal process or proceedings or requests from public or government authorities.

D. To complete a merger or sale of assets

If we sell all or part of our business or make a sale or transfer of our assets or are otherwise involved in a merger or transfer of all or a material part of our business, or participate in any other similar business combination (including, without limitation, in connection with any bankruptcy or similar proceeding), we may transfer all or part of our data to the party or parties involved in the transaction as part of that transaction. You acknowledge that such transfers may occur, and that we and any purchaser of our business or assets may continue to collect, use and disclose your information in compliance with this Privacy Policy.

E. Upon your request

We may also use and/or share your information, including your personal information, upon your request or instruction.

IV. Your choices

A. Interest-based advertising opt-out

We adhere to the Digital Advertising Alliance (DAA) Principles regarding online behavioral advertising (otherwise known as “interest-based advertising”) (more information here). We also adhere to the to the IAB Europe EU Framework for Online Behavioural Advertising (more information here). Accordingly, we offer an “opt-out cookie” to block the placement of our behavioral advertising cookies on your system for two years from the time you opt out. When we detect our opt-out cookie on your browser, we do not serve you with interest-based advertising. However, the opt-out cookie is browser and device specific. Therefore, if you use multiple devices, multiple browsers or have multiple users on a single device, you will need to perform the opt-out operation for each device, browser and user that you want to opt out. If you delete your cookies, change browsers, or use a different device, you will need to opt-out again. Browser settings that block all cookies may prevent this opt-out from operating correctly and certain privacy software may delete the opt-out cookie or cause it to function incorrectly. Furthermore, the opt-out cookie is not effective on devices that do not accept or otherwise support cookies, such as iOS based mobile devices, internet connected televisions and other non-cookie based connected devices and applications.

You may install our opt-out cookie by clicking the button below:

optout

Please note that if you choose to opt-out of interest-based advertising, it does not mean you will no longer receive advertising on the internet. However, it does mean that the display advertising you see will not be behaviorally targeted by us to your interests or preferences, so long as the opt-out cookie remains in place. Further, except for the specific restrictions noted above, our opt-out cookies do not otherwise prevent us from continuing to collect, maintain or use information as described herein.

B. Platform and App-Based Opt-Out

Opting out of behaviorally targeted advertisements associated with PC, mobile, or other digital platform applications (also referred to as “apps”) and internet connected devices, such as iOS or Android based mobile phones, internet connected televisions and other non-cookie based connected device platforms, requires a different process than opting-out of browser-based behavioral targeting. Opting-out in this context requires you to follow the process implemented by the application owner, platform device manufacturer, or third-party advertising network partners that control the placement of ads on the relevant app, device or other platform. . For example, Apple and Google provide settings in the iOS and Android platforms that allow you to opt-out of interest-based advertising on your mobile device which uses such platforms. Opting out on these apps, devices and platforms is a third-party process, and we take no responsibility for the actions or inactions those third parties with respect to their respective opt-out mechanisms, if any. We encourage you to review your options and exercise your choices on such third party apps, devices and platforms. To learn more about opting out on mobile devices, click here.

C. Unsubscribe Opt-Out

If you would like to unsubscribe or opt-out of our use of your personal information that you have provided to us, all such unsubscribe or opt-out requests should be sent to us at privacy@viantinc.com and we will process your request within a reasonable time after receipt. We are not responsible for removing your personal information from the lists of any third party who has previously been provided your information in accordance with this Privacy Policy or your consent, such as a sponsor. You should contact such third parties directly.

D. Other important information and links

For more information on the products and services covered by this Privacy Policy, please click here, here, here, or here. Please click here to review the terms of use governing Site Meter’s services. If you are a Myspace user, you may click here to exercise choices regarding the use of your Myspace information for advertising purposes.

Viant is a member of the Network Advertising Initiative (NAI) and adheres to the NAI Codes. The NAI is a cooperative of online marketing and analytics companies committed to building consumer awareness and establishing responsible business and data management practices and standards. For more information, please visit http://www.networkadvertising.org.

V. Security

We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your information. We cannot, however, ensure or warrant the security of any information you transmit to us and you do so at your own risk. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.

VI. Health and financial related information

We create non-sensitive health and financial related interest-based segments as part of our services, including  general interest-based segments such as “Health::Medical Centers” and “Finance::Insurance,” and custom interest-based segments such as “Health::Dieting::Acai Berry” and “Health::Contact Lens.” However, we recognize that consumers may have differing opinions regarding which data segments are sensitive. Therefore, we encourage you to click here for a list of our general health and financial related interest-based segments. We do not use interest-based segments to determine credit worthiness or for insurance underwriting or employment eligibility purposes.

VII. Children’s privacy

We are very sensitive to the importance of children’s privacy. Our websites, products, and services are neither developed for, nor directed at, children. We do not knowingly employ or offer services or target advertising towards or collect information from children under the age of 13. Although we make reasonable efforts to ensure that children do not use our services and are not behaviorally targeted (i.e., we do not knowingly provide targeted advertising to partner websites whose audience is comprised of primarily children under the age of 13), we cannot guarantee that your child will not be exposed to advertising provided by us, or that we have not received information related to your child’s online activities. If you believe your child has provided us with personally identifiable information, or registered at one of our websites, please contact us atprivacy@viantinc.com to have the data provided by and associated with your child deleted.

VIII. Storage in the United States

This Privacy Policy is governed by the laws of the United States of America. Our servers are maintained in, and we control and operate our services from, the United States of America. Your information may be stored and processed in any country where we have facilities or in which we engage service providers. By using our services, you freely and specifically give us your consent to export your information to countries outside of your country of residence, including the USA, which may have different data protection rules from those of your country. A as specified in this Privacy Policy. You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA.

IX. Data retention

The cookies that store data related to interest-based advertising expire 24 months after the last time that Viant’s ad serving system interacts with your browser or device. We store data collected and received in non-aggregate form, such as IP address and other log-level data, for up to 36 months, unless a longer retention period is required by law or is necessary to comply with regulatory audits, court orders, legal proceedings, or law enforcement requests. We retain aggregated data for longer than 36 months for purposes such as analysis, research, development and improvement of services.

X. Changes to Privacy Policy

We will continue to evaluate this Privacy Policy in order to keep up with changing user needs, enhanced technologies, and as we develop new service offerings, and we may make changes to the policy accordingly. We reserve the right to modify this Privacy Policy at any time, so please review it frequently. When changes are made to this Privacy Policy, we will revise the “Effective Date” found at the beginning of this Privacy Policy.

If we make any material changes to our privacy practices that may impact you, we will prominently post notice of the changes on our website(s) for a period of at least 30 days. We recommend that you check the Privacy Policy frequently to inform yourself of any changes.

XI. Specific product practices

Please click here to review the Myspace privacy policy, or here to exercise choices regarding the use of your Myspace information for advertising purposes.

XII. Questions and comments

Questions and comments about our Privacy Policy should be directed to privacy@viantinc.com or mailed to:

Privacy Officer, Viant

4 Park Plaza, Suite 1500

Irvine, CA 92614

 

Key terms
  1. Cookie
  2. Embedded script
  3. Hashed
  4. Interest-based segment
  5. IP address
  6. Non-personal information
  7. Personal Information
  8. Pixels
  9. Server Logs
  10. Unique identifier
  11. User Panel
  12. Web Crawler

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.

Embedded script

An embedded script is programming code that is designed to collect information about the way an advertisement displays on a website. The code is temporarily downloaded onto a user’s device from our web server or a third party web server, is active only while you are connected to a particular website, and is deactivated or deleted thereafter.

Hashed

Hashed means de-identified. Technically, a hashing algorithm is a function that converts a data string into an alphanumeric string output of fixed length. When we use “hashed” in this privacy policy, we mean a de-identified version of the data that is hashed. For example, the hashed version of “example@example.com” is: 23463b99b62a72f26ed677cc556c44e8.

Interest-based segment

A user or group of users categorized on the basis of preferences or interests inferred from the data we collect and receive that are used as a basis for displaying advertisements and other content intended to be more relevant and useful to the user or users. Examples include “AUTO::Auto In-Market MASTER,” “TRAVEL::Travel In-Market MASTER” and “SPORTS::Sports Enthusiasts.”

IP address

Every computer connected to the internet is assigned a unique number known as an internet protocol (IP) address. Since these numbers are usually assigned in country-based blocks, an IP address can often be used to identify the country, and in many cases a more precise location, from which a computer is connecting to the internet.

Non-personal information

All forms of user information other than the personal information that you provide to us. This includes, for example, browser type, user device, operating system, IP address, performance statistics, cookie IDs, request-based information, demographic information, unique identifiers, web browsing information, performance information, session information, and log information and other similar data, whether collected by us or received from affiliates or third parties. Please see Section 1 of our Privacy Policy for a more complete description of the non-personal information we collect.

Personal information

This is information that you provide to us that personally identifies you, such as your name, email address, billing address and credit card information.

Pixel

A pixel, also known as a pixel tag or web beacon, is a small snippet of code embedded in a website. Pixels allow a website to transfer or collect information through a graphic image request. Pixels can be used count site visitations and conversions, gather broad-based user interest data, transmit to and receive information from third parties, deliver, read and write to cookies and for other purposes connected to the provision of advertising, analytics or other services.

Server logs

Like most websites, our servers automatically record the page requests made when you visit our sites. These “server logs” typically include your web request, IP address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.

Unique identifier

A unique identifier is a string of characters that is used to recognize a user’s device, browser or other platform. Unique identifiers may be used in conjunction with or separate from cookies, including on platforms (e.g., certain mobile devices) where cookie technology is not available.

User panel

Panel of internet users that agree to anonymous recording of their ad exposure activity as they browse the web and are exposed to video and display advertisements in exchange for free software and services such as browser toolbars, games, and applications that provide information services such as weather, travel, news.

Web crawler

A sophisticated bot that renders webpages as a user would in order to analyze the page content and how ads deliver to users on a given webpage.

 

Financial and Health Interest-Based Segments