We want to be transparent with you about how we collect and use your Personal Data in providing our technology to website and mobile app publishers (“Publishers”) and online advertisers (“Advertisers”).
We are Nativo, Inc. We are a Delaware company. Our address is: 222 Pacific Coast Highway, 10th Floor, El Segundo, CA 90245.
We have a UK subsidiary called Nativo London Limited. Its address is: 5 Margaret Street, 2nd Floor, London, UK W1W 8RG.
Nativo is an advertising technology provider. We focus on delivery of online advertisements (“Ads”). This may include “native” Ads, which refers to content (which may be a textual article, an image and/or a video) that adopts the look and feel of adjacent editorial content, but that is separately labeled as sponsored or advertising content. It may also include more traditional digital Ads (e.g., a banner Ad displayed at the top or along the side of a website).
Our technology enables us to ensure that you see Ads on Publishers’ websites and mobile apps (“Publisher Properties”) that we, Publishers and Advertisers think you would prefer to see, based on your previous interaction with other Publisher Properties and the Advertiser’s websites and mobile apps (“Advertiser Properties” and collectively with Publisher Properties “Properties”). This decision is made based on online activity associated with:
To enable us to provide these services we have developed software for Publishers and Advertisers to integrate into their Properties. This software, together with the Nativo Cookie we set, enables us to:
Nativo collects Mobile Advertising IDs to help us store basic information about users of mobile app-based Properties. This enables us to identify that user when we see them on a different mobile app-based Property. To be able to do that, we need to collect the Mobile Advertising ID itself.
Effect of resetting your Mobile Advertising ID.
All the information we have about a mobile-based user is tied to their current Mobile Advertising ID. If you reset your Mobile Advertising ID, the next time you visit a mobile app-based Property, we will not recognize you or your device, we will treat you as an entirely new user we have never seen before, and we will collect your new Mobile Advertising ID.
Opting-out from your Desktop Browser.
You can opt out of all targeting of any Ads by all Advertisers using Nativo’s services using Personal Data collected on your browser by clicking below:
When you opt out of receiving interest-based Ads, we will stop collecting Personal Data from the browser that you used to opt out for purposes of targeting Ads. In addition, we will, as soon as reasonably possible, permanently decouple any information we hold from your Cookie ID.
Note that if you use multiple devices and/or web browsers, you would need to visit this link on each browser/device to fully opt-out of interest-based Advertising.
In addition, Nativo has a partnership with Liveramp to provide our Advertiser and Publisher partners the ability to do Audience-Matched Advertising, which uses data linked, or previously linked, to personally-identified information for the purpose of tailoring advertising. To opt-out of this type of advertising please visit the Liveramp opt-out link here.
Opting-out on Mobile.
Reset your iOS Advertising Identifier: if at any time you wish to reset your iOS Advertising Identifier, which will disassociate that Mobile Advertising ID (and any data collected using that Mobile Advertising ID) from your device and cause us to start afresh, you can do so by replacing the final step with “Click on ‘Reset Advertising Identifier’”.
Reset your Android Advertising ID: if at any time you wish to reset your Android Advertising ID, which will disassociate that Mobile Advertising ID (and any data collected using that Mobile Advertising ID) from your device and cause us to start afresh, you can do so by replacing the final step with “Click on ‘Reset advertising id’”.
Find your Android Advertising ID: if at any time you want to know your Android Advertising ID, you can find it at the bottom of the ‘Ads’ section referred to above. You will need to find your Android Advertising ID to send it to us if you want to make a specific Erasure or Access request in respect of your Android device.
Nativo is a member of the Network Advertising Initiative (NAI) and adheres to the NAI Codes of Conduct. You may use the NAI opt out tool, which will allow you to opt out of receiving tailored online ads from Nativo and from other NAI members.
Nativo participates as a vendor in the IAB Europe’s Transparency and Consent Framework and intends to participate as a Framework Participant in the IAB CCPA Compliance Framework for technology companies to manage data collection and processing in California. If you are located in the European Economic Area (EEA), Switzerland, the United Kingdom or California, you may be presented with certain choices regarding our collection and use of your Personal Data when you visit Publisher Properties, which choices may be passed to us via the IAB Europe’s Transparency and Consent Framework or the IAB CCPA Compliance Framework, as applicable. We honor consumer choices that we receive via those Frameworks.
Reset your web-based User Profile Records.
If you want to continue to see our tailored Ads on your web browser, but want us to clear the information we currently associate with you and your device, you should remove your cookies – as described below, in effect this will reset your User Profile Record.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility).
As noted above, all the information we have about a web-based user is tied to the Cookie ID that is assigned to the Nativo Cookie currently placed on their device. If you clear your cookies, it will delete the Nativo Cookie and therefore the Cookie ID (and associated User Profile Records) will no longer identify a cookie on your device. This means the next time you visit a Property, we will not recognize you or your device, we will treat you as an entirely new user we have never seen before and we will set the Nativo Cookie (together with a new Cookie ID) again.
If you are located in the European Economic Area, the United Kingdom or Switzerland, you have the following additional rights:
In addition to the opt-out rights described above, you may have the right to request that we erase Personal Data we hold about you in certain situations. You can exercise these rights by contacting our Data Protection Officer at email@example.com or by filling out our Data Subject Request Form. Since we don’t have a way to identify your data by name in our systems, we may need to request certain information from you (such as the applicable Cookie ID and Mobile Advertising IDs from your systems) to complete this request.
When we receive an eligible request to erase your Personal Data, we will try to comply with it as soon as reasonably practicable and (in any event) within one month.
You may also have the right, in certain situations, to request that we provide you with the Personal Data associated with your current Cookie ID and/or Mobile Advertising ID. You can exercise this right, if applicable, by contacting our Data Protection Officer at firstname.lastname@example.org or by filling out our Data Subject Request Form. Since we don’t have a way to identify your data by name in our systems, we may need to request certain information from you (such as the applicable Cookie ID and Mobile Advertising IDs from your systems) to complete this request.
When we receive an eligible request to provide you with the Personal Data associated with your current Cookie ID and/or Mobile Advertising ID, we will try to comply with it as soon as reasonably practicable and (in any event) within one month.
Correction and amendment.
As the Personal Data we hold about you is ‘pseudonymous’ (for more information on what this means, see here), we do not know who you are. This means we would not be able to correct or amend any Personal Data that may be inaccurate.
However, if you believe we hold information about you that is inaccurate or you would like to correct or amend, we recommend you contact our Data Protection Officer at: email@example.com or by filling out our Data Subject Request Form.
Right to object.
You may have a right to object to our use of your Personal Data, in certain situations. If you want to exercise this right at any time, the quickest and easiest way to do so is by ‘opting out’ following the steps described here.
Alternatively, you may also have the right to request that we ‘erase’ your Personal Data by following the steps outlined here. However, this will be a more manual, lengthier process.
If you would like to make a complaint regarding this Interest Based Ads Policy or our practices in relation to your Personal Data, please contact our Data Protection Officer at firstname.lastname@example.org
We will reply to your complaint as soon as we can and in any event, within forty-five (45) days.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
For EEA residents: Please contact our EU Representative at email@example.com.
Alternatively, they can be reached by post or phone:
The DPO Centre
3 Ballsbridge Park
(+353 1 631 9460)
Effective January 1, 2020, If you are a resident of the State of California (as defined in Section 17014 of Title 18 of the California Code of Regulations), then you have the below additional rights under the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning when used in this Section.
Deletion. You have the right to request the deletion of your personal information that we have collected and retained, subject to certain exceptions.
Disclosure. You have the right to request, no more than twice in a 12-month period, disclosure of the personal information about you that we collect, use, disclose and sell during the preceding year, which shall include as follows:
• The categories of personal information that we’ve collected and sold about you, or shared for a business purpose with our service providers.
• The categories of sources from which we collected such information.
• The categories of third parties with whom we’ve shared that personal information and to whom we’ve sold that personal information.
• Our business or commercial purpose for collecting or selling that personal information.
• The specific pieces of personal information we collected about you.
Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights.
Opt out. You have the right to opt out of our “sale” of your personal information to third parties.
If you wish to contact us to submit a request under the California Consumer Privacy Act of 2018, please feel free to contact us by telephone at 1-855-905-0440, by email at firstname.lastname@example.org, or by filling out our Data Subject Request Form. Your request must: (a) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (b) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Since most of the information we collect is pseudonymous and not connected to your name or email address, we may need to request additional information from you, such as your cookie or mobile advertising ID, to identify you and comply with your request.
For purposes of exercising your rights above, please refer to the “What Personal Data we Collect”, “How we Use Your Personal Data and Why” and “Who We Share Your Personal Data With” sections of this policy, which discloses the categories of personal information we have collected about consumers in the previous 12 months and the categories of personal information that we have disclosed for a business purpose or sold to third parties in the previous 12 months. You may designate an authorized agent to make a CCPA request on your behalf by verifying your identity and providing written permission to your agent to make the request for you.
To opt out of the use of your personal information for interest-based-advertising purposes, please refer to the “What Your Rights Are” Section of this policy. For clarity, under CCPA personal information does not include de-identified or aggregated consumer information.
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
“Personal Data” refers to information about you that may be considered “personal data” or “personal information” under GDPR, CCPA or other applicable privacy or data protection laws.
As further detailed below, the personal information we collect may include: (A) identifiers, such as your Internet Protocol address, cookie identifiers and mobile device identifiers; and (B) Internet or other electronic network activity information, such as information regarding your interaction with our Publisher and Advertiser websites, mobile properties or advertisements that you view or visit. We may also draw and store inferences about you and your preferences from the information we collect.
Three important notes:
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of this breach.
Important note: as the Personal Data we hold about you is ‘pseudonymous’, we do not know who you are – so, we don’t have any means of liaising with you directly to inform you of any Personal Data breach that may have occurred. Although this will be decided on a case-by-case basis, working in conjunction with the regulator, it is most likely that we will provide notice of any such breach by way of a general posting on this website.
We will only retain your Personal Data for so long as we reasonably require it to use it for the purposes set out above, unless a longer retention period is required by law (for example for regulatory purposes):
The table below shows our standard retention practices: