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What does this Website Privacy Policy Cover?

We want to be transparent with you about how we collect and use your Personal Data when you visit our website available at www.nativo.com or any other Nativo web property or service referencing this Website Privacy Policy (collectively, the “Website”).

With that in mind, this Website Privacy Policy is designed to describe:

This Website Privacy Policy does not cover Personal Data that we collect and use when you visit the websites or mobile apps of our publisher and online advertiser clients – this information can be found on our interest-based ads page.

Incoming, EU-wide data protection legislation known as the “General Data Protection Regulation” or “GDPR” (a copy of which is posted here), will have effect from May 25th, 2018. The Website Privacy Policy is intended to meet our duties of Transparency under the GDPR and all other applicable privacy laws.

We will post any modifications or changes to this Website Privacy Policy on this page.

Who we are.

We are Nativo, Inc. We are a Californian company. Our address is: 100 N. Sepulveda Blvd., 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.

When we refer to “Nativo”, “we” or “us” in this Website Privacy Policy, we are referring to both ourselves and our UK subsidiary.

We have appointed a “Data Protection Officer”, this is a person who is responsible for overseeing and advising us in relation to our compliance with the GDPR and our compliance with this Interest Based Ads Privacy Policy. If you want to contact our Data Protection Officer directly, you can email: privacy@nativo.com.

What we do.

Nativo is an advertising technology provider. Our technology facilitates campaign planning, buying, management, delivery, optimization, measurement and analytics for advertisers and agencies and enables publishers to build, upload, host, serve, render and report on campaigns delivered to their web and mobile app properties.

Cookies.

The Website uses cookies, pixels, beacons and similar technology placed by us or third parties. The cookie we set (the “Nativo Cookie”) is a ‘persistent’ browser cookie. This means the Nativo Cookie remains on your device even after you close out of your browser or turn off your device. Nativo uses this Nativo Cookie and other similar technologies to help us store basic information about a user of the Website. This enables us to identify account holders, to optimize user experience on the Website, and to learn from and improve the Nativo technology and services, based on user behavior. Cookies may also be used by our third-party providers to track how you use the Website to target ads to you on other websites.

To be able to do the above, we need to collect:

  • A unique identifier (which is resettable) assigned to a particular cookie (a “Cookie ID”); and

  • information about your logged-in status, key value records and reference data regarding your interaction with the Website and our technology infrastructure and tools (collectively, “Passive Data”).

Effect of clearing your Cookies.

If you clear your cookies, it will delete the Nativo Cookie and therefore the Cookie ID will no longer identify a cookie on your device. This means the next time you visit the Website (unless you actively identify yourself by logging in), 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.

Expiry date of the Nativo Cookie.

The Nativo Cookie expires within 30 days following the time at which you last visited the Website.

What "Your Rights" are.

Opt out of Targeted Advertising

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.

Reset your Cookies.

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, if you clear your cookies, it will delete the Nativo Cookie and therefore the Cookie ID will no longer identify a cookie on your device. This means the next time you visit the Website (unless you actively identify yourself by logging in), 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.

Erasure.

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 privacy@nativo.com. If you do not have an account with us, we won’t have a way to identify your data by name in our systems, so, in such case, we may need to request certain information from you (such as the applicable Cookie ID from your system) to complete this request.

When we receive any 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.  

Access.

In certain situations, you may have the right to request access to the Personal Data associated with your account and/or your current Cookie ID. You can exercise this right by contacting our Data Protection Officer at privacy@nativo.com. If you don’t have any account with us, we don’t have a way to identify your data by name in our systems, so, in such case, 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 a request, pursuant to the previous paragraph, to provide you with the Personal Data associated with your account and/or current Cookie ID, we will try to comply with it as soon as reasonably practicable and (in any event) within one month.  

Correction and amendment.

If you have any account with us, you can correct your account information directly through your account, or by contacting your account manager at Nativo. However, if you believe we hold information about you that that you are unable to correct or amend through your account, we recommend you contact our Data Protection Officer at: privacy@nativo.com.

Right to object.

You 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.

You can also request that we ‘erase’ your Personal Data by following the steps outlined here.

You can also request that we stop sending marketing communications to your email address by using the unsubscribe link in our marketing emails or by contacting privacy@nativo.com.

Complaints.

If you would like to make a complaint regarding this Website Privacy Policy or our practices in relation to your Personal Data, please contact our Data Protection Officer at privacy@nativo.com.

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.

What Personal Data we collect.

All the Personal Data we collect from you is outlined in the table below.

Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it boils down to: information about an individual, from which that individual is either directly identified or can be identified.  

It does not include ‘anonymous data’ (i.e., information where the identity of an individual has been permanently removed).

However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).

Category of Personal Data collected What this means How we collect it
User Profile Records Cookie ID or Mobile Advertising ID (as applicable) and reference data tied to that Cookie ID or Mobile Advertising ID (i.e., previous history of interacting with site content and ads, including pages visited, ads viewed and frequency of ads viewed). To improve the relevance of the data we collect directly, we also supplement it with applicable Segment Data and Location Data we receive (see below). Via the Nativo Cookie or your Mobile Advertising ID when you visit a Publisher Property.
Log Records Log records contain transactional data describing details about a user session and ad impression, including timestamp, Cookie ID or Mobile Advertising ID (as applicable), user agent (device, browser, etc.), IP address, browser language, page visited, referring page, logged-in status and key/value records. Via the Nativo Cookie or your Mobile Advertising ID when you visit a Publisher Property.

How we use your Personal Data and why.

Purpose Category(ies) of Personal Data involved Why do we do this Our legal basis for this use of data
To provide you with access to the Nativo platform and tools Account Information Using this data helps us to provide you with a consistent experience. Our legitimate interests, as well as those of your organization. We need to provide you with access to administer our platforms and services and fulfil our contractual obligations to your organization as a service provider.
To provide reporting to your organization Account Information; Log Records We use your Account Information and Log Records to prepare reports to report on your use of our services. Our legitimate interests, as well as those of your organization. We need to be able collect information regarding your usage of our services to report back to your organization.
To learn about and improve the Nativo products and services. Account Information; Log Records We conduct analytics on user interaction with our services to facilitate improvement of our products and services. Our legitimate interests, as well as those of your organization. To provide you and your organization with the best experience from our services, we need to learn from how you interact with our services to enable us to make improvements.
Troubleshooting Log Records We use Log Records to track issues that might be occurring on our systems. Our legitimate interests, as well as those of your organization. We need to monitor and ensure the proper operation of our systems and services to administer our services and fulfill our contractual obligations to your organization.
To Contact you Account Information We use your Account Information to contact you regarding your account or our services, including to market our services to your organization. Our legitimate interests, as well as those of your organization. We need to contact your organization to administer our platform and services, to fulfill our contractual obligations, and to keep your organization informed about additional product and service offerings.
To Measure and Target Advertisements Account Information; Log Records Our third-party providers use information about your interaction with the Website to display ads for Nativo when you visit other properties on the Internet. Our legitimate interests, as well as those of your organization. Use of information about user interaction with the Website allows us to target advertising to users who have previously demonstrated interest in our services.

Who we share your Personal Data with.

The table below describes who we share your Personal Data with, what we share and why we share it.

We endeavor to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. In addition, where relevant, when we share Personal Data with third parties who are not directly subject to the GDPR, we make sure:

  • that party is either:
    • based in a country that has laws and institutions in place; or
    • part of a sector or participates in a framework (e.g., the EU-U.S. Privacy Shield), 

      that the European Union considers ensures that your Personal Data will be adequately protected; or

  • adequate safeguards are in place to ensure your Personal Data will be protected in line with the requirements of the GDPR.
Recipients Category(ies) of Personal Data we share. Why we share this Personal Data
Hosting Provider Account Information; Log Records Our services are hosted on our proprietary Nativo Platform. In order to host this service, we have to pass all the data we hold (including your Personal Data) to our hosting provider.
Reporting and Analytics Providers Account Information; Log Records We pass certain Account Information and Log Records (excluding your passwords and other security protocols) to our reporting and analytics providers to enable us to learn and improve the Nativo products and services
Affiliates Account Information; Log Records As a group of companies, we rely on affiliates to provide certain services to us. All affiliates are required to adhere to the descriptions and specifications set out in this Interest Based Ads Privacy Policy.
An acquirer or insolvency practitioner Account Information; Log Records. We may share Personal Data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding. All counterparties will be required to keep such information strictly confidential.
Law enforcement agencies and regulatory authorities Account Information; Log Records. We may share Personal Data as we believe necessary or appropriate:
• to comply with applicable laws; and/or
• to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements.

How we keep your Personal Data secure.

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.

How long we store your Personal Data.

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:

Category of Personal Data Retention period
Account Information We keep Account Information for a maximum of one (1) year from the date on which the organization account holder closes the applicable account or terminates its relationship with us.
Log Records We keep Log Records for a maximum of two (2) years from the data on which they are collected, after which they will be deleted permanently. The duration of this retention period is required to ensure that we are able to retain this information for as long as is needed to comply with our obligations to your organization (particularly audit requests) and for internal reporting purposes.

Our policy on children.

Our websites, products and services are not intended for use by children under the age of 16.

Nativo, Inc., and Nativo London Limited.