Decibel runs a technology buying platform for digital media. The Decibel technology allows our customers to buy ad space on websites, mobile apps, video players, and other devices. When ad space is bought or sold our technology fulfills the transaction by delivering the ad to Internet users who visit that site, apps, or device. Generally, an Internet user’s computer or mobile device comes into contact with Decibel technology when a user views an ad delivered by our technology or clicks or taps on the ad to visit the advertiser’s website or app.
Privacy Practices for Our Technology
Decibel’s works with a variety of adtech vendor(s) and third parties to deliver ads. The direct vendor(s) we interact with are members of the Network Advertising Initiative (NAI) and we adhere to the NAI Codes of Conduct. To learn more about the NAI and the Code of Conduct please visit: http://www.networkadvertising.org/code-enforcement/code.
What Information We Collect, The Purpose of Collection and Use
The Decibel technology collects information on behalf of its customers to help target online advertising to you based on your interests. This information may include cookie and mobile advertising identifiers, your IP host address (which we truncate when we know the user or the ad request is subject to GDPR or CCPA), your browser type (e.g. Chrome or Firefox), the date and time of the ad request, advertiser pages viewed, your operating system (e.g. Macintosh, Windows, Android, OSX), the URL or App you are using, and your Internet Service Provider (e.g. Verizon or Comcast).
We collect contact information through our technology from customers, vendors and distributors who wish to obtain information or support, or to obtain access to our platform. Contact information includes: first name, last name, email address, job title, name of the organization, country, state/region and phone numbers (cell and/or landline). This contact information is used by our sales, support and operations teams to contact our customers, vendors and distributors for the purpose of providing the requested information or support, communicate via email regarding our current and future offerings, and/or provide and receive feedback on our Services.
Like most organizations, we rely on automatic data collection technology to collect information such as your IP host address, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, number of links you click, search terms, and other data. We use this data to analyze the use of and improve our Services.
To provide relevant ads to users on mobile devices we may also collect the following mobile specific information: device type, make and model, operating system, mobile advertising identifiers, operating system device identifier (For example, IDFA for iOS and Android ID for Android) and information about the apps you use. We may also use the GPS location of your device if you have opted-in to provide it to one of the publishers or ad exchanges who make digital advertising inventory available through the Services as further described below under “Location Tracking.”
Your iOS mobile device may provide a “Limit Ad Tracking” setting and other settings that allow you to control the data that applications may use for location and interest-based advertising. On Android devices, your settings may allow you to “Opt out of Interest-Based Ads.” When you have opted out using this setting on a device and that information is passed to Decibel, Decibel will not use your unique device identifier to target ads to you or place you in segments for future marketing. Learn more about setting your privacy preferences on mobile devices at the NAI’s Your Options page.
We also use pixel tags, which are small, invisible 1×1 images on a web page. Pixel tags allow us to set, read and modify cookies when you visit the websites or apps of our partners.
When you opt out, we will place an opt-out cookie on your computer. This cookie tells us not to collect your information to tailor our online advertising campaigns. Please note that opt-out cookies are necessary to fulfill your opt-out requests. If you block, delete or restrict cookies in any way, your opt-out request will not work. Also, opt-out settings are specific to each browser or device, so you will need to set your opt-out preference for each one, and if you use a different computer or Internet browser, you may need to renew your opt-out choice.
Decibel may receive latitude and longitude of mobile users from publishers or ad exchanges. We use such data for targeting ads and evaluating their success, and we may share it with third party companies acting as controllers (See, Onward Transfers to Third Parties). This information is also maintained in our logs in accordance with our data retention policy (below). In the European Union, when we receive precise location information and we know the user or the ad request is subject to GDPR, we truncate the location data to three decimal places to be less precise before storing such data.
Information We Receive from Third Parties
Use of Cross-Device Linking
Onward Transfer to Third Parties
Business Transfers. In the event of a merger, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality.
Disclosure to Public Authorities. We are required to disclose the information that we have collected in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
Access to Personal Information
How We Protect Your Information
Links to External Websites
Important Notice to All Non-US Residents
Our computer servers that store personal information for our Services may be located in the US. If you are located outside of the US, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to and processed in the US. We comply with all applicable laws to protect the security of data during international transfer, for instance by using EC standard contractual clauses and appropriate supplementary measures when a transfer is made to a third party country that is not considered adequate by the EU Commission or the UK.
We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We commit to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) to address any privacy-related complaints from you. If you do not receive timely acknowledgment of your privacy-related complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.
Important Notice for Residents of the European Economic Area, UK and Switzerland
With regard to the General Data Protection Regulation (“GDPR”), Decibel’s role depends upon the personal data we collect and the circumstances under which we process it.
Lawful Basis for EU Data Processing
We process personal data in several ways, each with respect for the privacy rights of individuals. When we are acting either as the data controller or data processor for our customers, we rely on the following lawful bases for our processing:
Performance of contract. We need to collect and process personal data in order to deliver our Services as required by our contracts with our customers.
Legitimate business interests. We may use personal data for our legitimate business interests to administer our platforms, ensure the integrity of our transmission network, and to enforce our legal and contractual rights and obligations, for example, by analyzing data for signs of fraud.
Data Subject Consent. To the extent our we or our customers need to collect and share, or to allow us to facilitate the collection and sharing of personal data to enable our Services, we or our customers may do so after providing necessary privacy notices and obtaining required consents.
California Privacy Rights
California residents have the right to be informed about our practices regarding the collection, use, disclosure, and sale of personal information. Specifically, under the California Consumer Privacy Act (“CCPA”), California consumers have the right to request disclosure and deletion of their personal information, the right not to be discriminated against for exercising one of their California privacy rights, and the right to opt-out of the sale of their personal information by a business.
In the, WHAT INFORMATION WE COLLECT, THE PURPOSE OF COLLECTION AND USE section of this policy, we describe in detail the information we collect from consumers and the purposes for which we use this information, which includes the information we have collected in the twelve (12) months preceding the date of this update to our policy. The categories of personal information we collect and the business purposes for such information generally include: (1) contact information from our customers and others who have authorized access to our Services, which we use to provide and share important information about our Services, and for our marketing efforts to customers; (2) analytics information, which helps us understand and improve our and our customers’ websites, marketing activities and services; (3) identifiers, such as cookie and mobile advertising identifiers, which we use in our Services in connection with pixel tags to help our customers delivered tailored advertising to consumers; (4) location information, which we use in our Services to deliver targeted, location-based ads for our customers; (5) information we obtain from third parties, such as cross-device linking data and audience data, which we use in our Services to help our customers buy digital media and deliver targeted ads to consumers. This third party information may include information about consumer preferences and behaviors that third parties collect to create profiles about consumers reflecting their preferences, characteristics, psychological trends, predispositions, behaviors, attitudes, intelligence, abilities and aptitudes.
The categories of sources from which we collect personal information are (1) our customers, who are advertisers that buy and publishers that sell digital advertising for the purpose of delivering ads to consumers; (2) our Services, typically when we encounter a consumer’s cookie or mobile advertising identifier while providing our Services; and (3) third parties who provide or sell data that helps our customers with their marketing efforts or helps us to deliver our Services.
In the, Onward Transfer to Third Parties section of this policy, we describe in detail the information that we disclose or sell to third parties for a business purpose. The categories of such personal information generally include: (1) reports to customers about their use of our Services, such as whether their targeted ads have reached the intended consumers; (2) certain information described in the previous paragraph, which we provide to our customers and third parties who provide our customers with related services, or to publishers who sell digital advertising media to advertisers. We have no actual knowledge that we sell personal information of children under 16 years of age.
Your California Privacy Rights Under CCPA
If you are a California resident, CCPA provides you the following rights. We will honor requests to exercise these rights to the extent required by law and within the time provided by law. In doing so, where we are acting as a service provider to our customers or other businesses in our processing of your personal information, we may refer requests to access or delete personal information to those businesses.
Right To Access And Information Regarding Personal Information
You have the right to request that we disclose to you the categories and specific pieces of personal information about you that we have collected or sold, the sources for such information, and our business purpose. These disclosures are in the preceding “CCPA Disclosures” section of this policy. We will deliver personal information that we are required by law to disclose to you in the manner required by law within 45 days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law. We may deliver the personal information to you electronically or by e-mail at your option. If electronically, then we will deliver the information in a portable and readily usable format that allows you to transmit the information from one entity to another without hindrance.
Right To Deletion Of Personal Information
You have the right to request that we delete personal information about you that we have collected from you. We will delete such personal information except where a legal exception applies. In cases where we do not delete your data as requested, we will notify you of the categories of data we did not delete and why.
Right to Opt-Out from Sales of Personal Information
Our Services include the transfer of personal information to our customers and other participants in the digital advertising market that may qualify as sales of personal information under CCPA. You have the right at any time to direct us not to sell your personal information, which is known as your right to opt out. See the Requests to Exercise Your California Privacy Rights section below to opt-out.
In other cases, Decibel collects and processes personal information as a service provider for website publishers and other service providers that they use. If they inform us that you have exercised your right to opt-out of their sale of personal information, we comply with such requests in accordance with CCPA.
Right to No Discrimination
We may not discriminate against you because of your exercise of any of the foregoing rights under the CCPA. Decibel does not discriminate in response to privacy rights requests from California consumers.
Requests to Exercise Your California Privacy Rights
If you are a California resident, you may request to exercise the foregoing rights by:
Submitting a request to email@example.com
California consumers may also authorize your agent to make a request on your behalf. If you use an agent, you must instruct them to contact us as instructed above. Please note that we may take steps to verify your or your agent’s identity, as well as your agent’s authority to act on your behalf, before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. For example, CCPA requires us not to disclose or delete personal information if we cannot verify the identity of the person making the request, including verifying that your agent is acting on your behalf. We may also limit our response to your exercise of the above rights as permitted by law.
California “Shine the Light” Law
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact Decibel via email at firstname.lastname@example.org. Except for the methods for managing your personal information described in this policy, Decibel does not monitor, recognize or honor any opt-out or do not track mechanisms, including general web browser, “Do Not Track” settings and/or signals.
You may contact us regarding these California privacy disclosures as noted in the Contacting Us section of this policy.
We retain the information that is reasonably linkable to a device and collected for ad targeting and/or ad delivery and reporting only as long as is necessary for running advertising campaigns and for no longer than 13 months. We keep opt-out information for longer than this period so that we can continue to honor opt-out requests. Aggregated data, such as the results of advertising campaigns or the amount spent on different inventory sources, may be retained indefinitely provided that the data is not reasonably linkable to a device. Our cookie’s duration on your browser may exceed 13 months, but no data associated with that cookie will do so.
Changes to Our Policy
Should you have any questions in regards to this policy or Decibel’s privacy practices, please contact us at the following email and they will be more than happy to clarify and assist you in any way possible: email@example.com.
Updated: March 4, 2023