Privacy Policy | Media.net

Last Updated and Effective as of June 30, 2023

About Our Business

Media.Net Advertising FZ-LLC, working by itself or at times with its affiliated companies, (individually and/or collectively, "Media.Net," "we," "us" or "our") utilizes its digital advertising technology platforms (our "Technology") to assist with the selection, deliver and display of contextual (nonpersonalized) and targeted (personalized) advertising (our "Services") on behalf of the advertisers and their business partners and representatives (collectively "Buyers") on websites and properties (collectively "Seller Sites") owned and/or operated by entities (collectively "Sellers") that participate in our advertising marketplace.

When Does this Privacy Policy Apply?

This Privacy Policy applies:

When we collect information about consumers and other end users who interact with our Services and Technology on Seller Sites. Buyers and Sellers may be referred to as Partners. Click here to learn more.
When our Buyers, Sellers, potential Buyers and potential Sellers or other end users interact with our website located at www.media.net (our "Website"). Click here to learn more.

CONSUMERS AND SELLERS IN CALIFORNIA CAN CLICK HERE FOR MORE INFORMATION ABOUT THEIR PRIVACY RIGHTS.

IF YOU ARE SITUATED IN THE EU OR UK, CLICK HERE FOR MORE INFORMATION ABOUT YOUR RIGHTS UNDER EU/UK LAW.

NOTICE AT COLLECTION.

This describes the information we collect and the purposes for which we collect it. It covers both the information collected on our Website and through our Services from End Users (individuals who visit our Website or the Website of a Partner). The section of this notice that follows describes the information collected from our Partners.

I. Privacy Practices for End Users.

A. Information We Collect.

The Technology we use to provide our Services collects information from end users who visit one or more Seller Sites and/or our Website. While this information does not enable us to directly identify you (e.g., we do not receive your name, email address, etc.), it may be considered "personal data" or "personal information" under applicable privacy or data protection laws.

The information we may collect includes:

Online Identifiers. This includes your IP address, device IDs, cookie identifiers, advertising identifiers (IDFA and Google AdID), and other mobile identifiers.
Seller Site Information. This includes the web page URL or application through which you are viewing content, referrers viewability data, contextual categories, attributes pertaining to ad formats, click data, types of advertisements viewed and other data that the Seller Sites make available to us.
Device Information. It includes your browser, device model, device operating system, browser language and device type.
Location Information. It includes non-precise location information (city, country, zip code) but may also include precise location information if you have actively enabled location services on your device or a Seller partner sends it to us in their bid request (only in case of an opt-in).
Website Usage Data. This includes information we collect when you visit our Website about how you use the site. This includes information such as web page interactions, time spent on our pages and referral web pages.
Non-Cookie Identifiers. This includes the local storage or cache in your browser to collect information about you as you browse the Internet.

Information we receive from third parties: We may also receive information from third parties at the instruction of advertising partners or for the benefit of our Seller Sites that provide user demographics, behaviors or interests, obfuscated user identifiers such as hashed email addresses, user preferences on the ad experience and other information that may help make the ads more relevant.

Cookies. We use cookies, web beacons, mobile SDKs and other web tools ("Tools") to collect information regarding your behavior and usage patterns on our Website and on our Seller Sites. We use these Tools:

For Frequency Capping. To inform us if an advertisement has been served to the same computer or browser before, and if so, when the advertisement was served. This allows us to ensure that
For Research and Fraud Prevention. To conduct research and identify fraud and malicious activity.
For our Services. When you visit one of the Seller Sites we work with, we may assign your computer one or more cookies which enable us and our Buyers to deliver targeted advertisements to you on the Seller Sites. This form of advertising is called "behavioral advertising" or "interest-based advertising". We use cookies (e.g., Google’s advertising cookies) for this purpose. We believe that such advertising is helpful because you will see ads that are relevant to your interests. However, if you would like to opt-out of these interest-based advertisements, please see the section titled "Your Choices" below. When you conduct a search or visit Seller Sites that do not engage in interest-based advertising, we may deliver advertising based on search results or the content (context) of the page where the advertising appears. This form of advertising, which is not personalized, is often called “contextual advertising.”

Further, while we do not collect or process sensitive personal information, and our Technology does not deliver targeted ads based on actual or known medical conditions of users, or the treatments they use, nor does it market prescription drugs, we do generate and serve ads for non-sensitive health-related advertising that may be of interest to End Users: diet and fitness; doctors; health care professionals; health conscious; health and medicine; health and well-being; interest in health insurance; and pregnancy and in some cases health advertising that is based on the content of the page on which such ads appear (e.g., we may include an ad for a dietary supplement that complements an article regarding weight loss).

B. For What Purposes Do We Use Your Information?

We use your information in the following ways:

Monitoring for Click-Fraud and Other Advertising Fraud We collect information related to clicks, views, impressions, robotic mouse movement, non-human clicks, etc. and use it for fraud detection purposes.
Selecting and Delivering Advertising. We use information about you to select and serve advertising on our Publisher Sites. We present advertisements tailored to the context in which the ad appears (the page or the search results) or the interests you have shown; inferring eligibility of users for interest, general geographic and demographic-based segments; creating online advertising models through lookalike modelling or similar research methodologies.
Improving our Services. We combine information we collect from consumers with information we obtain from our Partners, ad networks, and/or other companies such as data providers, including our corporate affiliates in order to provide our services, conduct internal analysis in order to perform and improve our services.
Analytics. Providing insights and reporting back to our Partners, including statistical reporting in connection with the activity on a website or mobile application, optimization of location of ad placement, ad performance, reach and frequency metrics, billing, and logging ads served on a particular day to a particular website or application; evaluating the probability and nature of connections between devices.
Frequency Capping. Determining whether you have seen a particular advertisement before so as to avoid sending you duplicate advertisements.
Data Privacy. We respond to data privacy questionnaires, data subject access requests (DSAR).

Service Providers. We use third parties, , operational service providers and subcontractors (also called subprocessors) ("Vendors ") to operate and provide our services to Partners and to comply with legal and regulatory requirements. As necessary under this Privacy Policy, our Vendors are required to protect the information we provide to them in a manner that is consistent with this Privacy Policy. The services provided by Vendors include attribution, analytics, billing, fraud prevention, management of leads/campaigns, dispute resolution, cloud hosting, and technical support. When services are provided by Service Providers (processors or subprocessors) we contractually prohibit them from using any personal information except to provide services to us.
Buyers. We may share your information with Buyers to help them make decisions regarding buying advertising inventory on Seller Sites or to analyze the effectiveness and performance of advertising campaigns via our Services, explore business opportunities, and perform audits/research.
Sellers. We share information with our Sellers when we deliver ads on their Seller Sites. Sellers may use your information to make inferences about your preferences in order to serve more relevant advertising to you.
Legal, Government Contacts. We provide information to third parties for legal process (e.g., in response to a subpoena or civil or criminal investigative demand, court order, or a request from law enforcement or other government agency); to establish or exercise our legal rights; to defend against legal claims; to protect the security and integrity of our assets and business operations; or as otherwise required by law. In addition, we may disclose your information when we believe it is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Media.net, our Partners, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce the terms of service of our Website or other agreements or policies.
Acquisitions & Other Corporate Partners. We may also provide information to third parties in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

We may aggregate data so that it is no longer identifiable. That data may be shared with third parties for their business purposes. In addition to the foregoing, we may share your information with anyone provided we have your express consent..

II. Privacy Practices for Partners.

A. Information We Collect. We ask for information about you when you contact us for information about our Services, or when you register to participate in Media.net’s program for use of Media.net Technology. We may also collect information about you when you use our Website or interfaces. Information we obtain from Partners includes:

Contact information, which includes name, email and mailing address, and other information you may provide that allows us to contact you.
Government Identifiers, which include your driver’s license number or other identifiers.
Financial Information, which includes your bank account and other payment information required to collect or receive payments from you.
Online Identifiers, which includes your IP address, device IDS, cookie identifiers, and lo-information.
Device Information, which includes your browser and device type.
Location information, which you may provide to us or we may generate based on your IP address.
Usage Data, which includes your browsing or search history, web page interactions, referral web page, as well as information about how you use our Website.

Cookies. We use cookies, web beacons, and other web tools ("Tools") to collect information regarding your behavior and usage patterns on our Website, on our mobile applications (to the extent downloaded to your mobile device). We may use Tools to help our Website function, to analyze your use of our Website and/or reporting of our Services, and to understand our Website visitors and how the Website may be improved.

For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu.

B. How Do We Use Your Information? We use your information in the following ways:

Customer Service. We respond to general customer inquiries, troubleshoot technical challenges, up-sell, cross-sell, and provide payment payout support.
Marketing. We analyze publisher signups, affiliate signups, webinar signups and support our sales team. We may partner with third parties to collect information on our Website to deliver advertising that we believe may interest you based on your activity on the Websites. These third parties may set and access cookies on your computer or other device and may also use pixel tags, web logs, web beacons, or other similar technologies.
Providing our Services. We combine information we collect from consumers with information we obtain from our Partners, ad networks, and/or other companies such as data providers, including our corporate affiliates in order to provide our services, conduct internal analysis in order to perform and improve our services.
Compliance/Security. We verify signups through searching publisher email addresses through social media, perform website whois lookup to discover the domain name registration details, review IP addresses location. We also review the quality of traffic onSeller Sites. We review personal data protection online and offline threats on our infrastructure, network, networking equipment, computer systems, computer software, applications installed on the servers, access management, and mitigate the risks.
Data Privacy. We respond, and assist our client in responding, to data privacy questionnaires, and data subject access requests (DSAR)
Legal Obligations. We will use your information to comply with our legal obligations when we need to do so, including responding to requests from law enforcement; enforcing our terms and conditions and other legal rights; to protect our company and our employees, and to prevent or address suspicious, or potential illegal activity.

C. With Whom Do We Share Your Information? Subject to the section titled "Additional EU/UK Disclosures," we share the information we collect from and about you with certain third parties in the following ways:

Service Providers. We use third parties, Partners, operational service providers and subcontractors (also known as “subprocessors”) ("Vendors") to operate and provide our services to Partners and to comply with legal and regulatory requirements. As necessary under this Privacy Policy, our Vendors are required to protect the information we provide them in a manner that is consistent with this Privacy Policy. Service Providers include fraud prevention service providers and cloud hosting service providers. When services are provided by Service Providers (processors or subprocessors) we contractually prohibit them from using any personal information except to provide services to us.
Legal, Government Contacts. We provide information to third parties for legal process (e.g., in response to a subpoena or civil or criminal investigative demand, court order, or a request from law enforcement or other government agency); to establish or exercise our legal rights; to defend against legal claims; to protect the security and integrity of our assets and business operations; or as otherwise required by law. In addition, we may disclose your information when we believe it is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Media.net, our Partners, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce the terms of service of our Website or other agreements or policies.
Acquisitions & Other Corporate Partners. We may also provide information to third parties in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

We sometimes aggregate data so that it is no longer identifiable. We share aggregated information with third parties for their business purposes.

III. Your Choices. Your browser may give you the ability to adjust your settings to delete or disable cookies. Some mobile devices enable you to turn off or reset the mobile ad identifier. To opt out using these mechanisms, consult your device settings ("Opt out of Personalized Ads" on Android devices and "Limit Ad Tracking" on iOS devices).

To opt out of receiving interest-based advertising (including retargeting) from our Technology through the use of cookies in your current browser and for more information on what it means to opt out, please go to https://www.media.net/optout/. You can also opt-out of receiving personalized ads from us and other third-party advertisers and ad networks who are members of the Network Advertising Initiative ("NAI"). The NAI’s opt-out tool can be found here http://www.networkadvertising.org/choices/. More information about system privacy controls and instructions for opting out via your mobile device can be found at http://www.networkadvertising.org/mobile-choice. You can find out more about cookies and opt-out from cookies on www.aboutads.info/choices in the U.S. and www.youronlinechoices.com in the EU/UK. Please note that if you use a different web browser, computer, clear, block, delete or restrict your cookies after opting out, you may need to repeat your choices.
Some of our Partners have their own opt-out mechanisms that are linked from their sites or their online-posted privacy policies. You should review the privacy policies of those companies for these opt-out links if you no longer wish to receive targeted advertising from a particular company, or multiple companies. Google is one of our Partners. To learn more about how Google uses information it collects and/or to access its privacy policy, click here.

IV. Rights for California Consumers. The terms "Business Purpose(s)," "Personal Information," "Sell" (or "Sale"), "Service Provider(s)," and "Third Parties" have the meanings given in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act, ("CCPA"). These term references and disclosures describe the rights of California Consumers and provide information about the way we collect and use the personal information of California Consumers.

A. Collection of Personal Information.

Categories of Personal Information Collected. Unique device identifiers such as Cookies, Mobile Ad IDs (IDFAs for iOS and Android Ad IDs), Timestamps, User Agent Strings, IP addresses; General location data that is no more specific than a postal code, and web addresses (also known as "URLs"); Precise Location Information; Internet Activity Information, such as the website URL or mobile app you are browsing, web pages, content, and advertisements you view and links you click on, and whether you open, forward, or click the links in emails we send to you; and your browsing history. For our Partners, we collect: Identifiers such as your name, IP address, email address, and other account information, Unique Device Identifiers, Professional or employment-related information, Internet or other network activity, and Geolocation Information.
How Do We Use Personal Information. We use personal information to deliver and measure online advertising. For our Partners, we use personal information to market and provide our Services to you.
Categories of Sources from which Personal Information is Collected. Websites, mobile applications, advertising services, technology platforms. For our Partners, we collect information from you directly and from your use of our Website and mobile applications.

B. Disclosure of Personal Information. We share information as described above. This section also descrbes how we “sell” information, as that term is used in the CCPA. Categories of Personal Information Sold. Identifiers and inferences about website visitors.

Purposes for Selling or Personal Information. This data is used by our Advertisers and Partners for more tailored advertising, marketing, measurement, analytics, and research.
Categories of Third Parties to whom Personal Information is Sold. Advertisers and potential advertisers, , advertising agencies, marketers, technology platforms, Websites, and market research firms.
Categories of Third Parties to whom Personal Information was Disclosed (Sold or Shared) for a Business Purpose. Advertisers, advertising agencies, marketers, technology platforms, Websites and market research firms.

C. California Consumer Rights & Options. You have the right to access, correct, or delete Your Personal Information. We do not collect, use, sell, or share sensitive Personal Information, but if we ever do, you will have the right to tell us to limit its use. You may exercise your rights by submitting a privacy rights request here or by mailing us at privacy@media.net. You can opt out of sale or sharing of your personal information or exercise your "Do Not Sell or Share My Personal Information" right via Media.net’s opt-out tool here. We may set a non-unique cookie for the sole purpose of implementing your opt-out request. If you opt-out, you should not delete your cookies. If you delete your cookies after opting out, you will need to opt-out again. Please note that because most of the information we store can only identify a particular browser or device, we may not be able to provide you with copies of the personal information we hold if we cannot verify that it is yours. If you ask to delete your personal information, and we cannot determine which information is yours, we may treat your request as a request not to sell your information. We do not honor “Do Not Track” signals that are not officially recognized, but we will honor requests to opt out of sale sent from officially recognized global privacy controls. s. If an authorized agent submits a request on your behalf, we may require that the authorized agent provide written proof of their authority and we may separately verify your identity and confirm your request with you. If you have any questions about your rights or our disclosures, please contact our privacy officer per the details listed in the section titled "Contact Us" below. We will never discriminate against you because you have exercised these rights.

D. Rights of Consumers in Other U.S. States. If you are a Virginia, Connecticut, or Colorado consumer, you have the right to:

Confirm whether or not we are processing your personal information;
Access your personal information;
Correct inaccuracies in your personal information and the purposes for which we are processing it
Delete your personal information;
Obtain a copy of personal information you have previously provided to us;
Opt out of targeted advertising
Opt out of the sale of your personal data;
Opt out of profiling that would be used for significant decisions about you.

We will never discriminate against you because you have exercised these rights.

For certain requests, we may email you to confirm your identity. You can email us at privacy@media.net or make your request here.

V. Additional EU/UK Disclosures

A. Data controller. We are the data controller for all processing of l Personal Information collected through our Website. When we perform Services, we generally act as a data controller for the personal information we process, but we sometimes perform Services as a Processor for one of our customers. If you have a complaint, contact our privacy office per the details listed in the section titled "Contact Us" below. You also have the right to contact the data protection authority in your country.

Our EU-GDPR Representative is:
Rickert Rechtsanwaltsgesellschaft mbH
- MediaNet -
Colmantstraße 15
53115 Bonn
Germany
art-27-rep-medianet@rickert.law

Our UK-GDPR Representative is:
Rickert Services Ltd UK
- MediaNet -
PO Box 1487
Peterborough
PE1 9XX
United Kingdom
art-27-rep-medianet@rickert-services.uk

B. Legal Basis for our Processing of Your Personal Information. Below are the types of lawful basis that we will rely on to process your Personal Information:

Consent Consent means your freely given, specific, informed agreement to processing, shown by an affirmative action you have taken to communicate that you agree to your personal information being processed.We rely on Consent as the legal process for placing Tools on your browser or device, and for using them to store information on your device. We also rely on Consent as the legal basis for providing personalized advertising. When we provide Services that facilitate the delivery of personalized advertising, including the use of a your behavior across web sites and over time, or the development of a profile, we also rely on Consent.If we provide Services that make it possible to deliver personalized content to you, we will rely on Consent as the legal basis for the data processing required.For Website analytics we sometimes rely on Consent, and sometimes legitimate interest, depending on the data collected, and legal basis used by Sellers and Buyers
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). We also do not use your Personal Information where such interests are overridden by your data-protection interests or fundamental rights and freedoms.

We sometimes rely on our legitimate interest to use limited information (such as the content you are currently viewing, or your general geographic area) to provide basic ads to you. We do not believe that the use of this general information, which is not used to create a profile of you, presents substantial risks to you as a data subject. Any risks are outweighed by the benefits all parties derive from using basic advertising to support the delivery of Content.

When a Seller relies on its legitimate interest to process limited personal information for the delivery of basic ads, instead of obtaining your consent to do so, we too rely on our legitimate interest to perform the services that make it possible to provide basic ads. Similarly when a Seller uses limited personal information to select content, we too rely on our legitimate interest to do so. In both of these cases there is little risk to your rights and freedoms based on the limited personal information used.

We rely on legitimate interest to determine how many times an advertisement has been presented to you so that you do not see it too often, and to detect fraud so that Sellers only pay for legitimate advertising views. In both of these cases, the risk to the data subject based on the limited data used is smaller than the benefit that we, the Sellers, Buyers, and Partners, and you the data subject, derive from maintaining the usefulness and integrity of the advertising services we provide. Similarly, we rely on our legitimate interest to measure the performance of advertising. This too helps to ensure the quality and integrity of the advertising Services without adding any substantial risk to your rights and freedoms.

We rely on our legitimate interest to use the data we are processing when we perform Services to support, develop, and improve our Services. This does not present any additional risk to You and it helps us provide high quality Services that benefit you and the Sellers, Buyers, and Partners who rely on us.

You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by submitting a privacy rights request here or by contacting us at privacy@media.net
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. We rely on this legal basis for processing when we process the business contact information of Partners and clients to which we provide Services.
Comply with a legal or regulatory obligation means processing your Personal Information where it is necessary for compliance with a legal or regulatory obligation that we are subject. If we are required to provide personal information to a data protection authority or other legal authority, we do so in reliance on this legal basis for processing

C. Participation in the advertising industry Transparency and Consent Framework. We participate in the IAB Europe’s Transparency and Consent Framework (“TCF”), which allows you to better understand who is providing advertising services to you on the websites you visit, and gives you choices about who may process your personal information. We are a registered vendor (142) on the IAB Europe’s Global Vendor List (GVL).

D. Sharing of Personal Information. We share information as described above.

E. Additional EU/UK Privacy Rights. If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time. You have the right to request that we correct or erase your personal information. You also have the right to object to some or all of our processing and to object to automated decision-making with significant or legal effects. You can exercise your rights at any time by submitting a privacy rights request here or by contacting us at privacy@media.net.

F. Modifications to this Privacy Policy. We may edit, amend, modify, and update our Privacy Policy at any time and from time to time, by posting updated text on or links to our Website. When we make material changes to our Privacy Policies or our privacy practices, we will notify you by posting a notice on our Website or providing a notice to you. We display the Effective Date at the top of our Privacy Policy so that you will know when there has been a change in its effective date. By using our Website or our Technology or any Publisher Site using our Technology after the effective date, you will have agreed and be deemed to have agreed to comply with and be legally bound by the updated Privacy Policies.

G. Cross border transfers. Our Website and technology infrastructure is primarily maintained in the United States. If you are visiting our Website or Seller Sites from the regions with laws governing data collection and use that may differ from those in the United States, please note that you may be transferring your information to the United States and to other countries around the world. By using our Website, you agree to export and use your information within the United States and in other countries as specified in this Privacy Policy. If you are situated in the EU/UK, whenever we transfer your Personal Data out of the EU/UK, we ensure appropriate and suitable safeguards are used to protect your Personal Information . Where we use certain service providers, or provide Services ourselves, we may use specific contracts including data processing agreements based on the EU/EEA Standard Contractual Clauses to ensure these safeguards are in place.

VI. Sensitive Information. We ask that you not send us, and you not disclose, any sensitive personal information (e.g.,social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership) on or through our Website, or our Services or otherwise to us.

VII. Third Party Practices. This Privacy Policy applies solely to our privacy practices, and not to the practices of other parties. We encourage you to review the privacy statements of every website that you visit to be sure you understand the terms and conditions that apply to you from each of them.

VIII. Data Retention. We will only retain information relating to you for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for such information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements. Unless contrary to applicable laws, except with respect to information about our Partners with whom we have an ongoing relationship, our policy is to retain the non-aggregated information we collect for up to 24 months, after which the data is either anonymized or deleted from our systems. And as permitted by law, we may continue to retain aggregated information. In some circumstances, if you are an EU/UK data subject, you can ask us to delete your Personal Data by submitting a privacy rights request here or by sending us an email to privacy@media.net. We use commercially reasonable procedures to protect the personal information that we collect. However, we cannot guarantee the security of our databases, nor can we guarantee that personal information you supply won’t be intercepted while being transmitted to us over the internet.

IX. Children. Our Website is intended for an audience above the age of 18. Neither our Website nor our Technology / advertising services are developed for, intended for, or directed at, children, and we do not knowingly collect information from or about children under the age of 16 (or such other age as may be restricted under local law). If you believe your child has provided his or her information to us, please submit a privacy rights request here or contact us at privacy@media.net.

X. Contact Us. If you have any questions relating to this Privacy Policy, please contact us at privacy@media.net or mail us at:

Privacy Officer
Media.net Advertising FZ-LLC
2701 Aurora Tower, Dubai Media City
Dubai 215028, UAE