Vertical Mass – Privacy Policy

Vertical Mass, Inc. (“we,” “us”, “Vertical Mass” and “our”) is a data company that operates a data technology platform (the “Platform”) designed to help website, social, and mobile application operators (our “Partners”) manage, process and protect consumer data. The Platform also helps deliver targeted advertising messages for companies that are in the business of digital advertising (our “Clients”) from data we receive from our Partners. At Vertical Mass, we believe the privacy of Internet Users is of great importance. This Privacy Policy explains how we collect and use information and data when you use Vertical Mass’s website (“Site”). This Privacy Policy is subject to change at any time for any reason, so you are advised to consult this Privacy Policy regularly for any changes. Any changes will go into effect on the “last updated” date shown in the revised Privacy Policy. By continuing to use our Site, you consent to the revised Privacy Policy.

Privacy Practices for data collected from the Site

Personally Identifiable Information
We generally collect personally identifiable information (“PII”) via our Site only if you provide it to us by asking a question or registering with us. The PII may include your name, company information, postal address, email address and your telephone number. We use this PII to answer your questions and to facilitate your registration with us. We also collect PII from our Clients. For example, we need PII to enable Clients and Partners to login to the Site and for billing purposes. The PII collected via the Site is not shared, sold or rented to any other third parties unless otherwise specifically provided in this Privacy Policy.

Logfile Data and other pseudonymous information
We collect certain logfile data and other “Pseudonymous Data” (“Pseudonymous Data”) from visitors to our Site. On our Site, it may include such information as your Internet Protocol address, your User Agent, your browser and o/s type, referrer and your activity on the Site. We use this Pseudonymous Data to help us better understand who is visiting our Site so that we can better maintain the Site, consider new features or otherwise tailor or enhance our services.

Cookies and Web Pixels
For Pseudonymous Data that we collect on our Site, we employ the use of web “pixel tags” and/or “cookies.” Pixel tags are small bits of code that provide a method of delivery information on a webpage which allows the operator of the page or a third party to collect information about the users of the page. Cookies are small text files that are stored on the browser of your computer that uniquely identify your browser and provide information to the cookie sender. Many websites send cookies to the browsers that are visiting those sites, and many browsers are initially configured to accept cookies. For more information about cookies and pixel tags, please visit http://allaboutcookies.org. At this time, we do not recognize automated browser signals regarding tracking, including “do-not-track” signals.

Privacy Practices for our Data Platform

Vertical Mass is a data processor that collects or otherwise obtains data from websites and mobile applications operated by our Partners (the “Partner Sites and Apps”). We operate a platform (the “Platform”) that obtains data from Partner Sites and Apps in order to help target advertising messages on behalf of our Clients.

Personally Identifiable Information
We received Personally Identifiable Information as well as Pseudonymous Information (defined below) obtained from Partner Sites and Apps in order to buy media via Facebook and other social networking platforms.

Logfile Data and other Pseudonymous Information
We obtain Pseudonymous Data from Partner Sites and Apps such as IP address, user agent, browser type, computer (or mobile device’s) operating system, mobile o/s advertising ID (e.g., IDFA for iOS) or other pseudonymous identifiers. We also receive interest segments from our Partners so we can conduct interest based advertising via the Platform on behalf of Clients. Interest based advertising is the collection of data across multiple non-affiliated mobile sites and apps for the purpose of creating interest segments or profiles for ad targeting or content creation. For more information about interest based advertising (“IBA”), please visit http://www.aboutads.info. We also use this information to engage in cross-device advertising, which is the collection of data to create inferences that certain browsers and devices are related to each other (e.g., they belong to the same user or household). Finally, we receive ad delivery and reporting information about Client advertising campaigns such as the time/date that an ad was served.

Cookies, Web Pixels and other Tracking Technologies
We use cookies, web pixels and mobile advertising IDs on our Platform to help us better recognize Users over time and across multiple non-affiliated websites and apps. We also engage in ID synching (sometimes also referred to as cookie syncing) in order to help us link data from multiple advertising platforms and purchase ads in more than one place. For more information about cookies and web pixels, please visit http://www.allaboutcookies.org. We also use statistical ID’s, which are created when our Platform collects a user agent, browser fonts and similar information. We use the statistical ID’s on our Platform for select Partner websites in order to help us to more effectively recognize a particular browser or device on that Partner website.

Choice Mechanisms
We offer multiple choice mechanisms for our use of information on the Platform. The opt-out is applicable to our interest based advertising (“IBA”) and our cross-device advertising services. You can opt-out as follows:

Where we are able to detect the presence of an opt-out signal, we won’t engage in IBA or cross-device advertising via the Platform.

Privacy Practices for the Site and Platform

Data Security
We employ reasonable industry standard measures to protect against the unauthorized access, disclosure, modification or destruction of the PII and Pseudonymous Data. While we are committed to ensuring the security of such data, you should be aware that no protection measures can provide a 100% guarantee of security. Consequently, we do not warrant or guarantee the security of the data we collect.

Data Retention
We retain PII obtained via the Site for so long as necessary to answer your question or concern and then for a reasonable time thereafter. We rain PII collected from Clients and Partners for so long as we have a business relationship and then for a reasonable time thereafter or as required by law. We will retain Pseudonymous Data collected via the Platform for targeting purposes for 60 days and may hold it for operational purposes for up to 13 months. We will retain Pseudonymous Data collected via the Site for up to a year in order to ensure our Site is operating properly. After such time, we only retain such data on an aggregated basis for analysis.

Children Under 13 Years of Age
Vertical Mass’s Site, Platform and our products and services are not intended for persons under 13 years of age, and are not intentionally developed for or directed to children. We do not knowingly solicit or collect any PII from children under the age of 13, nor do we knowingly market our products or services to children under the age of 13.

Data Integrity, Purpose Limitation
We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use as described above.

Access and Deleting your PII
Although Vertical Mass doesn’t collect PII via our Platform, we offer the ability to access, update, correct, delete, or deactivate any PII that you have provided via the Site, or as a Client or Partner. Please send your request to info@verticalmass.com and the company will process your request within a reasonable period of time after receipt.

Disclosure of Information to Third Parties, Onward Transfer
Vertical Mass may share PII with trusted third-party partners such as Client and Partner billing and payment processing vendors and hosting providers for our Site, App and Platform. These third-party contractors are prohibited from using the information for purposes other than performing services for Vertical Mass.

The above notwithstanding, we may disclose any of the Pseudonymous Data, any PII or any other information we collect when we believe that we have a legal obligation to do so or to protect the safety, property or rights of Vertical Mass or of any third party. For example, we may disclose any of the above in order to (i) protect our rights and/or comply with a judicial proceeding, court order, or legal process served, (ii) for law enforcement or national security purposes, or (iii) protect or defend our proprietary rights.

If all or part of Vertical Mass is sold, merged, or otherwise transferred to another entity, the Pseudonymous Data and PII gathered by us may be transferred as part of that transaction. We will take reasonable measures to ensure that such data is used in a manner consistent with the Privacy Policy under which it was collected. If such a change in our corporate structure occurs, you will be notified as described below in the section entitled “Your Consent and Changes in this Policy.”

Disclaimer
We have no control over, nor any responsibility for, the privacy policies and/or content of any of third party websites or mobile applications. As a result, we disclaim any and all responsibility for, or affiliation with, any third-party cookies, pixels or practices. We do not authorize third parties to collect PII about your online activities over time and across different websites when you use our Platform or services. Similarly, our Client’s use of data obtained from the Platform is subject to the privacy policy of each Client.

Your Consent and Changes in This Policy
By visiting our Site, you hereby consent to our collection, storage, and dissemination of your data as described above. If we decide to change our Privacy Policy, we will post those changes in this location and other places we deem appropriate so that you are aware of such changes. We reserve the right to modify this Privacy Policy at any time, so please review it frequently.

Governing Law
Please be aware that your data may be transferred to and maintained on servers or databases located outside your state, province, or country. By using our website or services, you agree to the transfer of that data to the United States and that the applicable laws of the United States will govern the collection, use, transfer, and disclosure of your data. The laws in the United States may not be as protective of your privacy as those in your location.

Contact Information
For questions or concerns relating to privacy, please email info@verticalmass.com.
Alternatively, you may contact us at the address below:
Vertical Mass, Inc.
Attn: Privacy Officer
8923 Sunset Blvd.
Los Angeles, CA 90069

Last Updated: December 9th, 2016