Personally Identifiable Information
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.
Vertical Mass 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 and conduct analytics on behalf of our Clients. Our Partners are typically sports, music or celebrity brands. For example, your favorite sports team may operate a Site or App that you visit regularly. Or perhaps a celebrity chef or iconic pop singer you like may have a Site that collects email addresses from you and other fans. Those types of brands may contract with Vertical Mass to host the data they collect from you and other Internet Users so that it may be bundled into profiles such as “enjoys pop music.” And those profiles may be of interest to advertisers looking to engage certain types of Internet Users - and offer them advertisements for products or services which may be of interest to them. More information on how Vertical Mass uses information below.
Personally Identifiable Information
We receive Personally Identifiable Information as well as Pseudonymous Data 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. We also enable Partners to manipulate the data they store on the Platform to create profiles for ad targeting, analytics and market research practices as described below.
How Does Vertical Mass Use Data Processed Via the Platform?
Vertical Mass enables Partners to do a better job of understanding who comes to their Sites and Apps and provides tools and services which enables our advertising Clients to leverage that data for advertising purposes. Although not all of these use cases are applicable everywhere we operate, here are the most common use cases for the data processed by Vertical Mass:
Interest-based advertising - 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 in general (“IBA”), please visit
http://www.aboutads.info or http://youronlinechoices.com/. Vertical
Mass collects Pseudonymous Data across multiple Partner Sites and
Apps in order to create ad targeting profiles. These profiles are
based upon the theory that regularly visiting a Site or App owned by
or including content about a music, sports, entertainment celebrity,
brand, or related company allows one to infer interest in certain
products or services.
Cross-device advertising - Vertical Mass also uses information
collected across Partner Sites and Apps to enable 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).
Social Media Buying - Our Data Partners may allow Vertical Mass to upload their User email lists onto Facebook and other social media platforms to enable our advertising Clients to reach their fans in those environments.
Market Research and Analytics - Vertical Mass may share data with
companies with large pools of consumers insights (e.g., Twitter,
Facebook or Oracle) to map Data Partner’s data against the high-level
segments created by those companies. For example, a brand may want to
understand. In some instances, our Data Partners may obtain
additional insights into the demographic composition of their
audience. Demographic insights include gender, age, and household
Ad Delivery and Reporting - Vertical Mass processes the Pseudonymous Data IBA profiles created by Data Partners and sends them to other ad delivery platforms such as Oracle Data Cloud, LiveRamp, AppNexus, or Google may send Pseudonymous Data segments into ad delivery platforms. As advertising messages are placed on third-party websites, Vertical Mass may receive additional Pseudonymous Data indicating how a particular ad campaign has performed and the time/date and website that a particular ad was serviced.
Cookies, Web Pixels and other Tracking Technologies
We offer multiple choice mechanisms for our use of information on the Platform. The opt-out is generally applicable to our interest-based advertising (“IBA”) and our cross-device advertising services although Internet Users located in the EU are afforded additional opt-out rights described below. You can opt-out as follows:
Opt-out from the Vertical Mass Platform via the industry opt-out pages. You may visit the self-regulatory program opt-out pages: http://www.aboutads.info/choices for the USA, http://www.youronlinechoices.com for the EU. Vertical Mass is one of the options listed and if you click on Vertical Mass, one of our opt-out cookies will be placed onto your browser which tells our systems not to process data associated with that browser.
If your browser is configured to reject cookies when you attempt to opt-out, we may not be able to set our opt-out cookie. Also, if you subsequently erase your cookies, use a different computer or change web browsers, you will need to opt-out again.
Opt-out from our Platform on mobile apps. We honor the mobile device settings for Android and Apple iOS devices. To exercise this opt-out, please visit the privacy settings of your Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android). For devices where we see that such a selection has been made, we will not use that information to serve IBA tailored ads or cross-device ads via our Platform.
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.
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.
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
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.
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 including sharing data of EU and Swiss individuals in response to lawful requests from public authorities to meet national security and law enforcement requirements, or (iii) protect or defend our proprietary rights.
In cases of onward transfer to third parties of the personal data of EU and Swiss individuals received pursuant to the EU-US and Swiss-U.S. Privacy Shield, Vertical Mass is potentially liable.
We will also provide an EU or Swiss individuals with opt-out or opt-in choice before we share their PII with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. If you’re located in the EU and seek to limit the use and disclosure of your information, please submit a written request to firstname.lastname@example.org.
Your Consent and Changes in This Policy
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 email@example.com and the company will process your request within a reasonable period of time after receipt. If you have an account with Vertical Mass, you may be able to access and correct your information and deactivate your account after logging into your account. EU data subjects may have additional rights as described below.
EU Data Subjects
In addition to the above referenced privacy practices, EU Data Subjects are granted additional privacy rights under the General Data Privacy Regulation (“GDPR”). For example, an EU (or Swiss) individual who seeks access, or who seeks to correct, amend, port over and/or delete inaccurate data, or who wishes to limit the use and disclosure of their personal data should visit our EU Subject Access Page http://site.verticalmass.com/sar/. Those rights also include the right to complain to EU Supervisory Authorities.
With respect to EU data subjects, personal data includes Pseudonymous Data such as an IP address, a mobile advertising ID or a cookie ID as well as PII. Where Vertical Mass receives from an EU data subject a request to cease processing of data via one of the choice mechanisms listed above, we will stop all data processing with respect to the opted out browser or device unless such processing is required by law. EU Data subjects wishing to object to our processing of data using the opt-out methods described above should note that the presence of an opt-out cookie tells our systems not to process your personal data.
Vertical Mass operates the Platform and provides the Services as a “data controller” under the GDPR. Although Vertical Mass generally processes data via the Platform and Services as directed by our data provider Partners, such Partners do not necessarily control which IBA profiles are provided to which advertising Client, as this is defined according to the terms of each agreement between Vertical Mass and each respective Data Partner. While Vertical Mass does create profiles of Internet Users, none of those profiles contain sensitive information, nor do the profiles present a “high risk” to the fundamental human rights of EU data subjects. As a result, we generally process the data via the Platform via our legitimate interest but may obtain a consent depending upon the type of data subject to processing and the policies of the applicable Partner providing such data.
Vertical Mass processes certain EU personal data provided by Clients and Data Partners under contractual necessity. For example, we require the billing details of our Clients located in the EU to process payment for the Services. We collect contact details from EU data subjects via our Website with consent. Our sales and marketing team may obtain additional contact details for current and prospective Clients via our legitimate interest where we think it is not overridden by the fundamental human rights of applicable data subjects.
Vertical Mass’ data protection officer and EU representative is Dr. Christoph Bauer, CEO at ePrivacy GmbH and he may be contacted at firstname.lastname@example.org.
For questions or concerns relating to privacy, please email email@example.com.
Alternatively, you may contact us at the address below:
Vertical Mass, Inc.
Attn: Privacy Officer
8923 Sunset Blvd.
Los Angeles, CA 90069
Enforcement and Privacy Complaints by EU and Swiss Citizens
We have further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
Last Updated: May 23rd, 2018