Privacy Practices for data collected from the Site and from Clients
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.
Privacy Practices for our Data Platform
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.
Personally Identifiable Information
We received Personally Identifiable Information as well as Pseudonymous Information 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 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
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
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 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.
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
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 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: June 15th, 2020