WHAT INFORMATION DO WE COLLECT AND HOW IS IT USED?
Information You Voluntarily Submit to The Sites.
We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, register for access to the Services or use certain Services.
Personal Data that is collected when you voluntarily provide it in connection with the Sites, Ad Management (by potential Publishers that are submitting an application), Grow Social, Grow, or Trellis may include, but is not limited to, the below:
- Your name
- Your email address
- Your website URL and name
- Company name
- Phone number
- Billing information
- Information about your website’s analytics and platform
- Date of Birth
- In the case of Mediavine Direct, information about your campaign
Automatically Collected Information and Information We Collect from Others.
We may receive information about you from other trusted sources, such as information that validates or supplements information automatically collected. We may collect information from third-parties that assist us in serving targeted advertisements, as detailed below in the section about Ad Management.
Sites. When you use the Sites, we may log your IP address, operating system type, browser type, referring website, pages you viewed, and the dates/times when you accessed the Sites. We may also collect usage data, which is information about actions you take when using the Sites, such as links clicked.
Grow and Video Player. Third-party website owners that utilize Grow (“Grow Publishers”) or the Video Player may collect your IP address or your email address. If you consent to receiving content recommendations through Grow, we will collect your IP address. If you sign up to receive email newsletters from Grow Publishers, we may also collect a hashed, anonymized form of your email address. The hashed, anonymized email address may be used to create a match or link between this data and other anonymized data in third party databases or utilized by advertising partners. This link may be shared by our partners globally for the purpose of enabling interest-based content or advertising throughout your online experience (e.g. cross device, web, email, in-app, etc.) by third parties unaffiliated with our website.
If you choose to create an account with Grow using a magic link provided by Mediavine instead of creating a password, you must provide your email address. Mediavine does not collect or store any other information in connection with your use of the magic link.
If you provide your email address through Grow Automailer to sign up for a Grow Publisher’s mailing list, we will collect your email address.
Mediavine collects and processes the following data from Publishers to provide interest based advertising on Publisher websites.
- IP Address
- Operating System type
- Operating System version
- Device Type
- Language of the website
- Web browser type
- Email (in hashed form)
Please see the section about third-party providers to see how this data is used and shared.
What are cookies?
A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Sites and Service. The Cookie will collect information relating to your use of our Sites, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at our Sites and Service via a link from a third party site, the URL of the linking page.
In addition to Cookies, our Sites may use web beacons. Web beacons allow us to count the number of users who have visited or accessed the Sites and to recognize users by accessing our cookies. We may employ web beacons to facilitate Site administration and navigation, to track the actions of users of the Sites, to compile aggregate statistics about Site usage and response rates, and to provide an enhanced online experience for visitors to the Sites. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. A web beacon is often invisible because it is only 1 x 1 pixel in size with no color. A web beacon can also be known as a web bug, 1 by 1 GIF, invisible GIF and tracker GIF.
What are the different types of cookies and how do we use them?
Essential – These are Cookies which are essential for the running of our Sites and Services. Without these Cookies, parts of our Sites and Service would not function. These Cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.
Examples of how we may use essential Cookies include:
- Setting unique identifiers for each unique visitor, so that website numbers can be analyzed.
Functional – These Cookies are used to remember your preferences on our Sites and Services and to provide enhanced, more personal features. The information collected by these Cookies is usually anonymized, so we cannot identify you personally. Functional Cookies do not track your internet usage or gather information which could be used for selling advertising.
Examples of how we may use functional Cookies include:
- Gathering data about visits to our Sites and Services, including numbers of visitors and visits, length of time spent on the site, pages clicked on or where visitors have come from
- Eliminating the need for returning users to re-enter their login details.
Analytical Performance – Analytical performance Cookies are used to monitor the performance of our Sites, for example, to determine the number of page views and the number of unique users our Sites and Services have. We use this information to improve user experience or identify areas of the Sites and Services which may require maintenance. The information is anonymous (i.e. it cannot be used to identify you and does not contain personal information such as your name and email address) and it is only used for statistical purposes.
Examples of how we may use analytical Cookies include:
- Measuring users’ behavior
- Analyze which pages are viewed and how long for and which links are followed to better develop our Sites and Services
Advertising – Behavioral advertising Cookies, which may be placed on your device by us or our trusted third-party service providers, remember that you have visited a website and use that information to provide you with advertising which is tailored to your interests. This is often called online behavioral advertising and is done by grouping together shared interests based upon web browsing history. Your web browsing history can be used to infer things about you (e.g. your age, gender etc.), and this information may also be used to make advertising on websites more relevant to you. Although behavioral advertising Cookies can track your activity around the internet, these Cookies cannot identify you personally.
Examples of how we may use advertising Cookies include:
- To market to specific users across our Sites, the Publisher Sites and third party sites, so that we and third parties can target advertising to users that will be more relevant to users’ interests.
Third Party Cookies – You may notice on some pages of our Sites and Services that Cookies have been set that are not related to us. When you visit a page with content embedded from, for example, YouTube or Facebook, these third party service providers may set their own Cookies on your device. We do not control the use of these third party Cookies and cannot access them due to the way that Cookies work, as Cookies can only be accessed by the party who originally set them. Please check the third party websites for more information about these Cookies.
How can you manage or opt-out of cookies?
Cookies, including those which have already been set, can be deleted from your hard drive. You can also change the preferences/settings in your web browser to control Cookies. In some cases, you can choose to accept Cookies from the primary site, but block them from third parties. In others, you can block Cookies from specific advertisers, or clear out all Cookies. Deleting or blocking Cookies may reduce functionality of the Sites and the Services. To learn more about how to reject Cookies, visit www.allaboutcookies.org or go to the help menu within your internet browser. If you experience any problems having deleted Cookies, you should contact the supplier of your web browser.
Opting out of Analytical Performance Cookies
If you would like to opt out of Analytics Cookies, please do so by clicking on the links below:
Google Analytics: https://tools.google.com/dlpage/gaoptout
Opting out of Behavioral Advertising Cookies
If you would like more information about how to opt out of interest-based advertising in desktop and mobile browsers on a particular device, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#. You may download the AppChoices app at http://www.aboutads.info/appchoices to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.
HOW YOUR INFORMATION MAY BE USED
We, and our subsidiaries and affiliates (the “Related Companies”), may use the information collected in the following ways:
- To operate and maintain the Sites, Ad Management, Create, Grow Social, Grow, Trellis or the Video Player;
- To provide and maintain the Sites, Ad Management, Create, Grow Social, Grow, Trellis or the Video Player;
- To provide the Services;
- To gather analysis to improve our Sites, Ad Management, Create, Grow Social, Grow, Trellis or the Video Player;
- To send you promotional information, such as newsletters. Each email promotion will provide information on how to opt-out of future mailings;
- To send you administrative communications, such as administrative emails, confirmation emails, technical notices, updates on policies, or security alerts;
- To respond to your comments or inquiries;
- To provide you with user support;
- To protect, investigate, and deter against unauthorized or illegal activity.
Ad Management. In connection with the Ad Management services, we use the information collected to provide personalized advertisements to users of Publisher sites. We also monitor and provide information related to activities you may take in connection with the ads served through the Ad Management services, such as clicks or views. We will use your information to detect fraud and maintain security and to improve our services.
We (and the Mediavine Partners, as detailed in our section about Third-Parties below) may also use the information collected to link to other end user information we or other Mediavine Partners have independently collected to deliver targeted advertisements. We and other Mediavine Partners may also separately collect data about end users from other sources, such as advertising IDs or pixels, and link that data to data collected from Publishers in order to provide interest-based advertising across your online experience, including devices, browsers and apps. This data includes cookie information, device information, usage data, information about interactions between users and advertisements and websites, geolocation data, traffic data, and information about a visitor’s referral source to a particular website. Mediavine Partners may also create unique IDs to create audience segments, which are used to provide targeted advertising.
If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit https://thenai.org/opt-out/. You may also visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/# to learn more information about interest-based advertising. You may download the AppChoices app at https://youradchoices.com/appchoices to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out. For more information about cookies and how to disable them, you can consult the information at https://www.allaboutcookies.org/manage-cookies/.
Grow. In connection with Grow, Mediavine may utilize your IP address, email address and hashed, anonymized email address to display personalized ad content on any third-party website that you view while you are signed in to the Grow service. You may also receive email communications which may contain suggested personalized content that has been compiled based on content you may have viewed and/or favorited using Grow. If you consent to receive the suggested personalized content recommendations, Mediavine will also collect your IP address.
Non-Identifiable Data: When you interact with Mediavine through the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Mediavine may store such information itself or such information may be included in databases owned and maintained by Mediavine affiliates, agents, or service providers. The Services may use such information and pool it with other information to track, for example, user behavior in connection with personalized ads. It is important to note that no Personal Data is available or used in this process.
Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Services, Mediavine often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Mediavine may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Mediavine may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
Pseudonymized Data. Through certain of the Services, Mediavine may collect personal data that is subsequently pseudonymized. Mediavine has placed certain internal restrictions and security measures in place to maintain such data as pseudonymized.
Newsletters. On the Website, you may subscribe to our newsletter, which may be used for advertising purposes. All newsletters sent may contain tracking pixels. The pixel is embedded in emails and allows an analysis of the success of online marketing campaigns. Because of these tracking pixels, we may see if and when you open an email and which links within the email you click. Also, this allows the Website to adapt the content of future newsletters to the interests of the user. This behavior will not be passed on to third parties.
THIRD-PARTY USE OF PERSONAL INFORMATION
Mediavine may share your Personal Data with certain third as set forth below:
Third Party Vendors: We may share your information with third party vendors or service providers who help us provide the Services or the Sites, including database hosting and data processing services, and assist us in responding to requests by you for information that you request. Please see our list of data processors above for more specifics.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. We may also share Personal Data with potential buyers. Usually, information will be anonymized, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Third Parties with Permission: We may share your information with third parties to whom you ask us to send your information.
Agents, Consultants, and Related Third Parties: Mediavine, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Legal Requirements: Mediavine may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity or in connection with our own investigation of suspected or actual illegal activity, in which case we may (and you hereby authorize us to) disclose information without subpoenas or warrants served on us, (ii) protect and defend the rights or property of Mediavine, (iii) act in urgent circumstances to protect the personal safety of users of the Sites or the public, (iv) protect against legal liability including to resolve disputes, investigate problems, or enforce our Customer contracts.
The Sites currently uses the following third-party service providers:
- Google Analytics – this service tracks Sites usage and provides information such as referring websites and user actions on the Sites. Google Analytics may capture your IP address, but no other personal information is captured by Google Analytics.
- At this time, your personal information is not shared with any other third-party applications. This list may be amended from time to time in our sole discretion.
Except when required by law, we will not sell, distribute, or reveal your email addresses or other personal information without your consent; however, we may disclose or transfer personal information collected through the Sites or Services to third parties who acquire all or a portion of our business, which may be the result of a merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.
The following are a list of partners (“Mediavine Partners”) with whom Mediavine may share the following data when providing ad management services to third-party publishers utilizing Mediavine’s ad management services. Mediavine processes the following data from Publishers to provide interest based advertising on publisher websites.
- IP Address
- Operating System type
- Operating System version
- Device Type
- Language of the website
- Web browser type
- Email (in hashed form)
If you sign up for a Grow Publisher’s mailing list through Grow AutoMailer, your email address will be passed to Amazon Web Services, our database provider, but shall not be used for any other purpose other than providing AutoMailer. In some instances, the email address will be automatically provided, through an API, to the Grow Publisher’s mailing list provider, including, but not limited to, ConvertKit, MailChimp or MailerLite.
RIGHTS RELATED TO YOUR PERSONAL INFORMATION
Please note that while any amendments, corrections or deletions will be reflected in active user databases (as updated with a reasonable period of time), we may retain all Personal Data for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.
We may retain your Personal Data to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.
Please contact us at firstname.lastname@example.org to submit a request or obtain information regarding any of the above.
LEGAL BASES FOR PROCESSING DATA UNDER THE GENERAL DATA PROTECTION REGULATION (“GDPR”)
Below are the types of lawful basis that we will rely on to process your Personal Data:
- 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 Data for our legitimate interests. We do not use your Personal Data 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at email@example.com.
- 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.
- Comply with a legal or regulatory obligation means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject.
- Consent means where you have consented to a certain use of your Personal Data.
- Vital Interest means processing your Personal Data to protect the vital interests of the data subject or another natural person
How to File a GDPR Complaint.
We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
WHERE YOUR PERSONAL DATA IS HELD.
Personal Data may be held at our offices and those of our affiliates, parent or related companies, third party agencies, service providers, representatives and agents as described below (see “Third Party Use of Personal Information”).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below.
TRANSFERRING YOUR PERSONAL DATA OUT OF THE EEA
If you are located in the EEA or the United Kingdom, we will only transfer your personal data if:
- the country to which the personal data will be transferred has been granted a European Commission adequacy decision; or
- we have put in place appropriate safeguards in respect of the transfer, for example we have entered into EU standard contractual clauses and required additional safeguards with the recipient, such as pseudonymization or the recipient is a party to binding corporate rules approved by an EU or UK supervisory authority; or
- the data has been anonymized and cannot identify you.
California Residents: Pursuant to the California Consumer Privacy Act of 2019 (“CCPA”), you have certain rights with respect to your personal information. For the purposes of this section, personal information is used as defined in the CCPA. Mediavine reserves the right to verify all requests made pursuant to the CCPA.
Access and Disclosure
You may make a verifiable request that we disclose the categories of personal information we have collected about you, the categories of sources of the personal information we collected about you, the business or commercial purpose for collecting or selling the personal information, the categories of third parties with whom we share your personal information, our use of the personal information and if the personal information was disclosed or sold to third parties, including the categories of personal information sold or disclosed. You also have the right to make a verifiable request for a copy of the personal information collected about you for the twelve (12) months prior to the date of your request.
To see any categories of personal information we have collected and possibly sold in the last twelve (12) months, please refer to the section listed above detailing the personal information we have collected or sent to our partners. Not all personal information collected and transferred is considered a sale pursuant to the terms of the CCPA. We may transfer or sell your personal information to our partners who may, in turn, transfer or re-sell your personal information in order to provide the Services or to deliver ads tailored to your interests. In connection with Mediavine’s Ad Management Services, Downstream Participants, as defined in the iab’s First Amended Limited Service Provider Agreement, of which Mediavine is a signatory, may transfer or re-sell the personal information sold by Mediavine in connection with those services.
You have the right to opt out of the transfer, sale or re-sale of your personal information by us or a Downstream Participant through the Do Not Sell My information link found on each page of a Publisher’s website or you can click on the Signatory Identification List and opt out on each Downstream Participant’s website. Opting out may not mean that you will stop seeing interest-based ads based upon personal information utilized by Publishers or Personal Information sold before you exercised your right to opt out.
|Deletion Request Rights|
You have the right to request that Mediavine delete any of your personal information that we collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the personal information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Children Under 16
We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Your Rights
To exercise the access, disclosure and deletion rights described above, please submit a verifiable request to us by either (1) calling 888-705-1246; (2) emailing firstname.lastname@example.org or sending us a written request to 160 W. Camino Real #504, Boca Raton, Florida 33432 Attn: CCPA.
You may only make a verifiable request for access or disclosure twice within a 12-month period. You may also make a verifiable consumer request on behalf of your minor child. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
To respond to your request or provide you with personal information, Mediavine must verify your identity or your authority to make the request. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request. For instructions on exercising sale opt-out rights, please refer to the Do Not Sell My Personal Information Link provided on each Publisher’s website.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing us at email@example.com Consumers who opt-in to personal information sales may opt-out of future sales at any time.
We will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
HOW LONG WILL YOUR PERSONAL INFORMATION BE KEPT
We will keep your personal information while you have an account with us or we are providing
products or services to you. Thereafter, we will keep your personal information for as long as is
• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly; and
• To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out
When it is no longer necessary to retain your personal information, we will delete or anonymize it.
SENSITIVE PERSONAL INFORMATION
Links to Other Websites
If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send nonpublic personal information, such as passwords, social security numbers, or bank account information, to us by email. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of most emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as customer service communications.
Other Terms and Conditions
Your access to and use of the Sites and Services may also be subject to any separate agreements or terms and conditions you have signed or agreed to with Mediavine. Please refer to those agreements as needed.
Access to Information; Contacting Mediavine:
To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Sites. To unsubscribe from any communications, please contact us at the email address below.
You may contact us as follows:
Last updated: May 9, 2022