Our Privacy Notice

Last Updated: October 15, 2020

PRIVACY COMMITMENT

Protecting privacy is important to us. This Privacy Notice explains how we collect, use, and share the information that we collect about individuals who visit the websites, mobile apps, and other digital media properties (collectively “Digital Properties”) of our Marketing Partners (defined below), as well as the options available to such individuals. In certain parts of this Privacy Notice, we refer to such individuals as “you”. We’ll try to make this all as clear and as simple as possible, but if you have questions, you can contact us [email protected], and we’ll be happy to help.

WHAT WE DO

Compulse provides a platform for advertisers to find inventory that suits their needs and reach individuals who may be interested in their products or services. For companies, we help get advertisements in front of individuals who are most likely to find the advertisements interesting. For individuals, we try to place advertisements that are the most relevant and useful to them.

In order to do this, we collect and analyze information about individual interests. Our main source of information is from our Cookies and Tags (more on that below) on our Marketing Partners’ Digital Properties. In some cases, our advertising customers may also provide us with Platform Data that they have independently collected or we may purchase Platform Data from commercially available sources for the benefit of our customers. With this information, we try to understand the types of products or services that users individuals might find interesting so we can select the most relevant advertisements to be displayed to them and perform the Advertising Services described below.

SCOPE OF THIS PRIVACY POLICY

This Privacy Notice covers the information that we collect or receive, through our Advertising Services (defined below). It does not address any information collected from or submitted to the Compulse website.

SOME HELPFUL TERMINOLOGY

We use some words and phrases in this Privacy Notice that are unique to our business and/or unique to the online advertising industry. Here are some of the key terms that you’ll need to know to make it easier to review this Privacy Notice.

• Marketing Partners refers to the Digital Property operators, developers, and related partners that allow us to collect information about the individuals who use their Digital Properties. Many of our Marketing Partners have installed Compulse Cookies and Compulse Tags (defined below) on their Digital Properties which allow us to collect the information to provide the Advertising Services they have requested.
• Advertising Services refers broadly to the entire set of services that we provide for our advertising customers (the companies that pay us to understand individual interests and place their advertisements), and Marketing Partners, such as the collection of information about individuals who visit the Digital Properties of our Marketing Partners, the analysis of that information, the provision of that information back to our Marketing Partners, and the selection and placement of optimal advertisements based on that information. Our Advertising Services fall under the umbrella of what is commonly referred to as “interest-based advertising” or “personalized advertising.” You can learn more about interest-based advertising at the following links: http://www.aboutads.info/consumers; http://www.networkadvertising.org/understanding-online-advertising; and http://www.youronlinechoices.com.
• Cookies Cookies are small files containing a string of characters that are sent to your computer when you visit a website. When you visit the website again, the cookie allows that website to recognize your browser and the website that places the cookie has permission to read its contents each time you visit the website. Cookies may store user preferences and other information. You may be able to adjust your browser to refuse all cookies or to indicate when a cookie is being set. However, some website features or services may not function properly without cookies. Compulse Cookies can be identified by their URL: compulse.com.
• Tags (aka pixel tag or becon) is a piece of code embedded on a Digital Property that collects information about individual’s engagement on that Digital Property. The use of a Tag allows us to record, for example, that an individual has visited a particular page or clicked on a particular advertisement. When a user views a Digital Property with a Compulse Tag, our servers (located at compulse.com) are notified, and we are able to collect information about what the user does on the Digital Property.
• Platform Data refers to information about individuals that might serve to identify their or their household’s computer device (e.g., a phone, tablet, or connected TV), and/or browser. For example, we consider the following types of information to be Platform Data: Internet protocol (IP) address, device or browser settings, Cookie identifiers, mobile carrier, mobile advertising and other unique identifiers (“MDI”), OTT Identifiers for Advertising (“IFA”), details about your browser, operating system or device, geo-location information, Internet service provider, pages that you visit before, during and after you use Digital Properties, information about the links you click, and other information about how you use the Digital Properties. Note that we may use pseudonymous identifiers, such as a randomly generated Cookie identifier, to consolidate information that we’ve collected about you across different Cookies in a practice that is commonly referred to as “cookie syncing.” Information we collect may be associated with other identifiers and devices in a practice known as “cross-device tracking.” Depending on where you live, some Platform Data may be considered “personal data” or “personal information.”

INFORMATION COLLECTION AND USE

Some of our Marketing Partners have Compulse Tags installed on their Digital Properties and Compulse Cookies that launch upon viewing of their websites. When you visit one of our Marketing Partner’s Digital Properties, the Marketing Partner permits us to collect certain information about what you do on that Digital Property, such as, IP address, the pages you visited, products you viewed, browser information and other Platform Data. In addition, our Marketing Partners and advertising customers may provide us with Platform Data that they have independently collected. At the instruction of our customer, we may also purchase Platform Data from commercially available sources. We use this information according to their instructions, which may include determining what advertisements might be interesting to you and if we should serve you an advertisement. We may also engage in frequency capping of ads (which stops you from seeing the same ad too many times); performance analytics; auditing; detecting security incidents; protecting against malicious activity; debugging; fraud detection; developing new products and services; administrative and support services; ad reporting and conversions; and location-based advertising where permitted by law.

INFORMATION SHARING

Information Shared With Our Service Providers

We may share Platform Data work with third party service providers to provide and improve the Advertising Services and our software. These service providers may only use this information as we instruct them.

Information Shared with Marketing Partners and Advertising Customers

The Platform Data that we receive from our Marketing Partners’ Digital Properties may be shared back with the Marketing Partner that permitted us to collect the Platform Data. Thus, if one of our Marketing Partners allows us to collect information about individuals who use or visit its Digital Property, that Marketing Partner may also ask us to send that information back to them for their own purposes. In some cases, we may also share some Platform Data with our advertising customers, attribution and analytics partners, and other related parties to provide the Advertising Services.

Information Shared in Aggregated or De-Identified Form

We may use Platform Data to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, de-identified information about the computer or device from which you access Digital Properties, or other de-identified analyses we may create. De-identified or aggregated information is not personal information, and we may use such information in a number of ways, including to provide the Advertising Services, research, internal analysis, analytics, and any other legally permissible purposes. De-identified or aggregated data may be shared with our advertising customers, business partners, Marketing Partners, and other third parties.

Information Shared in a Change of Ownership

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then the information we have collected may be sold or transferred as part of such a transaction as permitted by law and/or contract.

Information Disclosed for Our Protection and the Protection of Others

It is our policy to protect you from having your privacy violated through abuse of the legal system, whether by individuals, entities, or governments, and to contest claims that we believe to be invalid under applicable law. However, it is also our policy to cooperate with government and law enforcement officials and private parties where appropriate. Accordingly, we reserve the right to disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary: (i) to satisfy or comply with any applicable law, regulation, or legal process or to respond to lawful requests, including subpoenas, warrants, or court orders; (ii) to protect our property, rights, and safety and the rights, property and safety of third parties, or the public in general; and (iii) to prevent or stop activity we consider to be illegal or unethical.

YOUR CHOICES

You can restrict our collection and/or use of Platform Data by following the instructions below:

Website: If you are browsing the web and prefer not to receive relevant advertising from our advertising customers, you can request to opt out from our services (click here to see details). We will then place a cookie on your browser that identifies you as having opted out. Remember that opting out is browser-specific. So, if you have multiple browsers or multiple devices you use to access the internet, you’ll need to opt out from each device or browser.

Mobile Applications and other Digital Properties: If you are using a mobile application or other Digital Property and would prefer not to receive relevant advertising from our advertising customers, you can limit ad tracking by adjusting the settings as each application and/or device may permit.For mobile application users, instructions for how to limit ad tracking can be found here: https://www.networkadvertising.org/mobile-choice. In addition, users of “smart” or “connected” TVs may opt out of some OTT advertising by visiting optout.tv and following the opt out instructions. Please note that in most cases you must separately opt out on each device.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from some data partners and advertising partners that participate in self-regulatory programs. You can access these and also learn more about interest-based advertising, consumer choice, and privacy at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu, https://youradchoices.ca/choices, and www.aboutads.info/choices.

Please note that even if you opt out, you will continue to receive generic ads.

OUR LEGAL BASES FOR PROCESSING

Legitimate Interest. If you are located in the European Economic Area (the “EEA”) and Compulse is a controller of your personal data, our legal basis for processing your personal data depends on the data concerned and the specific context in which we collect or use it. Normally, we rely on our and our Marketing Partners’ legitimate interests, except where these interests are overridden by your fundamental rights and freedoms. These legitimate interests may include:

• Providing and operating Compulse and the Advertising Services;
• Compiling statistics about the advertising transactions occurring through our Advertising Services;
• Conducting research and development for our own internal business purposes;
• Analyzing and reporting on campaign and ad performance;
• Investigating, protecting against and deterring malicious activity, fake traffic or fraudulent, unauthorized or illegal activity.

Consent. In some cases, we may rely on your consent which Marketing Partners obtain from you when you visit their Digital Properties. If our processing of your EEA personal data is based on your consent, you may withdraw your consent at any time.

Legal Obligation. In limited scenarios, we may also have a legal obligation to collect personal data from you.

If you have any additional questions about our legal bases for processing EEA personal data, please contact us as set forth below.

INDIVIDUAL RIGHTS

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your Platform Data; (ii) obtain access to or a copy of your Platform Data; (iii) receive an electronic copy of Platform Data that you have provided to us, or ask us to send that information to another company; (iv) object to our processing or restrict our uses of your Platform Data; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed Platform Data; and (vi) request erasure of Platform Data held about you by Compulse, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws.

To protect your privacy, Compulse will take steps to verify your identity before fulfilling your request. Please note that because Platform Data, by itself, cannot be used to identify an individual in the real world, we may not be able to authenticate your identity. As a result, we may not be able to fulfill your request.

SUPPLEMENTAL CALIFORNIA PRIVACY NOTICE

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Compulse has collected about them and whether Compulse disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.

Additional Privacy Rights for California Residents

“Sales” of Personal Information under the CCPA. For purposes of the CCPA, Compulse does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth below. We will process such requests in accordance with applicable laws.

DATA RETENTION

We store the Platform Data we receive as described in this Privacy Notice for as long as necessary to fulfill the purpose(s) for which it was collected, provide the Advertising Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

THE SECURITY OF YOUR INFORMATION

Compulse takes steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any Platform Data. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

WHERE WE KEEP YOUR INFORMATION

Platform Data may be transferred, processed and stored outside of your state or country (including in the United States), where the privacy laws may not be as protective as those where you live.

THIRD PARTIES WE WORK WITH

This Privacy Notice does not cover the privacy practices of the advertising customers, Digital Properties, and Marketing Partners we work with. The advertising customers, Digital Properties, and Marketing Partners have their own terms of use and privacy policies, and we encourage you to read those terms and policies.

OUR POLICY TOWARD CHILDREN

Our Advertising Services are not directed to children under 16 (or other ages as required by local law), and we do not knowingly target or collect any information from children. Nor do we collect information from Digital Properties that are directed to children. If we learn that we have collected Platform Data from a child, we will delete that information as soon as possible.

SUPERVISORY AUTHORITY

If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your EEA personal data violates applicable law.

CHANGES TO THE PRIVACY NOTICE

We may revise this Privacy Notice from time to time. If we make any material changes to this Privacy Notice that effect personal information previously collected about you, we’ll post the changes on our website.

CONTACTING US

If you have any questions about our Privacy Notice, please send us an email at [email protected].