Ads Interests Manager Privacy Notice Protecting personal information is a core TrustArc value. TRUSTe is now TrustArc, and TRUSTed Interests is now Ads Interests Manager. This Privacy Notice has been updated to reflect both corporate and product name changes. The policies and practices described here have not changed. Certification programs and dispute resolution services are offered by TRUSTe LLC (“TRUSTe”), a subsidiary of TrustArc Inc, and powered by the TrustArc Platform. Effective November 27, 2017 This Privacy Notice describes how TrustArc Inc and and its subsidiaries and successors worldwide, including without limitation, its subsidiary in the Philippines and TRUSTe LLC. (collectively “TrustArc”) uses the information it collects from your desktop web browser or mobile device, including both applications and web, and information that you provide about your advertising interests. You provide or make this information available to TrustArc by accessing Ads Interests Manager through an ad provided by one of TrustArc’s advertising or data partners. EU-U.S. and Swiss-U.S. Privacy Shield Participation TrustArc participates in the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks (“Privacy Shield”), and has self-certified with the Department of Commerce that we adhere to the Privacy Shield Principles. TrustArc is committed to applying the Privacy Shield Principles to all personal information received from countries in the European Economic Area (EEA) and Switzerland in reliance on the Privacy Shield. To learn more about the Privacy Shield, visit the U.S. Department of Commerce’s Privacy Shield website. Under the Privacy Shield, TrustArc is responsible for the processing of personal information it receives and subsequently transfers to a third party acting for or on its behalf. TrustArc is liable for ensuring that the third parties we engage support our Privacy Shield commitments. The U.S. Federal Trade Commission has regulatory enforcement authority over TrustArc’s processing of personal information received or transferred pursuant to the Privacy Shield Framework. Collection and Use TrustArc takes a Privacy by Design approach, making your privacy the default setting by collecting information about your interests only when you voluntarily provide that information to us. Information about your interests includes ad categories that interest or do not interest you, such as auto, dating, travel, etc., or whether you want to receive interest-based ads. We may collect one or more of the following advertising identifiers from your desktop or mobile device such as: IDFA Android ID Other Ad Network identifier that is stored in a cookie if you access TRUSTed Interests through your desktop or mobile web browser We collect these identifiers solely to associate your interests so advertising networks and data partners can honor them. The identifiers collected from your device depend on your device’s operating system (e.g. iOS, Android) and whether you accessed Ads Interests Manager from an application, or a desktop or mobile website. We use this information to: Apply your device specific interests for both mobile apps and mobile websites. Create a non-permanent unique ID within TrustArc’s system for the purpose of storing and communicating interests within TrustArc’s internal platform; Communicate and share your interests to advertising and data partners including whether you want to receive interest-based ads. Enable advertising and data partners to honor your interests according to the preferences you have set. You can view and modify your interests, including choosing not to receive interest-based ads, at any time by clicking here. You must access this link from the same device, either your desktop or mobile device that you were using when you accessed TRUSTed Interests and provided us your interest information. You also have the option to provide us your email address. TrustArc will use your email address to notify the ability to create an account allowing you to manage your preferences across multiple devices when the service is available. If your email address changes, please just enter your new address into the email signup form. To request deletion of your email address from our system email TrustArc’s Data Governance and Privacy Office at firstname.lastname@example.org. We will make reasonable efforts to respond within 30 days of your request. If we cannot honor your request within the 30-day period, we will tell you when we will provide access. In the unlikely event that we cannot delete this information, we will explain why we cannot do so. Tracking and Ads TrustArc uses IDFA, Android ID, or its own unique identifier to track users from either an application, or desktop or mobile websites that access Ads Interests Manager to associate information you provide about your interests, and recognize you when you return. Sharing TrustArc will share the collected device identifiers, your unique TrustArc created ID, and your stated interests with our advertising and data partners to manage your interests and enable the advertising partner to honor those interests. TrustArc works with advertising and data partners that have had their data collection, use, and sharing practices certified under industry frameworks that ensure those companies have responsible data management practices. Examples of these industry frameworks include TRUSTe Data Collection Certification Standards; Digital Advertising Alliance – US, Canada, and Europe; and the Network Advertising Initiative. Your email address will not be shared with TrustArc’s advertising and data partners. We will disclose your information: As required by law, such as to comply with a subpoena or similar legal process. To the extent we are legally permitted to do so, we will take commercially reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of a legal process. TrustArc also may be required to disclose personal information in response to lawful requests by public authorities, including requests from national security or law enforcement authorities. When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to a written government request. If TrustArc becomes involved in a merger, acquisition, or any form of sale of some or all of its assets. In the event of a merger, acquisition, or any form of sale of some or all of TrustArc’s assets, we will ensure that the acquiring organization agrees to protect personal information in accordance with the commitments we have made in this Privacy Notice, including our Privacy Shield commitment, and that the acquiring organization will provide notice before personal information, customer information, or business information becomes subject to a different privacy statement. Security and Data Integrity We will store your device identifiers as long as commercially reasonable and as needed to manage and communicate your interests. Safeguarding the information you give us or we receive about you is a priority for TrustArc. We take appropriate security measures to protect against loss, misuse and unauthorized access, alteration, disclosure, or destruction of your information. TrustArc has taken steps to ensure the ongoing confidentiality, integrity, availability and resilience of systems and services processing personal information, and will restore the availability and access to information in a timely manner in the event of a physical or technical incident. We will retain personal information for as long as it is needed to: Provide products and services that you have requested; To communicate with you about a request you have made to us; To manage your choices and rights you have exercised pursuant to this Privacy Notice; To enable you maintain an account with us, provided that you have not otherwise requested that we delete your information; To comply with our legal and regulatory obligations, to demonstrate compliance, and to enforce TrustArc’s rights and agreements. Other Information TrustArc complies with self-regulatory frameworks for interest-based advertising set forth by the Digital Advertising Alliance in the US (DAA), Canada (DAAC), and Europe (EDAA). Please note that this Privacy Notice may change from time to time. If we change this privacy statement in ways that affect how we use your information, we will advise you of choices you may have as a result of those changes. We will also post a notice on the Ads Interests Manager page of our website to inform users of such changes to our Privacy Notice. Contact If you have feedback, questions, or concerns about this privacy notice or Ads Interests Manager you may contact the TrustArc Data Governance and Privacy Office at: email@example.com 835 Market StreetSuite 800, Box 137San Francisco, CA 94103-1905 For information about your individual rights, including the right to access your personal data, please see the “Your Rights” section of the TrustArc Privacy and Data Processing Policy here: https://sigma.trustarc.com/privacy-policy/ If you are a resident of the EEA and have an unresolved privacy or personal information collection, use or disclosure concern that we have not addressed satisfactorily, please contact the EU Data Protection Authorities. If your are a resident of Switzerland and have this concern, please contact the Swiss Federal Data Protection and Information Commissioner. In connection with its self-certification under the Privacy Shield, TrustArc commits to cooperate with the panel established by the EU Data Protection Authorities and comply with the advice given by the panel with regard to personal information transferred from the EU. TrustArc also commits to cooperate with and comply with the advice of the Commissioner with regard to personal information transferred from Switzerland. This is provided at no cost to you. For more information on how to contact the EU Data Protection Authorities, click here. For more information on how to contact the Swiss Federal Data Protection and Information Commissioner, click here. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted. Defined Terms The following terms used in this Privacy Statement have defined meanings. Personal information. Any data about an identified or identifiable individual, including data that identifies an individual or that could be used to identify, locate, track, or contact an individual. Personal information includes both directly identifiable information such as a name, identification number or unique job title, and indirectly identifiable information such as date of birth, unique mobile or wearable device identifier, telephone number as well as key-coded data. Third party. Any legal entity, association or person that is not owned by TRUSTe, or in which TRUSTe does not have a controlling interest.