LAST UPDATED - JANUARY 17, 2020

Privacy Policy

Spotible is committed to the right of Internet consumer privacy. Spotible technology services do not require the collection of any personal data from users. However, in order to provide the most enhanced end-user experience such as advertisement frequency control, Spotible utilizes Local Storage Objects (LSOs). An LSO provides a unique computer identifier that by no means intrudes on the user’s anonymity to Spotible, nor is required for the operation and/or serving of Spotible advertisements. The acceptance and removal of LSOs is controllable from standard web browsers.

COLLECTION OF INTERNET CONSUMER DATA

Spotible collects and may share aggregated non-personally identifiable information-- such as anonymous advertisement interaction and reporting data related to user device, page(s) or application(s) visited, data and time of advertisement viewed and level of engagement or viewership of advertisement campaigns-- with media publishers and advertisers interested in ad viewership patterns and performance benchmarks of Spotible advertisement campaigns.

In some cases, Spotible may store personally identifiable information users have explicitly submitted in a Spotible advertisement campaign, such as entering your zip code to receive a promotion from an advertiser promoting a product or service. Any personal information supplied by a user and collected in a Spotible advertisement campaign is solely and strictly provided to the media publisher or advertiser or their respective authorized service provider and is not retained or used by Spotible in any way for any other purpose. The third party’s collection and use of user submitted personal information is protected under the respective party’s privacy policy and Spotible is not responsible for that third party’s privacy or information practices.

USE OF INTERNET CONSUMER DATA

Spotible primary use of collected consumer data information is for the purpose of providing the best suited advertisement campaigns fitting device capabilities, user engagement and reducing the repetition of advertisements through reach and frequency capping.

ACCORDANCE OF INTERNET CONSUMER DATA

Spotible data collection and usage upholds full compliance to the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising, 2013 Network Advertising Initiative (“NAI”) Code of Conduct for Online Behavioral Advertising and 2013 NAI Mobile Application Code, Children’s Online Privacy Protection Rule (“COPPA”), EU General Data Protection Regulation (EU) 2016/679 (“GDPR”), and California Consumer Privacy Act (CCPA), as updated periodically.

Spotible is a Processor or Service Provider in respect to Processing Operations. Spotible can be contacted at:

Spotible
555 8th Avenue, Suite 909
New York, NY 10018
(877) 709-7768
info(at)spotible.com

STORAGE OF CONSUMER DATA

Spotible collects user information through technology services that may be stored and processed in the U.S. or any other country Spotible or its affiliates or service providers maintain facilities. Spotible may transfer user information, including user provided personal information, to affiliated entities, or to other third parties across borders and from a user’s country or jurisdiction to other countries or jurisdictions around the world. If a user is located in the European Union or other regions with laws governing data collection and usage that may differ from U.S. law, Spotible may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as the user’s jurisdiction, whereby users consent to: i) transfer of information to the U.S. or any other country in which Spotible or its affiliates or service providers maintain facilities; and ii) the use and disclosure of user information as described in this Privacy Policy.

PROTECTION OF CONSUMER DATA

Spotible holds itself to the highest standard to protect user privacy and data, albeit cannot ensure or warrant the security of any information transmitted to Spotible or guarantee user information may not be accessed, disclosed, altered or destroyed by breach of any of industry standard physical, technical or managerial safeguards employed by Spotible. Spotible encrypts transmitted information using secure socket layer technology (SSL), however no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, Spotible cannot guarantee the absolute security of user information.

POLICY NOTIFICATION AND CONTACT

Spotible reserves the right to modify this Privacy Policy at any time without notice. As such, and for the sake of ease for interested parties to keep up-to-date with the policy, a Last Updated denotation will be clearly posted whenever modified. If you have any questions in respect to our Privacy Policy, please submit your inquiry via the contact form on our website.