Display.io Privacy Policy

Last Updated: September 5, 2019

Display.io Ltd. (together with its subsidiaries, affiliates, officers and directors, as applicable – collectively “Display.io”, “Company”, “we” or “us”) is a global mobile ad-tech company that provides its mobile application developer

s, advertisers and publishers (“Business Partners”) with an advertising platform for the purpose of delivering advertising to individuals (“user(s)”) who download, use or otherwise interact with an app developers’ app, site or our services (“Digital Assets”), as defined below (collectively, “Advertising Service(s)“).

Display.io respects your right to privacy as detailed in this privacy policy (“Privacy Policy”). This Privacy Policy will set forth our privacy practices with regards to:

• Information we collect from visitors of our website available at: https://www.display.io (“Site”) and our Business Partners who register to our Services through our Site.
• Information we collect from users who interact with our Business Partners’ Digital Assets which are using our advertising platform.

In this Privacy Policy you will learn about

• Our lawful basis for data processing (as required under the EU General Data Protection Regulation (“GDPR”), and applicable for European Economic Area (“EEA”) residents).
• Types of data we collect
• How we collect data
• What are cookies and how we use them
• Sharing data with third parties
• Our data retention policy (meaning when will we delete the data we collect)
• How we protect data
• User choices and controls (including opt out information)
• User rights
• Changes to this Privacy Policy
• How do we transfer data
• Children Privacy Online
• “Do Not Track” disclosure
• How to contact us

If you have any questions about this Privacy Policy or our privacy practices, please do not hesitate to contact us at: contact@display.io.

Lawful Basis

As required under GDPR, the lawful basis for our data collection and processing is as follows:

• Where a Business Partner uses our Services, we process the Business Partner’s Personal Data in order to perform our contract with the Business Partner;
• Some Online Identifiers, such as third party cookies we use, are based on consent;
• For direct marketing of Business Partners, we will process such data under our legitimate interest.

Display.io acts as a Processor of certain Personal Data, as defined under the GDPR, such as the data processed from our users using our Business Partners’ Digital Assets. Display.io is also a Controller of certain Personal Data, such as our Business Partner’s registration data, or if individuals contact us via our Site.

Types of Data We Collect

If you are a visitor of our Site, Business Partner or a user of our Business Partner’s Digital Assets which use our Advertising Services, Display.io collect several types of data, which can be mainly classified as follows:

• “Non-Personal Data”: non-identifiable information which is not identifiable to a specific individual and as such we are not aware of your identity due to such information.
• “Personal Data”: individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual.

In the event we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.

For your convenience, we have arranged the types of data we collect according to your interaction with us, meaning, the first table below will detail the data we collect from visitors of our Site including our Business Partners who register to our Advertising Services, and the second table will detail the data we collect from users who interact with our Advertising Services (e.g., a user who have downloaded our Business Partner’s app which serves ads through our Advertising Services). The tables below will also explain how we use each type of data.

Data we collect from Business Partners and visitors to our Site:

Data we collect from users who interact with our Business Partners’ Digital Assets (meaning user who download our Business Partner’ mobile app which integrates our SDK to serve advertisements):  

How We Collect Data

We may collect the data detailed above in two different ways:

• When you voluntarily provide us with such data – meaning, for example, if you are Business Partner and you register to our Advertising Services and create an account through our Site, or if you are a visitor of our Site and you contact us.
• Data collected automatically – meaning, if you are either visiting our Site or use our Business Partner’s Digital Assets (e.g., a mobile application which integrates our Advertising Services),  we may use our SDK, Cookies and other similar tracking technologies (as detailed below) to gather information automatically, such as your Advertising ID, IP address, data that is made available for us via the app developer etc.  We may also acquire information from other trusted sources to update or supplement the data that that we collect automatically.

Please note that, whenever required under applicable law, we will obtain your consent prior to collection of Personal Data, or obligate our Business Partners to obtain such consent, and you are always able to  opt-out – see information in the “User Choices and Controls” section below.

What are cookies and how we use them

When you visit Display.io Site, we may use tracking technologies known as “cookies” and or similar technologies. Cookies are small text files that are placed on your hard drive by a web server when you access our Site or Services.

The cookies can be used for various purposes, such as to facilitate the use of the Site, to collect statistical information or customize the Site and our services offered therein. If you wish to block the cookies, you will have to modify settings in your browser and follow the necessary instructions to disable receipt of cookies – please review the “User Choices and Controls” section below for helpful information. However, bear in mind that disabling cookies may complicate or even prevent certain features of the Site and our services and your online experience may be limited. You can find more information about cookies at www.allaboutcookies.org.

We may permit third parties to use cookies or other technology to collect information about your online and application usage activities, this data may include Personal Data therefore we recommend you review providers’ cookie policies carefully:

Sharing Data with Third Parties

We do not share any Personal Data collected from you with third parties or any of our partners except in the following events, and solely to the extent needed:

• If the Company reasonably believes that you have breached our terms of use, or abused your rights to use the Site or Advertising Services, or performed any act or omission that the Company reasonably believes to be violating any applicable law, rules, or regulations;
• If the Company is required, or reasonably believes that it is required by law or law enforcement agencies to share or disclose your information; 
• In any case of dispute, or legal proceeding of any kind between you and the Company or between you and other users with respect to, or in relation with the Site or Advertising Services; 
• If the Company organizes the operation of the Site or Advertising Services within a different framework, or through another legal structure or entity, or if the Company is acquired by, or merged into or with another entity, provided however, that those entities agree to be bound by the provisions of this Privacy Policy, with respective changes taken into consideration;
• We may disclose Personal Data to our trusted agents and service providers so that they can perform requested services on our behalf, for example for security, fraud detection, server and data storage providers, etc. (among others, as detailed in the “Cookies” Section above);
• We may share your information in order to prevent harm to the rights (including any legal rights), property (including intellectual property) or other or safety of us, our users or any applicable third party;
• We may share certain identifiers and demographic data (as detailed above), including Advertising IDs or IP addresses collected by us (as detailed above), for the purpose of operating and improving our business, providing the Site or Advertising  Services, as well as to detect fraud, security or technical issues in connection with the Site or Advertising Services.
   

Data Retention Policy

The table below details our data retention practices – meaning , when will we delete data we collect and process:

Notwithstanding the above, in some circumstances we may retain the information we collect for longer periods, for example, when we are required to do so in accordance with legal, tax and accounting requirements. In addition, we may also retain your Personal Data for longer periods if we reasonably believe, at our discretion, that we need to obtain an accurate record of your correspondence or any dealing with us, for example, in the event of any complaints, all, in compliance with applicable laws.

User Choices and Controls

You may opt out of the data collection and sharing process related to our Site or Advertising Service, as shall be detailed below.

Options to opt out:

Mobile Opt-out:

If you use an Android device please follow this link for instructions: https://support.google.com/ads/answer/2662922

If you use an iOS device please follow this link for instructions: https://support.apple.com/en-il/HT205223.

Website Opt-out:

You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Please refer to the support page of the browser you are using. In this regard, following are some links which you may find useful:  

• For chrome;
• For Firefox;
• For Opera;
• For Internet Explorer;
• For Safari;
• For Edge.

Industry Standards

You may opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s (“NAI”) website – NAI consumer opt-out and the Digital Advertising Alliance’s (“DAA”) website – DAA opt-out page. If you wish to opt out of interest-based advertising, you may click here. Please note you will continue to receive generic ads.

Business Partners opt-out

You may find additional instructions on how to opt out from or limit the collection of information provided by the mobile app you are using. Please refer to the app’s privacy policy to learn more. Please note, however, that we are not responsible for the privacy practices of our Business Partners, and other third parties.

You may also contact us at: contact@display.io and we will be happy to assist you. Note that once you opt out, part of the Site or Services provided by us might no longer be available and some features may not work if you revoke the data transfer.

User Rights

Data protection and privacy laws provide you with the ability to exercise some rights regarding your Personal Data that we hold (which might be different in each jurisdiction) such as; right to access your Personal Data; right of rectification; the right to erasure of your Personal Data; right to restrict processing of your Personal Data; the right to object to processing of your Personal Data; data portability; the right to file a complaint to a supervisory authority (in the event you are EEA resident); and, the right to withdraw consent.  

If you wish to exercise any or all of the above rights, please fill out the Data Subject Request (“DSR”) form available here, and send it to our Data Protection Officer at: dpo@display.io.

Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, where and if they are applicable, including the right to complain to the supervisor authority. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law.

Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

Changes to this Privacy Policy

This Privacy Policy may change from time to time and we will post the amended terms on the Site and make reasonable efforts to notify you by email of major changes. The last revision will be reflected in the “Last Updated” date above. Amended terms will take effect immediately. Hence, you should review the Privacy Policy periodically to remain informed of any changes. You agree to accept the posting of a revised Privacy Policy as actual notice to you.

Your continued use of the Site or Services after any changes to this Privacy Policy have been posted as of the “Last Updated” date above signifies your acceptance of those changes. If you do not agree to the revised Privacy Policy, please refrain from using our Site or Services and contact us by sending an email to: contact@display.io.

Transfer of Data

We may store or process your information in the EU or in other countries. If you are a resident of the EEA we will take appropriate measures to ensure that your information receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your personal data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.

Do Not Track Disclosure

The Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see http://www.allaboutdnt.com.

Children Privacy Online

You represent and warrant that: (i) if you are located in the US, you are at least 13 years of age; or if you are located in the EU, you are at least 16 years of age; or if you are a resident of any other jurisdiction, you are above the age defined as “child” under applicable laws (collectively “Child” or “Children”); and (ii) you are of legal competence to enter into this Privacy Policy. If you are under 18, please be sure to read the terms of this Privacy Policy with your parents or legal guardians. The Site or Services are not directed or intended for Children, as defined under applicable law, and we do not knowingly collect or solicit information from children. If we become aware that a Child under that age has provided us with Personal Data, we take steps to remove such information from our servers. If you are aware that your Child has provided us with Personal Data, please contact us at contact@display.io.

When applicable, Company implements measures to comply with applicable Children Online Privacy regulation, including the US Children’s Online Privacy Protection Act (“COPPA”). If we become knowledgeable of end user that is considered a Child under applicable laws, we make sure to not process their personal data and take steps to delete such data if existed. 

If you become aware or have any reason to believe that a Child has shared any Personal Information with us, please contact us at:  dpo@display.io.

Comments and Questions

If you have any comments or questions about our privacy policy, please contact us at:

display.io Inc., Suite 972, 511 Avenue Of The Americas, New York, NY 10011, USA

You can also contact us via email at: contact@display.io.

Data Protection Officer

If you have any requests regarding the data collected under this Privacy Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: dpo@display.io.

Please be sure to include your information in any correspondence to us so that we can respond to your inquiry in a timely manner.