Effective as of February 1, 2017

Introduction

RLLCLL is a global provider of digital advertising media and data management technology. RLLCLL’s Audience Decision Engine and related technologies as well as any licensed technology (the “Technology”) activates data, automates execution, and optimizes advertising interactions across addressable media — delivering greater performance, transparency, and control to marketers and a better experience to consumers.

This privacy policy (“Policy“) sets out how RLLCLL processes information collected via our Technology and on our website at www.RLLCLL.com (the “Website”). It also sets out our practices regarding our use of such information, the steps we take to protect it, as well as the choices and rights that consumers (“users“, “you“, “your“) have regarding how we collect and process information about them.

In this Policy, we use the terms “RLLCLL“, “our“, “us” and “we” to refer to RLLCLL, Inc. and our affiliates.

RLLCLL is committed to protecting the privacy of consumers when we process information about them via our Technology and the users of our Website. We adhere to applicable industry guidelines, and will continue to review and update our Policy and procedures to ensure the safety and protection of personal information.

The RLLCLL Technology

Data Collection and Use

In the course of delivering an ad to you via the Technology, RLLCLL does not intentionally collect information that reveals your real-world identity, such as your name, address, phone number, or Social Security Number. RLLCLL collects data about your computer or device through the use of cookies, web-beacons and other similar technologies, as explained below. This information is pseudonymous and is not considered to be personal information in many jurisdictions in which we operate. In some other jurisdictions in which we operate, in certain contexts, such information, including Internet Protocol (IP) addresses and other pseudonymous information, may be considered personal information.

The information RLLCLL collects includes common information found in every communication sent over the Internet, from which we infer such things as: browser type (e.g., Chrome or Internet Explorer); operating system (e.g., Mac OS or Windows); browser language (e.g., English or Spanish); Internet Protocol (IP) address; Internet Service Provider (e.g., Comcast or Verizon); and mobile advertising identifier, for mobile devices such as smartphones and tablets.

RLLCLL may also collect data regarding your interactions with our clients and partners, including your use of our clients’ sites and mobile apps, the sites and apps our clients advertise on, and other pages on the Internet. We may also capture additional data in order to calculate a statistical ID, as described below.

We may also receive Precise Location Data (as defined by the NAI) generated from your use of your mobile device, such as the latitude/longitude coordinates provided by a mobile app publisher or other media supply source in conjunction with the opportunity to purchase advertising inventory. RLLCLL may transfer such Precise Location Data to clients and partners, including for use in targeting ads based on the current location of the device. When we process Precise Location Data, the mobile app publisher or other media supply source is responsible for enabling you to provide or withdraw consent with respect to the collection and use of your Precise Location Data.

We and our clients and partners use the information we collect to create data segments, and these data segments are generally based upon your interactions with our clients or other third party media suppliers, such as the websites that you visit and the mobile applications that you use.

We also receive pseudonymous information from third parties, when they choose to provide it to us. This information may include identifiers (like mobile advertising IDs) and interest-based advertising data tied to those identifiers, including segments provided by third-party data providers for our clients to use in targeting ads through the Technology. RLLCLL does not use this data to personally identify you.

We may assign a RLLCLL ID to your browser, computer or mobile device when we serve an ad to it or we identify it on a client’s website or mobile app. The RLLCLL ID may be stored in a cookie on your computer or mobile device. It helps us understand your interests and deliver more relevant ads to you. The RLLCLL ID and other information collected via the Technology can also help our advertising clients measure your activity on their sites and determine the effectiveness of advertisements delivered via the Technology. This information can then be used by our advertising clients to better cater to your needs and deliver ads to you for the types of products and services in which you might be interested. None of these technologies enable us to personally identify an individual. Instead, they enable the Technology to determine within a reasonable level of confidence that a computer or device is the same as one with which the Technology has previously interacted. For instance, the Technology can determine that a computer or device to which we served an ad on Monday may be the same computer or device for which we observed a purchase on Tuesday.

In some cases, RLLCLL is able to infer within a reasonable probability that a particular computer or mobile device should be associated with the same RLLCLL ID that we have previously assigned to another computer or mobile device. In other words, in such cases we are able to infer that a device (e.g. your computer) and another device (e.g. your smartphone) are used by the same user. Where we are able to make such inferences, we may use this information to deliver targeted ads across multiple computers or devices, and to improve the services we provide to our clients. This is sometimes referred to as cross-device advertising.

We use the information that we collect directly and the information that we obtain from third parties to create segments, run analytics, target ads, and measure the effectiveness of ads on behalf of RLLCLL’s clients. We also use it to improve our Technology and the products and services that we provide to our clients, and to create new products and services. For these purposes we may share information with our clients, partners and service providers.

RLLCLL does not knowingly collect data or create data segments that are based upon what we consider to be sensitive information (for example, we don’t create any data segments to determine credit worthiness, for insurance underwriting or similar purposes, nor do we create segments of EU consumers based on personal data considered to be sensitive in the EU, e.g. information about physical or mental health or condition, sexual orientation, race or ethnic origin, political opinions, religious or similar beliefs). Clients may use health-related segments (which are not comprised of sensitive health data) such as an inferred interest in health and wellness or cough medicine and allergy medications.

Cookies, Web Beacons, and Other Ad Targeting Technologies

Like most digital marketing Technologys, RLLCLL uses “cookies”, mobile advertising identifiers, and other technologies to enhance users’ experiences on the web, to deliver more relevant ads, and for ad delivery and reporting via the Technology.

We use these technologies to help recognize a computer or device so that we and our clients are able to deliver relevant advertising to you, measure the impact of that advertising and better understand and recognize digital media usage patterns.

The types of technologies used via the Technology include:

  • Cookies – Cookies are small text files that contain a string of characters. RLLCLL uses cookies to uniquely identify an Internet browser. Certain browsers or browser settings sometimes block cookies, and cookies may not work effectively on some mobile devices. For more information about cookies, please visit http://www.allaboutcookies.org/.
  • Mobile Advertising Identifiers – Mobile advertising IDs (e.g., Apple’s IDFA or Google’s AAID) are unique IDs that are associated with individual mobile devices and that do not reveal your real world identity. They usually are user-resettable.
  • Pixel Tags – Pixel tags (also commonly known as web beacons) are transparent images, iFrames, or JavaScript that our clients and partners use to understand how consumers interact with them online, including on websites and in mobile apps.
  • Statistical IDs – Statistical IDs are created via an algorithm using pseudonymous information about your computer or device, including your operating system, user-agent string, IP address, Internet browser, installed fonts, and similar information. This information makes your computer or device distinct enough for our systems to determine within a reasonable probability that they are encountering the same computer or device, including in environments where RLLCLL cookies are not supported.

These technologies are used to identify a computer or device within a certain level of confidence that enables the Technology to function and serve more relevant ads.

Data Retention on the Technology

We retain the RLLCLL ID and, where applicable, its association with other devices for as long as this is necessary for our legitimate business purposes.

Cookies set via the Technology expire within 13 months. RLLCLL also expires within 13 months the browsing data tied to your RLLCLL ID (e.g., records of when we served an ad to your browser or identified it on a client’s website or mobile app).

Opt-Out

You may opt out from RLLCLL tracking and interest-based advertising at any time through one of the ways described below. If you wish to opt out of RLLCLL tracking and interest-based advertising on both internet browsers and mobile applications, you need to opt out separately for each browser or device via the methods described below.

Two Reasons You May Not Want to Opt Out

Advertising supports the free Internet. It is the primary way that most website and app publishers make money in order to produce the content consumers want. Not all advertising shown to consumers is relevant to their interests, though. Interest-based advertising is advertising that tries to make the ads you see more interesting and relevant to you based on the types of sites you visit online and other information that does not personally identify you. We conduct interest-based advertising on our Website, and work with our clients to help them do the same on their websites and apps.

Without interested-based advertising, you will still see ads, but those ads are not likely to have anything to do with products or services you care about. With interest-based advertising, you receive ads and offers that are more likely to be useful to you.

There is also a second benefit to you: companies that create websites and apps rely on the revenue from interest-based advertising to support the rich array of content they produce. Without that revenue, the content would either be unavailable or consumers would have to pay for it.

What does it mean to opt-out?
In general, “opting out” means that you want RLLCLL to limit the information it collects and stores about your computer or device and to not deliver ads that are targeted to your interests on your computer or device. If you use multiple browsers, computers or mobile devices and wish to limit the information RLLCLL collects and stores or do not wish to receive RLLCLL interest-based advertising on any of them, you must opt out from each browser, computer, and mobile device individually. Please note that if cookies are not enabled in your browser, or if you use certain ad-blocking tools, our opt-out mechanism may not work properly. Please also note that deleting your cookies does not opt you out.

Opt out this browser (if using a browser)
Your current opt-out status with RLLCLL in this web browser is:

When you opt out, we record the opt-out on our servers and in browser environments we will attempt to place an HTTP opt-out cookie onto your computer or device. When you opt out, RLLCLL will collect and store information from your computer or device only as needed to honor your opt-out and for limited research and development purposes to improve our browser- and device-recognition technology, which also helps to improve our ability to honor your opt-out. When you opt out, RLLCLL also stops serving interest-based advertising in that browser. In many instances, even if you delete your cookies, we are able to maintain a record of your opt-out on our servers. Nonetheless, please note that if you clear your cookies, or if you use a different browser or device, you may need to renew your opt-out choice.

Opt out in the mobile application environment

You may opt out in mobile app environments using the “AppChoices” mobile application, which you can download to your mobile device from your App Store or via the Digital Advertising Alliance AppChoices page here.

Please note that you will still see ads if you opt out. The ads delivered via RLLCLL will just not be as relevant to you. When you opt out, RLLCLL will collect and store information from your device only as needed to honor your opt-out and for limited research and development purposes to improve our device-recognition technology, which also helps to improve our ability to honor your opt-out. When you opt out, RLLCLL also stops serving interest-based advertising in mobile apps on that device.

Other ways to opt out

You may learn more about interest-based advertising and opt out of interest-based advertising from RLLCLL and other online advertising companies that are also members of applicable self-regulatory organizations by visiting their opt-out links:

Other ways to exercise choice

You may also limit ad tracking in mobile app environments on your device. For the most effective and up-to-date methods for doing so, you should consult instructions provided by those device manufacturers. We offer the following information solely for informational purposes, and we cannot guarantee that the methods below are the most current:

Where RLLCLL receives a signal to limit ad tracking, we will collect and store information from your device only as needed to honor your opt-out and for limited research and development purposes to improve our device-recognition technology, which also helps to improve our ability to honor your opt-out. When you opt out, RLLCLL also will not serve interest-based advertising in the mobile app environment of that device.

If you have questions about how to opt out or limit mobile tracking, please contact us at privacy@RLLCLL.com.

The RLLCLL Website, www.RLLCLL.com

Data Collection and Retention on our Website

RLLCLL collects personal information on the Website when visitors choose to reveal it to us. For example, when you contact us to request a demonstration of our products or services or to otherwise send us questions, we will collect personal information such as your name and email address. RLLCLL uses information from the Website log files to determine how you found out about us, what your interests are regarding our services, and how to further improve our site and our service towards you.

Social Media Features and Widgets
The Website includes Social Media Features, such as the Facebook Like button, and Widgets such as the ShareThis button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on the Website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with each of these Features is governed by the privacy policy of the company providing it.

Login
When you login in to our website to access information, this area of our site is password protected and provides information related to our business partnership in real time.  Please see terms and conditions located in that area of The Site.

Information Collected Automatically
As is true of most websites, we gather certain information automatically and store it in log files. This information may include IP address, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you. We collect information automatically through the use of various technologies including cookies.

Additional information applicable to both our Website and Technology

Links and other websites
This Policy applies solely to the Technology and Website of RLLCLL. RLLCLL’s Website contains links to other sites, and the ads delivered by the Technology may run on a variety of other sites. Please be aware that RLLCLL does not control these third party sites, ads and cookies and is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our Website and to read the privacy statements of third party websites to find out how they collect and use your personal information and to establish whether and for what purpose they use cookies.

Information Pertaining to Children
RLLCLL’s products and services are designed for those 13 years of age and older. We do not knowingly collect personal information from anyone under the age of 13. If we are made aware that we have received personal information from someone under 13, we will use reasonable efforts to remove that information from our records.

Data Security and Integrity
RLLCLL implements technical and organizational measures to safeguard data in our possession against loss, theft, and unauthorized use, disclosure, or modification. No transmission of data over the Internet, however, is guaranteed to be completely secure. It may be possible for third parties not under the control of RLLCLL to intercept or access transmissions or communications unlawfully. While we strive to protect your information, we cannot ensure or warrant the security of any information you transmit to us. RLLCLL processes information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current, and reliable for its intended use. If you have any questions about security on the Website or through the Technology, you can contact us at privacy@RLLCLL.com.

Data Sharing and Disclosure
We may publish or otherwise make public anonymous, aggregate, or summary information regarding campaigns run on behalf of our clients.

We may share information (including personal information):

  • With our group companies.
  • With clients and partners, where this is necessary in order to operate the Technology and the Website, to provide our products and services, to improve our Technology, products and services and to create new products and services.
  • With service providers who help with the operation of the Technology, the provision of our products and services and our business operations. We require our service providers to only use the information that we provide to them in connection with the services they perform for us.
  • With third parties when we consider this to be necessary: to establish or protect the legal rights of RLLCLL or its employees, agents and contractors, as well as the legal rights of its clients or other third parties; to protect the safety and security of users and visitors to our Website; to protect against fraud; or to comply with the law or legal process.
  • When we are required to or allowed to do so by law (for example in response to subpoenas, to comply with a binding court order. legal process, or government requests, including in response to a public authority to meet national security or law enforcement requirements).
  • If RLLCLL sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, we may transfer or assign the information to a third party as part of that transaction.

Policy Updates

From time to time RLLCLL may revise this Policy. The date of the last update can be found at the top of this Policy. If we make revisions that materially change or affect whether or how we collect or use personal information we will notify you by email (if, as a user of our Website, you have provided us your email address) or by means of a notice on our Website prior to the change becoming effective. Therefore, you should review the Website periodically so that you are up-to-date on our most current policies and practices.