PRIVACY POLICY
At Casulo Media LLC (referred to as “Company,” “us” or “we”), we recognize that your privacy is important. This Privacy Policy ("Policy") discloses the privacy practices for the Company’s family of websites and online tools (collectively, the “Site”), as well as related products and services we may offer to you (collectively referred to as the “Services”). Please read the information below to learn the following regarding your use of this Site.
We provide ad serving technology (the "Technology") that helps our client advertisers ("Advertising Partners) buy available ad space across multiple web and mobile properties ("Publishers" and with Advertising Partners, our "Partners") to generate traffic to their sites and procure customers.
We have adopted this Policy to further the relationship between us and our Advertising Partner and Publishers on the one hand and the end users ("Consumers") who may visit the sites of our Advertising Partners through ads we placed with our Publishers. This Policy makes disclosures concerning our collection of information, including personal information, about our Partners when they use the Site and/or Services and when Consumers visit sites operated by our Partners that use our Technology, and how we use and disclose it to others. By using the Site and/or Services you accept the practices described in this Policy and that by accessing or using our Site, you agree to be bound by this Policy. Consumers and Partners from which we collect information are sometimes referred to as "you" or "your", as applicable.
We reserve the right to change this Policy from time to time. We will notify you about significant changes in the way we treat personal information by placing a prominent notice on our site, and by updating any privacy information on this page. Your continued use of the Site and/or Services available through this Site after such modifications will constitute your: (a) acknowledgment of the modified Policy; and (b) your agreement to abide and be bound by that Policy.
If you have any questions about this Policy, please feel free to contact us at: support@casulomedia.com.
IMPORTANT: BY USING THE SITE AND/OR OFFERINGS AVAILABLE ON THIS SITE, YOU GIVE YOUR CONSENT THAT ALL PERSONAL DATA THAT YOU SUBMIT MAY BE PROCESSED BY US IN THE MANNER AND FOR THE PURPOSES DESCRIBED BELOW. IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS, DO NOT USE THE SITE.
IF YOU ARE SITUATED IN THE EU, PLEASE SEE THE SECTION “ADDITIONAL EU DISCLOSURES” THAT PERTAIN TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONALLY IDENTIFIABLE DATA AND PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.
1. Types of Information
There are generally two types of information collected on websites and the internet - Personally Identifiable Information ("PII") and non-personal ("Aggregate") information.
Personally Identifiable Information: This refers to information that lets us know the specifics of who you are. When Partners engage in certain activities on the Site, such as registering to participate in our program and use the Technology, downloading or purchasing a product or service or sending us feedback, we may ask you to provide certain information about yourself. This information may include your first or last name, email address, mailing address (including zip code), employer, job title and department, telephone and facsimile numbers, credit card or financial information or other identifying information. PII is not collected on Partner sites through the operation of our Technology itself.
Personal Data: Additionally, we may also collect certain others types of information that, along with PII, may be considered and specifically named "Personal Data" in certain jurisdictions, including the European Union (“EU”), such as: technical data, which includes internet protocol ("IP") address, cookies, browser and device information, location data and your login data and usage data, which includes information about how you use our Site, Services and Partner Sites and advertising we serve on those sites including, in the case of Consumers, how many times you viewed the ad, clicked the ad etc. to improve our Services and also mitigate fraudulent activities.
Aggregate Information: This refers to information that does not by itself identify a specific individual. We gather certain information about you based upon where you visit on our Site and what other sites may have directed you to us. This information, which is collected in a variety of different ways, is compiled and analyzed on both a personal and an aggregated basis. This information may include the Website’s Uniform Resource Locator (“URL”) that points to the site you just came from, which URL you go to after visiting our Site, what browser you are using, and your IP address.
2. How We Collect and Use Information
We do not collect any PII about you unless you voluntarily provide it to us. For example, you may provide certain PII to us when you elect to use certain products or services available on the Site and when you register to be a part of our program.
We use your PII for a variety of purposes, including sharing it with third parties such as our Advertising partners, ad networks, Publishers, data providers and corporate affiliates in order to provide our services, conduct internal analysis to perform and improve our services and associated technologies and will primarily use your PII to provide product or service offerings to you. We will also use certain forms of PII to enhance the operation of our Site, improve marketing and promotional efforts, statistically analyze Site use and the Services, improve our product and service offerings, and customize our Site’s content, layout, and services. We may use PII to deliver information to you and to contact you regarding administrative notices. In addition, we use your PII for a variety of purposes including (i) inferring eligibility of users for interest, geographic and demographic-based segments; (ii) presenting advertisements tailored to interests you have shown; (iii) determining whether you have seen a particular advertisement before so as to avoid sending you duplicate advertisements; (iv) understanding the patterns of people who see advertisements; and (v) providing insights and reporting back to our business partners, including statistical reporting in connection with the activity on a website or mobile application, optimization of location of ad placement, ad performance, reach and frequency metrics, billing, and logging ads served on a particular day to a particular website or application. Finally, we may use your PII to resolve disputes, troubleshoot problems and enforce our agreements with you, including this Policy.
We may also collect or our third party advertising partners may collect, certain Aggregate Information. For example, we may use your IP address to diagnose problems with our servers, software, to administer our Site and to gather demographic information. Our third party advertising partners may also provide us with aggregate, but not individual, reports that will tell us how many ads were presented and clicked upon at out Site.
3. Cookies
Depending on how you use our Site, we will store cookies on your computer in order to collect certain aggregate data about our users and to customize certain aspects of your specific user experience. A cookie is a small data text file which is stored on your computer that uniquely identifies your browser. Cookies may also include more personalized information, such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server, and your first name to welcome you back to our Site. We may use cookies to perform tasks such as: monitoring aggregate site usage metrics, storing and remembering your passwords (if you allow us to do so), storing account and advertising preferences and personalizing the Services we make available to you and, in the case of Consumers, to inform us if an advertisement has been served to the same computer before, and if so, when the advertisement was served. When Consumers visit one of our Partner sites or mobile applications, we may assign your computer one or more cookies which enable us and our Partners to deliver targeted advertisements. This form of advertising is called “behavioral advertising” or “interest based advertising”. We believe that such advertising is helpful because you will see ads that are relevant to your interests. However, if you would like to opt-out of these interest-based advertisements, please see the section titled “Opt-Out” below.
Unless you choose to provide it to us, our Technology does not collect any sensitive consumer information about you during the ad delivery process. Our Technology does not, for example, collect any social security numbers, insurance plan numbers, financial account numbers, precise real-time geographic location derived through location-based services, nor any specific information about your past, present, or potential future health or medical conditions or treatments, including genetic, genomic or family medical history.
Advertising Partners and Publishers may also place a separate cookie on your computer. We will not provide any third-party Advertising Partners with any PII of any Consumers, although we may disclose the PII of our Publishers to our Advertising Partners. We do not have access to or control the cookies used by third parties on our Site or on any Partner sites, and this policy does not govern the use of cookies by these third parties.
We and our third party ad server will collect and use Aggregate Information about you, such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server and whether you responded to a particular ad.
Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some aspects of the Site may not function properly if you elect to disable cookies.
4. Release of Information
We will not sell, trade, or rent your PII to others.
Subject to the section titled “Additional EU Disclosures”, PII is generally only submitted to us by our Publisher or Advertising Partners in connection with their use of our Technology and we use this PII to service their accounts and respond to inbound inquiries related to sales or technical support requests.
Occasionally we may be required by law enforcement or judicial authorities to provide PII to the appropriate governmental authorities. In such cases, we will disclose PII upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful. We may also provide information to third parties in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
We may rent, sell, or share aggregated information and other information that is not PII with third parties for multiple reasons, including to develop and deliver targeted advertising and to conduct general business analysis. Information that we collect to create segments and profile information for our Service may be shared with our Partners. We may combine information we collect with additional information collected from other sources. Please note that this Privacy Policy does not cover any third party's use or handling of your information once it is shared. While we do not collect PII about Consumers when you view or interact with an ad, there is a possibility that our Technology and our Partners will make assumptions or infer things about you (or anyone using your devices or browsers) in order to display more relevant ads.
5. Application of Privacy Policy to Third Party Websites You Access
You will be able to access third party websites directly from the Site and, in the case of Consumers, directly from our Partner sites. This Policy does not apply when you access third party websites. We cannot control how third parties may use personal information you disclose to them, so you should carefully review the privacy policy of any third party website you visit before using it or disclosing your personal information to its provider.
WE ARE NOT RESPONSIBLE FOR THE INFORMATION COLLECTION, USE, DISCLOSURE OR OTHER PRIVACY PRACTICES OF ANY THIRD PARTY, INCLUDING OUR AFFILIATES, PUBLISHERS OR ADVERTISING PARTNERS, THIRD-PARTY SERVICE PROVIDERS, ANY EMPLOYERS (INCLUDING ANY EMPLOYER THAT PROVIDES A COMPANY PAGE), ANY THIRD-PARTY SOCIAL MEDIA PLATFORM, ANY THIRD PARTY MAKING AVAILABLE THE DEVICES OR OPERATING SYSTEMS FOR WHICH THE SITE IS AVAILABLE, AND ANY THIRD PARTY OPERATING ANY WEBSITE TO WHICH THE SITE CONTAINS A LINK. YOU MAY HAVE RIGHTS DIRECTLY ENFORCEABLE AGAINST THESE THIRD PARTIES SO YOU SHOULD CONSIDER THEIR PRIVACY POLICIES TO LEARN MORE.
6. Updating and Correcting Information
We believe you should have the ability to access and edit the PII that you have provided to us. You may also access and correct your personal information and privacy preferences by emailing or writing us at:
Casulo Media LLC
10 West 15th Street #414
New York, 10011
Attn: Privacy Compliance Officer
Email: support@casulomedia.com
Please include your name, address, and/or email address when you contact us.
We encourage you to promptly update your PII if it changes. You may ask to have the information on your account deleted or removed; however, some information, such as past transactions, logs of technical support calls, or other information may not be deleted. In addition, it may be impossible to completely delete your information without some residual information because of backups.
7. CHILDREN'S PRIVACY
Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or solicit PII (including persistent device identifiers) from anyone under the age of 13 or knowingly allow such persons to use the Site. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 is allowed to provide any PII to or on the Site. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible.
In addition, we require our Advertising Partners and Publishers to certify to us that their services (such as their websites or mobile apps) are not primarily directed to appeal to children under the age of 13 and that they do not share personally identifiable information relating to children under the age of 13 with us. Please note that while we strive hard to ensure that our policies are respected, we cannot be held responsible for the practices of third parties such as our Advertising Partners and Publishers. Our Publishers are responsible to ensure that their privacy practices comply with applicable privacy laws and requirements, including with respect to safeguarding children’s privacy (such as by complying with the U.S. Children’s Online Privacy Protection Act of 1998).
If you believe that we might have any information from or about a child under 13 or that our practices are included in any service (such as a website or mobile app) that is directed to or aimed to appeal to audience under the age of 13, please contact us at support@casulomedia.com, and we will remove their personally identifiable information from our servers without delay.
8. Security of Your Personal Information
At our Site you can be assured that your PII is secure, consistent with current industry standards. We strive to take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of your PII. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your PII, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.
9. Data Retention
We will only retain information relating to you for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for such information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements. And as permitted by law, we may continue to retain aggregated information. In some circumstances, if you are an EU data subject, you can ask us to delete your Personal Data by sending us an email to Support@casulomedia.com.
10. Additional EU Disclosures
Casulo Media LLC is the data controller of all PII collected through our Site. Website. If you are situated in the EU and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local Supervisory Authority, as defined by the EU's General Data Protection Regulation ("GDPR"). We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us in the first instance. If you have a complaint, please contact our privacy manager per the details listed in section titled “Contact Us” below.
Pursuant to the GDPR, you have eight rights. These are:
The right to be informed – we must be completely transparent in how we use your personal data..
The right of access - you have the right to know exactly what information is held about you and how it is processed.
The right of rectification - you are entitled to have personal data rectified if it is inaccurate or incomplete.
The right to erasure - also known as 'the right to be forgotten', this refers to your right to have your personal data deleted or removed without the need for a specific reason as to why you wish to discontinue.
The right to restrict processing - you have the right to block or suppress processing of your personal data.
The right to data portability - this allows you to retain and reuse your personal data for your own purpose.
The right to object - in certain circumstances, you are entitled to object to your personal data being used. This includes, objecting to the use or your personal data for the purpose of direct marketing, scientific and historical research, or for the performance of a task in the public interest.
Rights of automated decision making and profiling - the GDPR has put in place safeguards to protect you against the risk that a potentially damaging decision will be made without human intervention. For example, as described above, you can choose not to be the subject of a decision where the consequence has a legal bearing on you, or is based on automated processing.
The legal basis for our processing your PII include having a legitimate interest, performance of contract, compliance with legal or regulatory obligation and consent. If we are relying on your consent to process your PII, you have the right to withdraw your consent at any time by contacting us at support@casulomedia.com.
11. Modification to this Privacy Policy
We may edit, amend, modify, and update our Privacy Policy at any time and from time to time, by posting updated text on or links to our Website. When we make material changes to our Privacy Policy or our privacy practices, we will notify you by posting a notice on our Website or providing a notice to you. We display the Effective Date at the top of our Privacy Policy so that you will know when there has been a change in its effective date. By using our Website or our Technology or any Partner site using our Technology after the effective date, you will have agreed and be deemed to have agreed to comply with and be legally bound by the updated Privacy Policy.
12. Contact
If you have any questions, concerns or inquiries about this Policy, or our use of your PII, or our privacy practices, please contact us at: support@casulomedia.com. You can also reach our Privacy Compliance Officer by sending written correspondence to:
Casulo Media LLC
10 West 15th Street #414
New York, 10011
Attn: Privacy Compliance Officer
Email: support@casulomedia.com
Effective Date: March 15, 2019
© Casulo Media LLC 2019