No Collection of Personally Identifiable Information
The Network Advertising Initiative (NAI), which is a trade association for the Internet marketing industry, defines “personally identifiable information” as “any information used or intended to be used to identify a particular individual, including name, address, telephone number, email address, financial account number, and government-issued identifier.” We do not collect any personally identifiable information nor other types of sensitive consumer information, such as insurance plan numbers or information about medical conditions. All of our profiles are non-personally identifiable. While we may be able to associate interests and intent to purchase with specific profiles, we cannot match non-personally identifiable profiles with a specific individual or individuals.
Also, through the Digital Advertising Alliance (“DAA”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of and greater control over ads that are customized based on their online behavior across different Web Sites. CBS Interactive is committed to complying with the Self-Regulatory Program for Online Behavioral Advertising. To learn more and make choices about interest-based ads from participating third parties, please visit the DAA consumer opt out page. We adhere to DAA Principles.
About Our Online Advertising Services
DaVinci II is not an ad network or a data broker. It is a digital advertising technology platform. By “platform,” we mean a technology that provides tools for advertisers, or buyers, to purchase ad space and for website and mobile application publishers, or sellers, to sell their ad space in the most efficient way possible.
Users benefit from targeted advertising by receiving more interesting and relevant advertisements, while advertisers benefit through the more efficient delivery of advertising to interested Users.
Our targeting options are based on non-personally identifiable data that is collected over time as described below in “What Information We Collect” and may range from sending an advertisement to a User based on such factors as a User’s interests, similarities to other Users, or general geographic location. This data may be used to identify and predict the sites and groups of Users that are most likely to create a response to an advertiser’s campaign.
If you prefer not to have DaVinci II tailor online advertising to your interests, you may opt out at any time by one of the following methods:
Opt out of DaVinci II’s user interest targeting cookie by clicking the button below. Please note that if you delete your cookies, change browsers, or use a different computer, you will need to opt out again.
DaVinci II follows the standards of PrivacyChoice, which offers an opt-out wizard covering numerous advertising technology companies.
When you opt out, we will clear all data about you in our system and place three pieces of data in your browser’s cookie. The first piece of data tells us that you have opted out of DaVinci II; it does not contain any data about you except for the fact that you have opted out. We need this cookie in place so that we know not to collect information about your interests in the future. The second piece of data allows us to count the number of times you are exposed to our advertisers’ campaigns. The third and final piece of data enables us to count the number of people who visit our advertisers’ web sites as a result of seeing our campaigns.
Please note that opting out does not mean you will not see advertisements online, but only that DaVinci II will not tailor online advertisements based on your interests.
What Information We Collect
Automatically Collected Information. We may also collect a variety of information from your browser or computer using the Technology, including “pixel tags,” “clear gifs,” or “web beacons.” This “automatically collected information” may also include request-based information which is passed to us by the User’s computer browser with every request and is stored without any personally identifiable information. Examples of this include your web browser type, the web sites that you visit just before or just after visiting a web site, and the dates and times that you visit a web site. We may also collect session information relating to Users and specific ad campaigns, which is used for frequency capping, or limiting the number of times a User sees a specific ad; and the targeting of Users based on their specific interests. If you are using a mobile device and viewing a website that utilizes our Technology, we may also use the Apple IFA, Android Advertiser ID, or other non-personally identifiable device information that uniquely identifies individual smartphones or mobile devices (collectively, “IDFA and Android ID”) in order to authenticate the user session. This IDFA and Android ID functions similarly to a persistent cookie to make it possible to authenticate the user without the need for a password.
Click Information. We may receive non-personally identifiable information when you click on or otherwise interact with ads deployed using our Technology, including when you indicate a “like” or “share” the ad by clicking on a button near the ad. The information received by us may include information about the ad that was clicked on, the web page, or other session-based and request-based information as described above. We may also receive information regarding any links that you may click on that are associated with ads deployed using the Technology or any links that you share or receive from third parties related to those ads.
Information from Tr.im. We may receive non-personally identifiable information when you click on or use our sharing tools on websites that use our Tr.im sharing service. When a user accesses a webpage that contains our sharing tools or utilizes our link shortening or video embedding services, we may add a cookie to the user’s browser to record information on websites that the user has visited, search terms that they have entered, or connections between non-personally identifiable cookies, but strictly in a non-personally identifiable profile. For our video embedding services, we may also track information related to the videos that you share, including social statistics and information relating to the parties accessing the video, but only as a non-personally identifiable profile. We may also collect the IP address and ZIP Code of any devices that access URLs shortened by our services, information about how the shortened URLs have been shared, and the date and time of the website access using the shortened URL. We may use this information to customize and send more relevant advertisements to that user, based upon the collected information, as described below in the section entitled, “How We Use and Disclose Information.” We do not scan the title or the content of any messages you send through our services.
Information Acquired from Other Sources. We may acquire non-personally identifiable data from third party sources, including through websites that use our Technology. This data may be used for a variety of purposes, including to update existing User profiles, to provide our clients and others with aggregate information about traffic and site usage in our advertising network, and other uses as described below in the section entitled, “How We Use and Disclose Information.” We do not share, rent or sell any of this non-personally identifiable data and require these third party sources to comply with applicable industry and legal standards.
How We Use and Disclose Information
I General. DaVinci II uses the information collected by the Technology to tailor advertising to you more effectively. The aim is for you to see ads which you are more likely to be interested in. We do this by comparing the information in a non-personally identifiable profile against our selection of ad campaigns and choosing the most suitable advertisement. In general, DaVinci II can only create these profiles and display ads to you when you visit a web site within our network.
Action Attribution. To gain a greater understanding of a web site’s performance or a User’s general interests, we use a variety of technologies to determine which web sites in our network the User has visited previously and/or where the User clicked on an advertisement. By using this information, we can calculate which web sites and/or which broad interest characteristics of Users are most likely to respond to a particular campaign. This may be performed two ways – Performance Attribution and User Interest Profiling.
User Interest Profiling. To create a User interest profile, we observe which web sites within our network Users have visited and determine what topics are covered by these web sites. This information is combined to generate a non-personally identifiable interest profile for specific browsers to better target our ads to Users. For example, if a User visits a sports site within our network, we may classify them as broadly interested in that sport and potentially interested in purchasing sports gear. That information may be provided to our advertising partners to allow them to better tailor their ads to specific Users.
Tr.im. If you use our Tr.im sharing service, we may provide our third party partners with non-personally identifiable metrics and analytics about information and websites that you access. For example, if you click on a curated link hosted by one of our partners, our partner may receive non-personally identifiable information about the fact that you have accessed that website, including but not limited to the date and time of such access, the website visited, and the IP address and ZIP Code of the device used to access the link, but strictly in a non-personally identifiable profile.
Service Providers. DaVinci II works with authorized service providers to provide website hosting, maintenance, and other services for us. To the extent it is necessary for these service providers to complete their obligations to us, these service providers may have access to User information. However, we contractually require these service providers to safeguard User information and generally limit their use of User information to the purpose for which it was shared.
DaVinci II uses generally accepted industry security standards to protect data on the Platform. Platform Data is stored using generally accepted security standards. It is usually aggregated or deleted within 30-60 days, but may be retained in the Platform for up to 18 months from the date of collection before aggregation or deletion. Aggregated data is used for reporting and analysis, and may be stored in the Platform for up to 2 additional years. When clients remove their data from the Platform, their own privacy policies and applicable laws, rules, or regulations govern their storage and retention of data.
DaVinci II maintains all server log data and stored data for a period of 24 months to comply with audits, court order or law enforcement inquiries. After 24 months all of the stored data is destroyed. Summarized data is kept indefinitely. Summarized data is aggregated statistical data (impressions, clicks, and conversions) used for financial reporting purposes.
DaVinci II uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of User information. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store data.
In the Event of Merger or Sale
In the event that DaVinci II is acquired by or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from Users as part of such merger, acquisition, sale, or other change of control.
DaVinci II’s web sites, products, and services are neither developed for, nor directed at, children under the age of 13. With respect to the Children’s Online Privacy Protection Act (COPPA), DaVinci II does not knowingly collect personal information from nor employ or offer targeting towards children under the age of 13. If you believe a child of yours who is under the age of 13 has provided DaVinci II with personal information or registered at one of DaVinci II’s web sites, please contact us, and we will use reasonable efforts to remove that information from our records.
DaVinci II Site Privacy Practices
The DaVinci II Site is generally intended for use by businesses, advertisers, and potential partners interested in learning more about DaVinci II. You may provide to DaVinci II personally identifiable information (such as your name or email address) when using the Site. For example, if you are an advertiser or web publisher and use the Site to request a contact from our sales or business development department, we will ask for your name, email address and other contact information so that a DaVinci II representative can respond to your inquiry. We do not use your Personally Identifiable Information for any other purpose other than responding to your request. We do not share your personally identifiable information with other organizations for their marketing or promotional uses without your express consent. Notwithstanding the above, DaVinci II reserves the right to disclose personally identifiable information if: (i) required by law or in the good-faith belief that such action is necessary to comply with state and federal laws; (ii) we believe, in good faith, that such action is appropriate or necessary to take precautions against liability; or (iii) such action is necessary to protect our rights or those of our Users and others.
We adhere to Digital Advertising Alliance Principles with regard to data collection and interest-based advertising. Visitors to the DaVinci II site may experience a third party engaging in data collection for such purpose, based on your browsing behavior across many sites. If you wish to control such data collection, you may visit the DAA Consumer Choice Page, where you can learn more about the value of interest-based ads, and express your preferences there.
The Site is hosted in the United States and is intended solely for visitors located within the United States. If you choose to use the Site from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personally identifiable information outside of those regions to the United States and by providing your personally identifiable information on the Site you consent to that transfer.
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