Last Updated: October 11th, 2023
- Information We Collect from Third Parties
- How We Use Information Collected from Third-Party Service Providers
- How We May Use of Both Sets of Personal Information
California Residents: If you are a resident of California, please see the Datum Privacy Notice and Addendum for California Residents for more information pursuant to the California Consumer Privacy Act (“CCPA”) (as amended by the Consumer Privacy Rights Act (“CPRA”), which provides you with additional information and choices as to how we process your Personal Information.
Texas and Virginia Residents: If you are a Texas or Virginia Resident, please see the Datum Privacy Notice and Addendum for Texas and Virginia Residents, which provides you with additional information and choices as to how we process your Personal Information.
This Policy addresses both information collected about devices and households from third parties as well as information collected directly regarding and website visitors through this website. Most of the information we handle is not collected directly on this website, but rather indirectly through relationships we have with other companies such as data suppliers, business partners (such as ad networks and other online partners), data services providers, agencies, and our clients (“Information Obtained from Third Parties in Providing Services”). We provide this Policy and the aforementioned section as a service to consumers and others who want to learn more about the data we handle and how we use it. If you are particularly interested in the information we collect directly on this website, please go to the section below titled “Information From Website Visitors and Potential Customers.”
This website itself is primarily directed to businesses or other organizations that may wish to use our services, but we welcome consumers who want to know more about our services. When you access our website or engage with us by email, we may collect the following information:
- Personal Information. When you provide us with information through our website, such as to request or download information, sign up for a newsletter, event or service or log in to a service or application we provide, we may request, and you may provide certain personal information to use. We may use your personal information for any business purposes, including to administer your account and provide you services, to send communications and administrative emails, to respond to your inquiries, and to send marketing and product update messages. We may also use it to analyze how customers are using our website or our products and services.
- Non-Personal Information. Whether or not you sign up for an account or provide us with personal information, we may collect other information when you visit our website. This may include:
- (i) The type of browser and operating system you have used to access the website, a timestamp, and other browser or device information.
- (ii) Your IP address (which is a number automatically assigned to your computer when you access the Internet and can be used to derive your general geographic location);
- (iii) Your clickstream data and any URL referral information (such as any website or social media platform that referred you to our website)
- (iv) What part(s) of our website you visit, click and view, and how long you view it;
- (v) A unique identifier, which we may associate with a cookie, device identifier or similar technology.
We may collect or store the above information by using cookies, web beacons, and similar technologies. These technologies and analytics tell us, for example, how many users visited our Sites, what pages have been browsed, and from what geographic regions users visited the Sites. The information collected through the use of analytics may include, for example, your IP address, the website from which you visited us, the type of device you used and your search query that led you to the Sites. Your IP address is masked on our systems and will only be used on a need-to-know basis to resolve technical issues, to administer our Sites and to understand visitor preferences. Traffic information on our Sites is accessed only by authorized personnel.
We do not use any of this information to directly identify visitors and we do not share it with third parties. We process personal information for these purposes because we have a legitimate interest in understanding how our Sites are used. Our websites are not designed to respond to “do not track” signals received from browsers. Please see the Section “Cookies and other Tracking Information” below for further information, and click on the cookie settings within the banner on our website to adjust your preferences.
To the extent you receive emails or other communications from us, you may opt out of such communications by clicking on the “opt-out” button included in such communication, or by emailing us at email@example.com.
The purposes for which we may process personal information will vary depending upon the circumstances and your relationship with us. In general, we use personal information collected from our customers and website visitors for the purposes of:
- Operating our network, services and websites, and providing related support, including communicating with you about your use of our websites and services, provide troubleshooting and technical support, undertake bug-prevention in our services, respond to your inquiries, process your payments, communicate with you, and for similar service and support purposes.
- Measuring and improving our sites and services.
- Providing you with information and services you request, including to respond to your inquiries and fulfill your orders and requests.
- Fulfilling transactions, including sending invoices, authorizing and conducting transactions, processing payments, etc.
- Customizing content, advertising, and your experience on the Datum network using our services and websites, including to tailor content we may send or display to you such as to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
- Communicating with you about service updates and other administrative issues.
- Analyzing site and user behavior and prepare aggregated reports.
- Telling you about our products and services and those of our corporate family, as well as for direct marketing and advertising purposes, including sending you newsletters, alerts and information we think may interest you. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them.
Aggregate, De-identified or Anonymous Data: We also create and use aggregate, anonymous and de-identified data to assess, improve and develop our business, products and services, and for similar research and analytics purposes. This information is not generally subject to the restrictions in this Policy, provided it does not identify and cannot be used to constitute personal information.
Datum employs micro-targeted mobile technology to reach audiences at a household level without the need for IP addresses or cookies. Specifically, we combine precise mobile device data with land survey and other data to ensure that we can place targeted advertising to audiences at a high level of accuracy by serving mobile ads on such devices. We collect mobile device and other geolocation data from third-party service providers, who in turn collect such information through mobile apps and services that incorporate the third-party service provider’s SDK technology. We also collect voter records and other information from third party service providers to help build accurate audiences fitting the needs of our customers’ advertising campaigns. We then place targeted advertising to mobile devices fitting such characteristics.
None of the information we collect, either directly or indirectly, includes information that would directly identify an individual (e.g., name, social security number, ID, etc.). However, the combination does associate a particular mobile device or group of mobile devices with a particular household.
Most of the personal information we collect from consumers in performing services are collected from third-party service providers. The actual personal information we collect, and how we use it, depends on the information available from such third parties as well as the needs of our clients.
Such third-party information may include:
- Mobile device data. A media access control address (“MAC address”), is a unique attribute used to identify individual electronic devices on a network. Some devices have multiple MAC addresses.
- Geo-location data. Latitude and longitude data associated with a mobile device number for a particular moment in time.
- Land records. Publicly available residential parcel and building footprint data.
- Voter records. Information regarding voting records, political affiliations, and other similar data associated with a particular parcel or address.
- Interest Other information about particular interests, issues, preferences, etc. associated with parcels or addresses associated with the MAC addresses at a given moment in time.
- Point of Interest Data. Specific geographic locations that have been designated as significant or noteworthy, such as landmarks, businesses, and attractions. This data can include the name, type, location, and other attributes of the point of interest.
- Data from Demand-Side Platforms (“DSPs”). Information collected from DSPs, including unique device IDs for tracking and ad performance metrics such as clicks and impressions.
By collecting, combining, and organizing this data, we are able to associate certain characteristics with a particular device or group of devices (often a group of devices) within a particular location. We then use the combination of mobile device numbers and data segments to conduct targeted advertising to particular audiences through mobile or other forms of cross channel advertising that fit the needs of our clients. These may be political campaign messages or commercial advertising.
Importantly, none of the information we collect is associated with a particular identity (i.e., name or other identifying characteristic) of an individual, but rather anonymous profiles built around a mobile device or group of mobile devices associate with a particular area. Indeed, because the average household often has multiple devices within the home, such combined data is often aggregated around a group of device numbers, and not any particular device within the household.
- To build audiences for our customers that meet their political or advertising campaign needs.
- To combine with other data collected from third-party service providers associated with a given mobile device number.
- To place targeted advertising to mobile and other devices collected from our third-party service providers consistent with the political or advertising campaign needs of our customers.
- To share with our customers so that they may place targeted advertising.
- Protect our legal rights and preventing misuse, such as to protect our websites, business operations; enforce agreements and resolve disputes; prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of this Policy
- Comply with our legal obligations, for example to comply with the law or legal proceedings, including to disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements, or respond to requests in connection with litigation or dispute resolution
- Related to our general business operations, for example to implement mergers, acquisitions, reorganizations, and other business transactions (including any related negotiations), and where necessary to the administration of our general business, accounting, recordkeeping and legal functions
Generally, we may share personal information as follows:
- Affiliates. We may disclose your personal information to our affiliated companies whose handling of personal information is also subject to this Policy.
- Service Providers. We may disclose your personal information to our service providers so they can perform services on our behalf, such as our payment processors, hosting providers, auditors, advisors, consultants, and customer service and support providers.
- Business transfers. As our business evolves, we may sell, transfer or otherwise share some or all of its assets in connection with a financing, merger, reorganization or sale of assets, or in the event of bankruptcy. We may disclose or transfer information, including personal information, as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event, including related to due diligence conducted prior to such event where permitted by law.
- Legally required. We may disclose your information if we are required to do so by law (e.g., to law enforcement, courts or others, in response to a subpoena or court order including national security or law enforcement disclosure requirements).
- Protect our rights.We may disclose information where we believe it necessary to respond to claims asserted against us, resolve disputes or comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of us, our clients, and others.
The information we collect and use for our third-party services is typically only shared with third-party service providers retained to perform services on our customers’ behalf, and who are contractually bound to confidentiality and use restrictions with respect to such data. Since we typically conduct the targeted advertising ourselves on third-party platforms according to our customers’ specifications, we do not typically share this personal information with third parties (including customers) in the normal course of business.
Occasionally, we will share the combined data sets (which again, reveal mobile device numbers combined with parcel data and other characteristics associated with the parcel or household, but which are unassociated with names or other personally identifying information) with our customers so that they may directly conduct targeted advertising or campaigns themselves. To the extent such sharing is considered “selling” the data, in such instances, we honor the right of certain individuals to opt out of such sharing. To review such rights, please see the section “Choices and Rights With Respect to Your Data.”
Managing your cookie preferences: You can manage your cookie preferences for our websites and opt out of certain cookies by editing your browser options as explained below.
Cookies: Cookies are alphanumeric identifiers that we transfer to your device or computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Some of the Services may not work properly if you disable cookies.
Clear GIFs, pixel tags and other technologies: Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our services to, among other things, track the activities users of our services, help us manage content, and compile statistics about usage of our services. We and our service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Do not track (DNT): Our Sites currently do not respond to “do not track” signals. You may, however, disable certain tracking mechanisms in the cookie preference settings of your web browser and opt out of certain third-party ad cookies on our websites.
- Interest-based Ads. As part of the Datum Network, we provide mobile ad measurement, analytics, and other ad services to our customers. For that purpose, we may collect or receive mobile device information and location information from third-party service providers who receive such information from tags and software development kits (“SDKs”) incorporate into apps and other services you download from your mobile device. This information is used by us or our customers or third parties to serve you personalized content and ads, measure ad performance, and conduct related analytics and reporting. Because we do not directly collect this information, but rather we procure it from our third-party service providers, we cannot directly prevent the collection of such information by our third-party service providers; however, you may be able to opt out of their collection of such information by adjusting your device privacy settings:
- For iOS Users: Navigate to your Settings > Privacy > Advertising and turn on/enable the “Limit Ad Tracking” setting. (More information on how to opt-out from sharing your advertiser ID: https://support.apple.com/en-us/HT202074)
- For Android users: Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising.” (More information: google.com/policies/technologies/ads/)
Note that if you later start sharing your Advertiser ID (i.e., by changing the privacy settings for your device), your opt-out will no longer be effective. Please note that if you opt out of sharing your Advertiser ID, advertisers and publishers will not be able to use your Advertiser ID for any targeting or tracking through your device.
As noted above, you may also control how we or third parties display certain ads to you, as explained further in the respective privacy policies and ad preferences pages. You can learn more about the information collection practices and “opt-out” procedures of many third-party ad companies by visiting www.networkadvertising.org/optout_nonppii.asp. You can also obtain more information about targeted advertising, and how to opt out of targeted advertising by participating members, through the following: U.S. Users: www.aboutads.info/choices (Digital Advertising Alliance)
Opting out of participating ad networks does not completely opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs. Please note that these tools only prevent collection of data pertaining to you on the browser on which they are installed, and will only function if your browser is set to accept third-party cookies. If you delete an opt-out cookie from a browser’s cookie files, we will collect data from that browser until an opt-out cookie is reset on that browser; so, if you delete cookies, block cookies or use another device, your opt-out will no longer be effective.
- Marketing Communications. We may send periodic direct marketing communications or promotional emails to our customers. You may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to ten (10) business days for us to process opt-out requests. Please note that if you opt out of receiving emails about recommendations or other information, we think may interest you, we may still send you emails about your account or any services you have requested or received from us.
- Links to Third-Party Sites. Our websites and services may contain links to other third-party websites and applications. Any access to and use of such linked websites and applications is not governed by this Policy but instead is governed by the respective privacy policies of those third parties. We are not responsible for the information practices of such third-party websites or applications, and we encourage you to review the privacy policies of such third parties prior to engaging on such third-party websites.
Datum’s website and services are not targeted to children under sixteen (16) years of age. If we discover that a child under 16 has provided us with personal information, we will delete such personal information from our systems. If you believe that we might have collected information from a child under 16, please contact us at firstname.lastname@example.org.
This Policy is current as of the Last Updated date set forth above. We may change this Policy from time to time at our sole discretion, so please be sure to check back periodically. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change, such as by changing the effective date of the Policy or notifying you at your email address of record, if such email address is within our possession. Your continued use of the website and our services following a change in the Policy represents your consent to the updated Policy to the fullest extent permitted by law.
If you have any questions about this Policy or our privacy practices, you may contact us at email@example.com.