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Introduction
Exponential Interactive, Inc. doing business as VDX.tv (“we”, “us”, or “our”) is an advertising media services company whose clients and customers are online advertisers (“Advertisers”) and digital content providers (collectively, our “Partners”). We help our Partners reach their target audiences and grow through ad sales. Learn more about us at VDX.tv.
Terminology
This policy uses the following terms:
- Personal information is used in the same way as the California Consumer Privacy Act defines it, which is essentially the same as GDPR's "personal data". This includes IP address, cookie ID and device ID.
- Personally Identifiable Information - information such as name, email address, phone number.
- Sensitive Information, or Sensitive Personal Information, also known as Special Category Data - information linking an individual to a precise geolocation, or a health condition, or ethnicity or religious categories.
- Legal basis - in EU and some other jurisdictions, legal basis must be ascertained before processing data. For the purposes of this policy, we include two legal bases:some text
- Consent - the user concerned, i.e. you, have provided consent to us directly or via one of our partners
- Legitimate interest - as a company, we have identified it is justified to process the data and doing so does not conflict with your rights, nor is it unexpected or unreasonabel for us to do so.
Purpose
This Privacy Policy describes our practices regarding the collection, use, disclosure and sale of personal information, and of the rights of consumers regarding their own personal information (collectively, “your information”) when you visit this website (VDX.tv), in relation to the services we provide our Partners, and any other means in which you interact with us, directly or indirectly. We are committed to protecting your privacy and processing your information in accordance with all applicable privacy and data protection laws, rules, and regulations, such as the European Union's General Data Protection Regulation and California's Consumer Privacy Act.
Table of contents
- Information we collect and how we use it
- Your Rights
- Data Retention
- Children's Privacy
- Health Information
- Political Information
- International Data Transfers
- Support for Industry Mechanisms
- Security
- Non-Discrimination
- Contact Information
- Changes To This Policy
Information we collect and how we use it
We may obtain personal information in one of the following ways – directly from you, via our online technology, or through our Partners.
When you visited this website, you will have been asked for cookie consent related to visiting the site, including any site analytics partners we work with.
Directly from You
We collect your information directly from you and for the following purposes when you:
- submit a job application, resume, cover letter, or social media profile to a job vacancy, or interview with us;
- enter into an employment or consulting services contract with us;
- complete forms, post content on our Site, respond to surveys, or use any features on our Site;
- provide feedback to us by phone, email, physical mail, or any other means of providing feedback;
- interact with us on our social media accounts, including without limitation LinkedIn, Instagram, X and Facebook;
- subscribe to any of our marketing materials; and
- participate in contests sponsored by us.
Our legal basis for using this data is legitimate interest in the case of candidate/employee data, and consent where the interaction has been initiated by you when e.g. submitting a "contact us" request on our website.
Further information of relevance to candidates can be found within the recruitment platform, and employee information can be found on our intranet.
We use the above data only to carry out the relevant action(s). We do not combine the above data with any data obtained via Online Technology or Our Partners. We do not sell the above data. We do not share the above data unless specifically necessary to carry out the relevant action(s).
We do not offer financial incentives associated with our collection, use, or disclosure of your personal information.
Online Technology
We may collect certain information when you visit websites or digital settings that include our online technology. Such information includes:
- Internet Protocol (“IP”) Address: An address provided by your internet service provider (“ISP”) to connect you to the internet and enable delivery of your online requests. The IP address gives a broad, non-precise, indication of geographic location.
- Cookie Identifier: A cookie (data file) with the following properties:some text
- Name: ANON_ID, Domain: tribalfusion.com, Value: a hashed value representing a pseudonymous ID, Expiry: 90 days
- Device ID: an identifier such as IFA relating to the CTV device where content is being viewed.
- User Agent: Information related to the web browser that acts on your behalf and enables your interaction with web content.
- Clickstream Data: Information about your interaction with a webpage (e.g., time and date you visited the page; webpage address; title of ad shown; topics (such as “beach” or “Caribbean”) that we interpret (as “summer vacation”) from the page.
- Viewed Content Data: Information related to video content viewed on an internet-connected TV (“Connected TV”).
We do not collect or process sensitive personal information.
In regions such as the European Union, our legal basis for collecting this information is consent, obtained via a Consent Management Platform utilizing the Transparency & Consent Framework.
Our online technology does not collect or process any special categories of information/sensitive personal information e.g. precise geolocation.
We process the above information to deliver our services of targeted online video advertising. Delivery of this service includes cross-context behavioral advertising.
We do not sell any of the above data to any other client or company. We may share data elements with our partners, only to enable our services. To carry out the relevant business purpose, those partners are acting as sub-processors or contractors and a contract will be in place.
We are not a data broker.
Our Partners
Our Partners receive your information when you visit or use their services or through third parties they work with. We require our Partners to have lawful rights to collect, use, and share your information before we receive any of your information. A list of Partners with whom we may share data, or who may share data with us, is available on our Partnerships & Accreditations page located at https://vdx.tv/partnerships.
Our Partners help us deliver our service to our clients by providing services to us such as brand safety, brand reporting, audience definition and advertising inventory.
We may use one or more of our partners to onboard offline data which may originally have included Personally Identifiable Information, however we do not use or have access to any PII as part of this process.
The table below lists the different data elements we may have processed and shared.
Your Rights
Opting Out/Deletion
Any email we may send to you for a marketing campaign, or related to a competition we may have sponsored, will feature an opt-out link.
You may request any data we may have by submitting a subject access request.
You may opt out or delete any data we may have by opting out as follows:
When you Opt-Out, your device will overwrite our cookie with a non-identifying Opt-Out cookie (“Opt-Out Cookie”). The Opt-Out Cookie indicates that your data should not be used for behaviorally-targeted advertising.
The details of the Opt-Out Cookie are shown below.
Opting Out on Connected TV devices
To manage privacy preferences around digital advertising on TV streaming devices, please refer to the device manufacturer’s instructions.
Subject Access Requests
To access any personal information we may have related to your online activity, or presence on any email lists, please do as follows:
Email Lists
Contact the originator of the email using the link in the email. If no such link exists, please forward the email to our <a href=#contact>contact email address</a>.
Online Activity
Please send the value of your tribalfusion.com ANON_ID cookie to our <a href=#contact>contact email address</a>.
The ANON_ID cookie (highlighted below in the image below) can be found in your browser’s privacy or cookie settings.
In Chrome, you will need to visit expo9.tribalfusion.com, right-click and choose "Inspect" to open Developer Tools, and find and copy the value as shown below.
Responses to Requests
In 2023, we had the following consumer requests:
*Note - this reflects emails received requesting opt-out/deletion, which were therefore directed to our opt-out link.
Data Retention
Our cookie automatically expires (i.e., is automatically deleted from your web browser) ninety (90) days from the last time we encounter you.
We retain log file data including cookie ID and IP address for one hundred (100) days for troubleshooting purposes or Subject Access Requests. Log file data is archived beyond that point if required as part of our legal and regulatory obligations, to a total duration of three (3) years.
Children's Privacy
Our Site and services are not intended for children. We do not knowingly collect, process, or sell the personal information of children under the age of sixteen (16). If you are under the age of sixteen (16), please do not access our Site or use our services. If we learn that we have inadvertently collected personal information of children under the age of sixteen (16), we will delete such information unless otherwise required by applicable law or regulation.
Health Information
We may infer health-related interests from sites you visit where our ad or pixel code is present. We do not put such code on areas of websites where medical condition or other sensitive personal information may be present.
We do not use data about you from health care providers or insurers. We may work with partners who do obtain such data, but we require them to do so according to prevailing law and regulation. In certain US states, this may mean our partners cannot obtain such data and hence we will not use the aggregated version of such audience data within our services.
Political Information
We do not have information about how you voted. We may work with partners who provide politics-related audience segments, but we require them to do so according to prevailing law and regulation. In certain US states, this may mean our partners cannot obtain such data and hence we will not use the aggregated version of such audience data within our services.
International Data Transfers
If you reside in the European Union, your personal information may be processed outside of EEA. We take all necessary steps to ensure that your information is adequately protected and processed in accordance with this Policy, using the European Commission’s Standard Contractual Clauses – European Commission-approved contracts that offer personal information the same protection as under European law.
Support for Industry Mechanisms
Transparency & Consent Framework
We are a registered vendor with IAB Europe's Transparency & Consent Framework mechanism https://iabeurope.eu/transparency-consent-framework/.
Do Not Track
We do not respond to or honor Do Not Track signals that may be transmitted by web browsers.
Global Privacy Control
We do support the Global Privacy Control signal https://globalprivacycontrol.org/.
Multi-State Privacy Agreement
We are signatories to the IAB's Multi-State Privacy Agreement https://www.iabprivacy.com/.
Security
We use commercially reasonable administrative, technical, and physical security measures to safeguard your information. Despite our efforts, please note that any information disclosed online is inherently vulnerable to interception and misuse by unauthorized parties. As such, we cannot absolutely guarantee total security of your information.
Non-Discrimination
We will not discriminate against you for exercising any or all of your rights under this policy and applicable laws and regulations. We will not:
- Deny you services;
- Charge you different prices or rates for services by granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of services; or
- Suggest that you may receive a different price or rate for services or a different level or quality of services.
Contact Information
Please contact us with any questions about this Policy using the information below:
United States Address
Exponential Interactive, Inc. d/b/a VDX.tv
Attn: Legal Department
2340 Powell Street, #378
Emeryville, CA 94608
U.S. Phone
U.S. toll-free number +1 (800) 480-0816
Emeryville local office number +1 (510) 250-5500
To protect the security of your information, we will take steps as we deem necessary to confirm your identity or the identity of your Authorized Agent or valid power of attorney before completing a request or sharing any personal information with you or your Authorized Agent or valid power of attorney.
Changes To This Policy
We reserve the right to update this Policy at any time and for any reason. We will notify you about any changes to this Policy by updating the “Last updated” date at the top of this Policy. In some cases, we may also notify you of Policy updates by adding a statement to our Site homepage, via email, or by any other means of communication allowed by law.
We encourage you to review this Policy from time to time to stay informed about our privacy practices and your options. By continuing to access or use this Site after those updates become effective, you agree to be bound to the terms of the then-current Policy.