March 24, 2017

This Privacy Policy describes how Collective (“we,” “us,” “our”) gathers information from advertisements we serve on websites where our Services are used (“websites”) and how we may use and share this information for our business purposes, including our offering of VISTO TM and Compass by Collective TM (“Services”). For information about the data practices related to our corporate site, www.collective.com, see the Collective Website Privacy Policy.

DATA COLLECTION BY OUR SERVICES

Our clients use Services to manage and optimize their digital advertising campaigns. To provide the Services, we may collect data about your visits to websites. This data is known as Activity Information and includes IP address, web viewing data (i.e., web pages which have been viewed by you), date and time, device type, domain type, and your responses to an advertisement delivered by us or a third party advertising technology vendor. Activity Information does not immediately reveal your identity. Nor will we use this information to attempt to discern your identity. Activity Information may be collected across different websites, browsers or devices. We may use different types of technologies, such as cookies, pixels, and other technologies to collect Activity Information. These technologies help us to operate and improve our Services, provide tailored advertising (known as interest-based advertising), and to measure the effectiveness of advertising delivered through our Services. You may elect not to allow us to use Activity Information for interest-based advertising by following the Choice procedures set forth below. We do not ask for Personal Information (i.e., name, postal address, email address and telephone) for our Services. Some of the Collective partner websites may ask users to register and provide Personal Information. None of this Personal Information is combined by Collective with other data and/or used by Collective for our ad serving.

NON-SENSITIVE HEALTH DATA

Where permitted by applicable laws governing online privacy, Collective uses non-sensitive health-related data segments to serve or optimize advertisements. In order to provide transparency around these data segments, please click here to view our list.

HOW WE USE AND SHARE INFORMATION

Collective may use Activity Information collected from websites for interest-based advertising; measurement, reporting and optimization purposes; for the purpose of associating various browsers and devices together. These Services help us better target advertisements and other content to individuals in an effort to create a more relevant experience for each person. Activity Information is also used for operation and system management purposes including compliance, public purpose and consumer safety, authentication, verification, fraud prevention and security, billing or product or service fulfillment, ad reporting or delivery, and market research or product development and as otherwise permitted under the National Advertising Initiative and Digital Advertising Alliance Principles (see below). This information may also be combined with data from other sources, and shared with our affiliates and partners for similar use.

COOKIES

A cookie is a small text file placed on your browser. We use cookies, for example, to provide information to advertisers on users’ web browsing activity. This enables us and our advertiser clients to provide users with a more meaningful web experience.

CHOICE AND OPT-OUT

Collective is a member of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”), and adheres to their respective self-regulatory codes. The NAI and DAA administer programs that provide consumer awareness and choices regarding web viewing data. As a member of these programs, we provide choice via the DAA choice tool. Additionally, Collective may partner with other advertising networks and providers to deliver ads on our behalf, or on behalf of others, across the Internet. These third party companies may collect information about your visits to our website in order to provide you with more relevant advertising on other websites. If you’d like to exercise that choice with respect to Collective’s or other DAA participants’ collection and use of data from your browser or device in connection with interest-based advertising, please click here www.aboutads.info/choices. When you exercise choice, Collective places an opt-out cookie on your computer. The Collective opt-out cookie tells us not to collect data from your browser or device to tailor online advertisement campaigns. Collective may still collect data for other purposes including reporting, analytics, and other business purposes.

BUSINESS SALE

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, bankruptcy proceeding, or similar event, we reserve the right to include any information we have among the assets transferred to the acquiring company.

CHILDREN

Collective does not knowingly collect personal information from children under the age of 13 through our Services, nor via any websites. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to instruct their children to never provide personal information on any website without parental permission. If you have reason to believe that a child under the age of 13 has provided personal information to Collective, please contact us.

EU-U.S. PRIVACY SHIELD

Collective complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union or European Economic Area to the United States. To learn more, please view our EU-U.S. Privacy Shield Policy.

LINKS TO OTHER WEBSITES

We may provide links to third-party sites, which are maintained by third parties. Please be aware that we are not responsible for and cannot control the privacy policies of these other linked sites or their practices. We suggest that you visit those sites directly for information on their privacy, security, data collection and distribution policies because they may differ from Collective’s own position under this Privacy Policy.

SECURITY

We have reasonable security measures in place intended to help protect against the loss, misuse or alteration of any data collected. However, we are unable to guarantee that the security measures we take will not be penetrated or compromised or that your information will remain secure under all circumstances. We retain Activity Information used for advertising purpose for up to two years from the last interaction between our cookie and your browser or device.

CHANGES TO OUR PRIVACY POLICY

This Privacy Policy is effective as of the date listed at the top of this policy. We may change this Privacy Policy from time to time, and will post prior notice of any such changes on our website.

HOW TO CONTACT US

If you wish to contact us about this Privacy Policy, you can reach us by email at legal@collective.com or by telephone at 646.790.8575.

Collective Legal Department
250 Hudson Street, 4th Floor
New York, NY 10013