Polymorph Labs, Inc. (“Company”) is an advertising technology company in the digital media advertising space. Company is not a data broker or an advertising network. Our clients are primarily online/application publishers that utilize our platform services. Our platform ("Platform") is designed and optimized to provide publishers with the ability to sell unique advertising formats that blend and appear "native" to the content in which they are delivered resulting in a smooth and seamless consumer experience. Company is also able to provide an analysis of consumer information so that we can enable the publisher to display a more relevant, precise and meaningful online experience for its audience.
Company supports industry self-regulation and adheres to applicable industry guidelines. Company adheres to DAA principles and guidelines, and is a member in good standing of industry associations that establish best practices in the area of online advertising, including the Interactive Advertising Bureau ("IAB"), and Digital Content Next ("DCN"). Company adheres to the IAB Code of Conduct, and the SelfRegulatory Principles for Online Behavioral Advertising.
Company complies with the cross-industry enhanced notice standard as set forth in the Self-Regulatory Program for Online Behavioral Advertising.
The Company Platform does not collect information that can be used to directly identify an individual, such as your name, physical address, e-mail address, Social Security Number, credit card number, account numbers, passwords, personal health information or precise, real-time geographic location derived through location-based services such as GPS-enabled devices (collectively or individually, "Personal Identifiable Information" or "PII").
As part of the process of providing a means for publishers to sell advertising space through our Platform, we do collect information about your interaction with a given publisher’s web site or application, your web browsing activity and your device, which in some jurisdictions may be considered PII. This information may include information such as your device type (e.g., a computer, tablet, smartphone, gaming console or smart/connected TV), your IP address, device identifiers, non-precise location information, the date and time of your visit, browser type, web pages visited when viewing an advertisement, and information about your interaction with our Platform when viewing content on your device, including whether you interacted with the advertisement (viewed a video advertisement to completion or clicked on an advertisement), and what content you viewed (which advertisement we delivered to you). For example, if you visit a number of retail-based websites and browsed for sneakers, you may be flagged as being interested in purchasing sneakers or similar products. Further, advertisements relevant to the content being viewed at a given publisher’s website may also be displayed. Company also obtains non-PII such as behavioral, contextual and demographic information we can provide to publishers so that they are better able to display interestbased advertisements as well as content-relevant advertisements.
With regard to mobile users, Company may also collect carrier IDs (from US users only), information about the applications you use and the location of your device if you have elected to provide that information to the publishers with whom we have partnered
As described in the next section, since this information is collected through cookies, we require our clients to obtain any legally required consents to allow us to place cookies on their web sites and collect information from you. Even if you consent, you can revoke your consent at any time by opting out as described below.
For information that Company collects, directly or indirectly, we typically employ the use of pixel tags, cookies, beacons, mobile SDKs, iOS Identifier for Advertising (“IDFA’s”), Android Advertising ID, and Globally Unique Identifier (“GUIDs”) (“Data Indicators”) which are commonly used on the Internet and mobile applications. These Data Indicators help us understand how you use a publisher's web site and the effectiveness of an advertisement so that we can more accurately analyze the types of advertisements that are relevant to the publisher’s content and to your interests. Data Indicators do not in any way damage your operating system or files. You can refuse Company Data Indicators, but doing so may result in the receipt of the same advertisements or advertisements that do not cater to your interests. To permanently object to the placing of Company Data Indicators on your computer, you can use the opt-out process described below.
Pixel tags are small bits of code that reside on a web site and provide a method of information delivery allowing the operator of the page or a third party to collect information about the visitors to the page. Cookies are small text files that are stored on the browser of your computer that assign an anonymous identifier to your browser and provide information to the cookie sender. In addition to cookies, mobile identifiers such as device IDs that are specific to an individual’s hardware, IDFAs (iOS), GUID (Microsoft), and Android ID, as well as statistical processes are utilized to identify an individual’s browsing patterns across multiple devices with a high degree of accuracy.
Company also receives information from 3rd party data providers who collect and make available information such as behavioral, contextual, and demographic information, for our clients to use in selling advertisements through our Platform.
Company primarily uses the information collected on the Platform to provide services to its clients – essentially, we use the data to operate, manage, maintain, and enhance the Platform. Company also uses information it receives and collects through its Platform to refine, and assess, the effectiveness of the advertisements our clients display, and to avoid showing you the same advertisements repeatedly. Our analysis includes contextual and demographic elements, behaviors and viewing preferences, and we use this information to predict the characteristics and preferences of the viewers on web sites and applications that use our Platform. We report this information to our publisher clients in an aggregated, anonymous form to assist them in their advertising campaigns to their audience, and to gain an understanding of the general make-up of individuals who visit their site(s). Collectively, this information assists publishers and web site owners in selling and displaying the most precise and effective ad campaigns to their audience and allows for a more relevant and engaging advertising experience for the consumer. However, if you opt-out of our services by following the instructions below, you will no longer receive interest-based advertisements from digital publishers via Company.
Company collects Personally Identifiable Information (“PII”) from our Web site when you choose to provide it to us. For example, if you request a demonstration of our Platform or submit a resume. We use this information only to contact you to respond to your inquiry. Once collected, we will maintain your PII for as long as reasonably required to fulfill your request, carry out the purpose for which the PII was collected, or satisfy Company’s legal and business obligations.
Company also automatically collects information via the Web site through the use of various technologies, including cookies and pixel tags. We collect IP address, browsing behavior and device IDs. We use such information collected on our Web site in anonymized form for internal purposes only, to administer, improve and customize the Web site and to enable us to better understand how our Web site is being used by visitors in order to enhance their overall experience.
Company, or other parties we do business with, may place or recognize unique cookies or other technologies on your browser when you visit our Web site. Company, or these third parties, may use these cookies or other technologies to collect information about your use of our Web site and your other online activities over time and across different websites, and may use that information to serve interestbased advertisements to you as you browse the Internet. To learn more about such interest-based advertising, and to opt-out of such collection and use, please visit the below links of the NAI and DAA in the US:
Company recognizes your right to make informed decisions about information collection. Company understands that, as may be provided under applicable law, at any moment, you may exercise your right to: (1) obtain confirmation of the existence of your PII in Company’s database; (2) verify its content, origin and accuracy; (3) request its correction, updating, amendment, deletion or transformation into anonymous form and its blocking due to violations of the law; and (4) oppose the processing of your PII on legitimate grounds.
In the event you have provided PII to Company through our company Web site or Platform and wish to edit or have it removed from our database completely or to exercise your privacy rights, please contact us at firstname.lastname@example.org. Please know that in order for us to respond to your request we may require that you verify your identity.
Company is an active member of the industry associations that govern the use and policies around online consumer privacy including the IAB. Company complies with the IAB Code of Conduct, and the Self-Regulatory Principles for Online Behavioral Advertising. Company believes that these codes and principles help protect and ensure individual consumer privacy.
When you opt-out of receiving interest-based advertisements via the Company Platform, we will place a
cookie in your web browser that identifies you as opted-out. Company’s Platform will recognize your optout
cookie and will preclude publishers from using the Company Platform to display interest/contextbased
advertisements to you. However, the choice to opt-out is unique to the browser in which you set it
and you may need to repeat your opt-out election if you use a different computer or change browsers.
Also, the opt-out cookie cannot be set if your browser is configured to block third-party cookies. Opting
operation of the Web site or other legitimate purposes unrelated to serving advertisements. Information
may still be collected about your web browsing activities for these other purposes.
Click the opt-out button, if you wish to opt-out of receiving interest-based advertisements:
Applications: To opt-out of the collection and use of data on your mobile application(s), you can adjust your Device’s settings. Here are two examples for iOS and Android Devices: iOS Devices: Settings > Privacy > Advertising > Limit Ad Tracking Android Devices: Google Settings App > Ads > Opt Out of Interest-based Advertising Your opt-out process may differ from the examples above, depending on which version of operating system is installed on your Device. Further information on opting out can be found via the NAI’s Mobile Choices page: http://www.networkadvertising.org/mobile-choices.
Except for information collected through the Platform and provided to our clients, affiliates, and partners in an anonymous format to operate or enhance our services for the purposes described above, or as required by law, Company does not rent, sell or share the information collected through the Platform with third parties.
In providing its services, Company works with a variety of third-party vendors and partners. These include, publishers, data providers, content providers, and other service providers. Company may share anonymous, non-PII with them, including statistical, demographic, contextual, behavioral and predictive information, about our users and their use of the platform, to the extent necessary for Company to provide its services. Company may also enhance the non-PII collected via our Platform with non-PII collected from trusted business partners. Such information remains anonymous non-PII and cannot be used to contact or identify any person individually.
Company may share information about individuals as it deems reasonably necessary in order to comply with applicable law, to exercise and protect the legal rights of Company or its personnel and representatives, and to investigate, prevent or respond to suspected illicit activities, including fraud and threats of harm to individuals.
If Company sells all or part of its business, or if any of its departments or Platform is acquired or merged with another company, we may transfer information about you, including PII submitted by you on our Web site, to the successor company as part of that transaction. To the extent consent is required under applicable law for such a data transfer, we will obtain your consent.
The Company Platform and Web site is operated in accordance with the laws of the United States. Given that we are an international business, our use of your information necessarily involves the transmission of data on an international basis. If you are located in outside of the United States, please be aware that information we collect may be transferred to and processed in the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen. As such, whether you are located inside or outside of the United States, you hereby authorize Company to use, transfer, and/or otherwise store data in the United States and any other country where Company, our clients, or service providers operate and maintain servers.
Company has established an appropriate technical and organizational safety and security protocol consistent with industry standards and applicable law to help prevent unauthorized access, loss, disclosure, modification or destruction of the information we collect. While we are committed to ensuring the security of such information, you should be aware that no data protection measures can provide 100% guarantee of security. Consequently, Company cannot warrant or guarantee the complete security of the information in our possession.
This Web site contains links to other sites that are not owned or controlled by Company. Please be aware that we are not responsible for the privacy practices of such third parties or the privacy policies governing their web sites.
We do not knowingly collect PII from, and do not intend for publishers to sell advertisements targeted at children under 13 years of age. If you believe your child or someone else has provided Company with PII about your child and you would like to have the information removed, please contact us and we will use reasonable efforts to remove such information from our records.
As of May 25, 2018, a new data privacy law known as the EU General Data Protection Regulation (or the “GDPR”) will be in effect through the EEA countries and Switzerland. The GDPR requires Polymorph and those using our services to provide users with certain information about the processing of their “Personal Data.” “Personal Data” is a term used in Europe that means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, cookie identifiers, mobile device, precise location data and biometric data.
To comply with the GDPR, we provide the below representations and information, which are specific to persons located in EEA countries or Switzerland (so don’t rely on the below, if you’re not).
The GDPR requires us to tell you about the legal basis we’re relying on to process any Personal Data about you. The legal basis for us processing your Personal Data for the purposes set out in sections above will typically be because:
As Polymorph works with global companies and technologies, we may need to transfer your Personal Data outside of the country from which it was originally provided. For instance, we may transfer your data to third parties that we work with who may be located in jurisdictions outside the EEA or Switzerland, and which have no data protection laws or laws that are less strict compared with those in Europe.
When we transfer Personal Data outside of the EEA or Switzerland, we take steps to make sure that appropriate safeguards are in place to protect your Personal Data. For example, Polymorph is Privacy Shield certified, and thus self-certifies to protect Personal Data from the EEA and Switzerland in accordance with established data privacy principles. Feel free to contact us at the contact information below, for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances.
As a general matter, we retain your Personal Data for as long as necessary to provide our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. We generally render our own identifiers (e.g., those we use to “sync” our customers data to online users) inactive after [13 months], provided that we may retain them if we have a legal or significant operational need to do so, such as for auditing, corporate record-keeping, compliance accounting or security and bug-prevention purposes.
The GDPR provides you with certain rights in respect of Personal Data that data controllers hold about you, including certain rights to access Personal Data, to request correction of the Personal Data, to request to restrict or delete Personal Data, and to object to our processing of your Personal Data (including profiling for online ad targeting).
For excerising any of the above rights contact us at email@example.com. We will process those queries in 60 days or less. We will contact you back if that period is extended due to any difficulties.
EU data protection law makes a distinction between organisations that process Personal Data for their own purposes (known as “data controllers”) and organisations that process Personal Data on behalf of other organisations (known as “data processors”). As noted above, we are not always a data controller of the data in our possession, but are sometimes a data processor for other companies such as our customers. In such cases, we may direct your inquiry to the relevant data controller, since data controllers are the ones with primary responsibility for your Personal Data.
Company is committed to providing its clients a broad-based marketplace that meets their goals, while at the same time adhering to industry best practices with respect to content that is illegal, pornographic, discriminatory, harassing, hateful, or designed to incite violence. As an IAB member, Company holds itself to the highest standards of quality control. Company also respects the right to free speech and will not engage in pre-emptive editorial censorship. We leave such decisions to our clients. Our policy is to allow our clients to determine the most appropriate approach for their business in determining partners they choose to work with. Such policy is reflected in our technology, which enables our clients to block both sources of supply and sources of demand they may deem inappropriate.
Polymorph Labs, Inc.
300 Broadway #12,
San Francisco, California 94133
Email Address: firstname.lastname@example.org