Amazon Ad Server Privacy Policy
Privacy Practices for Our Amazon Ad Server Websites (e.g., www.sizmek.com)
Amazon Ad Server (formerly known as Sizmek Ad Server) (“we” and “us”) firmly believes in theimportance of online privacy. We do not collect information that enables us to determine your actual
identity before, during or after your visit to this corporate website (sizmek.com) or our regional sites
accessible from this website (the “Amazon Ad Server Websites”), other than information that you
voluntarily supply to us (e.g. by submitting information through the “Contact Us” form). We may,
however, automatically receive and store certain other information, such as your IP address andbrowser type, when your device accesses our site, and we also use cookies on Amazon Ad Server
Websites for purposes such as counting website visits and recording unique or repeat visitors. In
some areas of the world, information such as IP addresses, cookie identifiers and device identifiers
may be considered to be personal information (sometimes referred to as personal data) that is
protected under applicable laws. Where this is the case, we comply with applicable laws regarding
our use and processing of personal information.
You can learn more about opting out of our use of cookies in the Opt-Out Options and Additional
Information section below.
Amazon Europe Core S.à.r.l. acts as a data controller for the processing of personal data related to
the Amazon Ad Server Websites and our business and as a data processor for information wecollect and process on behalf of advertisers, advertising agencies, publishers, and other users of
Amazon Ad Server services in the European Economic Area and the United Kingdom. If you havequestions about privacy at Amazon Ad Server, you may contact us using the contact details
provided under the “If You Have Questions About This Policy” heading below.
For What Purposes Does Amazon Ad Server Use Your Personal Information?
Amazon Ad Server uses personal information that you provide us or that is collected by us when you
interact with our Amazon Ad Server Websites and other Amazon Ad Server content to operate,
provide, develop, and improve our products and services. These purposes are listed in more detailbelow:•

Sale and delivery of our products and services. We use your personal information to
manage and deliver orders and subscriptions, process payments, and communicate with you
about orders, products and services, and promotional offers.

•

Provision, troubleshooting, and improvement of our services. We use your personal
information to provide functionality, analyze performance, fix errors, and improve the usability
and effectiveness of our services.

•

Recommendations and personalization. We use your personal information to recommend
features, products, and services that might be of interest to you, identify your preferences,and personalize your experience with our services.

•

Compliance with legal obligations. In certain cases, we collect and use your personal
information to comply with laws. For instance, we may collect certain information regarding
place of establishment and bank account information for recordkeeping and compliancepurposes.

•Communicate with you. We use your personal information to communicate with you in
relation to our services via different channels (e.g., by phone, e-mail, or chat).

•

Advertising. We use your personal information to display interest-based ads for our
features, products, and services that might be of interest to you. We do not use informationthat personally identifies you to display interest-based ads.

•

Fraud Prevention and Credit Risks. We use personal information to prevent and detectfraud and abuse in order to protect the security of our customers, affiliates, and others. We
may also use scoring methods to assess and manage credit risks.

For information on how Amazon Ad Server uses personal information collected and processed
through Amazon Ad Server services on behalf of our customers, please refer to the “Data Collection
through Amazon Ad Server Services” section below and related sections. For the purposes of thisPrivacy Notice, “our customers” refers to advertisers, advertising agencies, publishers, and otherusers of Amazon Ad Server services.
Data Collection through Amazon Ad Server Services
What does Amazon Ad Server do?
Through our services, our customers may collect and use information about your device to provide
you with a more tailored online advertising experience. Our customers use Amazon Ad Server’s
tools and services to create and deliver advertisements (also referred to as ad serving), to monitor
the success of and manage advertising campaigns, to detect and minimize advertising fraud and,ultimately, to present you with advertisements that are more likely to be interesting and relevant toyou. When providing these services to our customers, Amazon Ad Server acts as a service provider,
except with respect to providing cross-context behavioral advertising services (as defined by the
California Privacy Rights Act). This means that the customers are responsible for the processing of
personal data relating to you, while Amazon Ad Server processes such data based on thecustomer’s instructions.
How does Amazon Ad Server deliver advertising on behalf of our customers?
Amazon Ad Server’s cookies and similar technologies (described below) are deployed on yourdevices, and through the third-party websites and mobile applications you use. The information wecollect is associated with your cookie identifiers and/or mobile advertising identifiers (if you are usinga mobile device), as well as your IP address. We never collect information about your actual identity.
As explained above, our technology employs cookies, device identifiers and similar technologies(like pixels and statistical device identifiers) to collect information about your browser or device, thesites it has visited and the apps it has used, the advertisements served to it, interactions with those
advertisements, and, where available, the approximate geographic location of the device (“adserving information”).
We use the ad serving information we collect to deliver an advertisement to you from a company
who engages our services and to measure engagement with such advertisement. This information iscollected in the course of providing our customers with ad-serving and campaign management
services and is used for the purpose of helping our customers determine which advertisement issuitable to be delivered to you.
This ad serving information, which does not enable Amazon Ad Server to determine your actual
identity, may be shared with our customers and Amazon Ad Server’s and our customers’ partners forour customers’ advertising purposes. We use reasonable efforts to require our customers andpartners to treat the information we share with them in accordance with applicable laws, the terms ofthe contracts we may have with them, and their own privacy policies.
Cross-device advertising
We use the term “device” or “devices” to refer collectively to computers and mobile devices, as wellas the internet browsers and other applications on your devices that interact with the internet.
Amazon Ad Server may engage in cross-device data collection, which refers to the process ofcollecting data from separate devices that have been determined through statistical analysis to belinked or related, on behalf of our customers. Amazon Ad Server, or partners that we employ toprovide this service, use cross-device data to provide advertising services to our customers and todeliver tailored ads to users across multiple devices.
Information Collected by Customers and Their Partners
Please note that Amazon Ad Server customers sometimes include their own (or their partners’) adtags, pixels or similar technologies within advertisements that Amazon Ad Server serves to websites
for those customers. Amazon Ad Server does not control such collection or processing and we use
reasonable efforts to require customers to treat such information in accordance with applicable laws
and their own privacy policies.
In addition, if you visit a website or mobile application that uses Amazon Ad Server services, or clickthrough an ad to the website or online service of one of our customers, those customers may collectadditional information about your visit beyond the information described in this privacy policy. They
may also allow other companies (such as other ad networks or web analytics services) to collectinformation through mechanisms such as cookies, pixels and similar technologies.
Amazon Ad Server is not responsible for and cannot control the data collection and use practices of
its customers or their partners. You should read the privacy notices of the websites you visit and theonline services and interactive ads that you use to understand what information companies collectand how they use that information.
On occasion, at the request and on behalf of a customer, Amazon Ad Server may collect personal
information supplied voluntarily by consumers through their interaction with data collection fields inthe body of advertisements or on websites (such as name, email, etc.). This personal information isprovided directly to the customer on whose behalf the information was collected, or the customer’s
service providers, and is processed by Amazon Ad Server only to the extent and as long as isnecessary to provide the advertising services for which the personal information was collected.
Amazon Ad Server is not responsible for its customers’ use of this voluntarily supplied data. Amazon
Ad Server does not distribute this personal information to any party other than those indicated within
the advertisement or, at the customers’ direction, their service providers. Amazon Ad Server neverassociates any of this personal information with any other data (such as ad serving information)gathered or used in the delivery of advertisements.
Links to Other Sites
Our site and the advertisements we serve on behalf of customers may contain links to other sites
whose information practices may be different from ours. In addition, there may be links to other sites
provided within the body of advertisements on other websites. We do not have control over the
information that is submitted to, or collected by, these third parties. You should consult the privacy
policy of these other sites to learn how your privacy is protected.

Privacy Practices for Advertising and Content Served by Amazon Ad Server
We respect your right to privacy throughout all of the services we provide. In particular, Amazon Ad
Server adheres to the principles of the Digital Advertising Alliance (DAA) and the European
Interactive Digital Advertising Alliance (EDAA) regarding our use of data for interest-based
advertising purposes. Delivering relevant ads, on behalf of our customers, that are tailored to users’interests is known as “interest based advertising” (sometimes also referred to as “behavioral
advertising” or “targeted advertising”).
We also subscribe to the policies of the IAB Europe Transparency and Consent Framework, as aregistered vendor on the Global Vendor List. For more information about these organizations, theirpolicies and interest-based advertising, please visit their websites by clicking on the following links:
DAA (here), EDAA (here), or the IAB Europe Transparency and Consent Framework (here).
Data Security and Retention
We have appropriate technical and organizational security measures in place to help protect thepersonal information that is submitted to us voluntarily through our web site or collected throughinteractions with our services. However, no system can be completely secure, and we make noguarantees as to the safety or security of any information transmitted to or from this site or throughour services. Amazon Ad Server retains cookie information and information we receive from yourdevice in log files for up to 13 months from the time it is stored, after which time the information isdeleted.
Our Use of Advertising Technologies
This section provides additional information about the various technologies that Amazon Ad Serveruses to manage Amazon Ad Server Websites and to deliver ads to you and services to ourcustomers, including services that collect ad serving information when you interact with ourcustomers’ ads or the sites and applications where their ads are provided.
Cookies
We use cookies to provide functionality to Amazon Ad Server Websites and also to deliver our
advertising services to our customers. A cookie is a small text file that can be stored on yourcomputer or device when you view an advertisement or website relating to one of our customers.
The cookie does not contain your name, address, phone number, email address, or anything thatenables us to determine your actual identity. Instead, Amazon Ad Server uses cookies to collectinformation such as a computer’s IP address, the type of the computer’s operating system, the typeof internet browser software, what web pages were viewed and at what time. A common use of
cookies (on behalf of our customers) is to determine if a particular ad has already been served to a
specific device and to cap the frequency at which that ad is presented to the same device.
To learn more about the cookies we serve (including how to opt-out of them), please visit the OptOut Options and Additional Information section below.
Mobile Advertising Identifiers
Most mobile devices include an identifier that allows application publishers and marketers to trackuser activity on mobile devices for advertising purposes (for example, Google’s Android Advertising
Identifier (AAID) and Apple’s Identifier for Advertising (IDFA)). Amazon Ad Server may use mobile
advertising identifiers for the same purposes for which we use cookies and statistical identifiers,
including serving ads on behalf of its customers.

Log files
Like most websites and advertising services providers, we gather certain information when you visit
or interact with Amazon Ad Server Websites and on our customers’ behalf when you encounter ourcustomers’ ads and websites. This information is collected automatically and stored in log files. This
information includes internet protocol (IP) addresses, browser type, internet service provider (ISP),
referring/exit pages, operating system, date/time stamp, and clickstream data. This information,
which does not allow us to determine your actual identity, is used for purposes such as administering
the site and the services, analyzing trends, and measuring user engagement with content.
Pixels (also known as Clear Gifs)
On behalf of our customers, we may employ advertising pixels (a.k.a. clear gifs) on websites andadvertisements that interact with some of our services. Pixels help our customers better manage
content and advertising on websites by informing as to what content is effective. Pixels are graphics
embedded invisibly in web and advertising content and are about the size of the period at the end of
this sentence. Pixels work with cookies to record the interactions of users with websites andadvertisements.
Statistical Identifiers and Cross-Device
Like pixels, statistical identifiers help to better manage content and advertising on devices by
informing (without using cookies) as to the content with which users interact. Statistical identifiers
collect various information about a device, such as screen resolution, browser type, or operating
system. Devices may have unique, or near unique, device profiles and so collecting this information
helps to determine to a reasonable level of statistical accuracy the level of users’ engagement with
our website or our customers’ advertisements and websites and to recognize the devices of users
who interact with our or our customers’ content. The information gathered through the use ofstatistical identifiers is not associated with any information that would enable us to determine anindividual’s actual identity. Our customers use Amazon Ad Server’s cross-device solutions to tailor
advertising experience across all devices, such as a computer, mobile phone and tablet. For
example, using cross-device solutions, advertisers can limit the number of times you see the samead on multiple devices, or serve you a follow-up ad on your computer after you have seen a related
ad on your mobile device.
Information Relating to Children
Our products and services are not designed or intended for children (as defined in applicable dataprotection laws). We do not knowingly collect personal information from children on the Amazon Ad
Server Websites or through our services. Please advise us if you are aware of our having received
personal information from a child, in which case we will take appropriate steps to delete it. For these
purposes, “children” and “child” refer to ages defined by applicable law in the countries where we
provide our services.
International Data Transfers and Privacy Shield Compliance
The personal information Amazon Ad Server processes may be transferred to, and processed in,any country in which we, our group companies, or our service providers or partners operate, and thismay include countries other than the country in which you are resident. These countries may havedata protection laws that are different from the laws of your country. However, we have taken
appropriate safeguards to require that your personal information will remain protected in accordancewith this Privacy Notice. In particular, Amazon Ad Server complies with the EU/UK-US Privacy

Shield Framework and the Swiss-US Privacy Shield Framework. Click here to learn more.
Additional State-Specific Privacy Disclosures
Amazon Ad Server is a service provider or processor, as defined by the California Privacy Rights Act(CPRA) or the Virginia Consumer Data Protection Act, respectively (collectively, the “State Privacy
Laws”), for personal information that we process on advertisers’ behalf pursuant to our agreementswith them, except, where the CPRA applies, for cross-context behavioral advertising (as defined in
CPRA). Click here to read additional state-specific privacy disclosures required under applicablelaws.
IAB Europe Transparency and Consent Framework
Amazon Ad Server subscribes to the policies of the IAB Europe Transparency and Consent
Framework, as a registered vendor on the IAB Europe’s global vendor list. We process personal
data for the purposes described in this privacy policy. For more information, please
visit https://iabeurope.eu/transparency-consent-framework/.
Legal Basis and Purposes for Processing
If you are a user from the European Economic Area or the United Kingdom, our legal basis forcollecting and using the personal information described above will depend on the personal
information concerned and the specific context in which we collect it.
However, we will normally process personal information from you only where we have your consent
to do so, where we need the personal information to perform a contract with you, or where theprocessing is in our legitimate interest and not overridden by your data protection interests or
fundamental rights and freedoms. In some cases, we may also have a legal obligation to collectpersonal information from you or may otherwise need the personal information to protect your vitalinterests or those of another person (for example, to process your request to exercise your rights
regarding your personal data).
If you have questions about or need further information concerning the legal basis on which wecollect and use your personal information, please contact us using the contact details provided underthe “If You Have Questions About This Policy” heading below.
Your Data Protection Rights
You have the following data protection rights:•

If you wish to access, correct, update or request deletion of your personal information,
you can do so at any time by contacting us using the contact details provided under the “If
You Have Questions About This Policy” heading below or via this web service.

•

In addition, if you are a resident of the European Economic Area or the United Kingdom, you
can object to processing of your personal information, ask us to restrict processing ofyour personal information or request portability of your personal information. Again, you
can exercise these rights by contacting us using the contact details provided under the “If
You Have Questions About This Policy” heading below or via this web service.

•

You have the right to opt-out of marketing communications we send you at any time. You
can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing (such as postal marketing ortelemarketing), then please contact us using the contact details provided under the “If You
Have Questions About This Policy” heading below.
•

Similarly, if we have collected and process your personal information with your consent, then
you can withdraw your consent at any time by exercising your opt-out options. Withdrawing
your consent will not affect the lawfulness of any processing we conducted prior to yourwithdrawal, nor will it affect processing of your personal information conducted in reliance on
lawful processing grounds other than consent.

•

You have the right to complain to a data protection authority about our collection anduse of your personal information. You can file a complaint with our principal supervisory
authority, the Commission Nationale pour la Protection des Données in Luxembourg(www.cnpd.lu), or with a local authority.

•

We respond to all requests we receive from individuals wishing to exercise their dataprotection rights in accordance with applicable data protection laws.

Third-Party Disclosures
We may disclose your personal information to the following categories of recipients:•

To our group companies, third-party services providers and partners who provide dataprocessing services to us (for example, to support the delivery of, provide functionality on, or
help to enhance the security of the Amazon Ad Server Websites), or who otherwise process
personal information for purposes that are described in this privacy policy or are notified to
you when we collect your personal information;•

To any competent law enforcement body, regulatory, government agency, court or other third
party where we believe disclosure is necessary (i) as a matter of applicable law or regulation,(ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or
those of any other person;•

To a potential buyer (and its agents and advisers) in connection with any proposed
purchase, merger or acquisition of any part of our business, provided that we inform thebuyer it must use your personal information only for the purposes disclosed in this privacy
policy;•To any other person with your consent to the disclosure.

Changes to this Document
Amazon Ad Server reserves the right to change, modify, add or remove portions of this policy at any
time and without notice. We encourage you to review this page periodically for the latest informationon our privacy practices.
If You Have Questions About This Policy
To address any questions, comments, or concerns related to our privacy policy, please contact our
Amazon Ad Server Support by email at or by phone at +1 (866) 438-5552.
If you are a visitor from the European Economic Area or the United Kingdom, the controller of any
personal information processed about you by Amazon Ad Server is Amazon Europe Core S.á.r.l.,who can be contacted using the details provided above. Amazon Ad Server’s representative in theEuropean Economic Area or the United Kingdom may be contacted at dpo@sizmek.com.
Opt-Out Options and Additional Information
Opt-out choices
Amazon Ad Server provides the following options for controlling your choices or opting out of
Amazon Ad Server data collection for ad serving and for interest-based advertising. These settingsmust be performed on each device (including each internet browser on each device) for which you
want to opt out. For more information on Amazon Ad Server’s data collection and processing policies
and practices, please review this entire Privacy Policy. Since privacy controls change and are
updated from time to time, Amazon Ad Server may modify the following options and information at
any time.
Your opt-out status for this browser: Opted-In
For mobile and other data collection methods, see the table below.
OPT-OUTOPTIONDESCRI PTION

You can opt out of cross-context behavioral ads. Crosscontext behavioral ads use data from one site or app toadvertise to you on a different company's site or app.
Your Privacy
ChoicesIf you opt out, we won’t deliver cross-context behavioral ads
to you.
We’ll continue to share your data with Amazon, our parent
company. We will also set the Amazon Ad Server opt-out
cookie for the browser in which your opt-out choice is made.

Advertising
Industry Sites forControl ofInterest-Based
Advertising

Amazon Ad Server participates in advertising industry selfregulatory programs that allow users to opt-out of interestbased advertising (aka online behavioral advertising) bymultiple digital advertising service providers, including
Amazon Ad Server. To do this, the following advertisingindustry programs maintain sites that enable user controls forinterest-based advertising:• Digital Advertising Alliance (DAA)• European Interactive Digital Advertising Alliance(EDAA)

HOW TO SELECT T HIS OPTOUT OPTION A ND
ADDITIONAL
INFORMATION

Click Here to opt-out.
If you have previously opted out,
and would like to reverse yoursetting, Click Here to opt back in.
To opt-out on mobile devices andmobile apps, see Mobile Opt-Out
Methods below.

DAA: To opt-out of interest-based
advertising by DAA’s
participating companies, visit the
DAA site here.
EDAA: To opt-out of interestbased advertising by EDAA’s
participating companies, visit the
EDAA site here.
For additional information, visit
the sites identified above andsee Your Advertising Choices andThird Party Services in our privacy
policy.

Digital
Advertising
Alliance
AppChoices App

Installing the DAA AppChoices app on a mobile device
permits the user to control interest-based advertising inapplications on that device.

For more information and to
download AppChoices for yourmobile devices, visit the DAA
page here or visit your device’s
app store and search for“AppChoices”.

Other Opt-Out
Methods

Amazon Ad Server’s cookie or other third-party cookies may
not be available on certain browsers or devices. In suchsituations, use one of the other applicable opt-out options
described in this table. In some cases, you may also be able toopt out by visiting applicable advertiser, publisher, or provider
sites that support additional opt-out options.

For additional opt-out options notaddressed above, you may also
refer to applicable advertiser,
publisher, or provider websites orother online properties.

MobileAdvertising
Identifiers

Use mobile device settings to stop or limit interest-based
advertising on that device.

For instructions for using theadvertising choice mechanisms
provided by the most popularmobile operating systems, visit the
NAI’s Mobile Choices page here.
For additional information,
see Mobile Opt-Out
Methods below.

Cross-Device OptOut Guidance

Cross-device solutions attempt to tailor your advertisingexperience across all devices that may belong to you, such as
your computer, mobile phone and tablet. For example, using
Amazon Ad Server’s cross-device solutions, advertisers canlimit the number of times you see the same ad on multiple
devices, or serve you a follow-up ad on your computer after
you have seen a related ad on your mobile device. Note that
our cross device solution is based on probabilistic data only,
which means we are guessing which devices belong to thesame person but don’t actually know if they do.

To stop cross-device identification
by Amazon Ad Server, use the
opt-out options noted above oneach device that you use.
For additional information,
see Cross Device Opt-Out below.

Browser Opt-Out Methods
To opt-out on internet browsers, use the Your Privacy Choices option or Advertising Industry Sites
for opt-out of Interest-Based Advertising methods described in the menu above. This process willstore the Amazon Ad Server opt-out cookie in your browser, which allows us to recognize thatbrowser in the future and respect your opt-out preferences for that browser. The cookie will apply tothe specific browser you are using; if you wish to opt out for other browsers that you use, you must
repeat the process using these browsers. All other cookies associated with your browser will remain
intact and your opt-out will be effective with respect to the browser used as long as you do not delete
the cookie file from your hard drive. Please note that if you erase all cookies from your computer,
you will also erase our opt-out cookie and will need to repeat the process of opting out.
Mobile Opt-Out Methods
Mobile device system software offered by companies such as Apple and Google provides devicebased opt-out choices that are transmitted to companies providing interest based advertising on

mobile devices, which is sometimes referred to as cross-app advertising. Mobile device browsers
and applications may also provide certain privacy controls. Most mobile devices offer you the ability
to stop the collection of location information at any time by changing the preferences on your device.
For instructions for using the advertising choice mechanisms provided by the most popular mobile
operating systems, please click the following link to the NAI’s Mobile Choices here. To opt out of
Amazon Ad Server interest-based advertising on mobile devices, use the following methods
described in the menu above: Digital Advertising Alliance AppChoices App, Mobile Advertising
Identifiers, Cross-Device Opt-Out Guidance, and Precise Location Data.
Statistical Identifier and Cross-Device Opt-Out
To effectively opt-out of our cross-device data collection activities (which leverages statistical
identifiers), consumers must opt-out on every device browser and device using the Browser andMobile Opt-Out Methods described above. For more information about our use of statistical
identifiers and cross device methods, please see the Statistical Identifiers and Cross-Device sectionof our Privacy Policy.