document: title: privacy policy
text: ## Privacy and Data Use Policy for CPX Interactive

CPX Interactive is an advertising network that may deliver advertisements to the Web sites you visit. CPX Interactive understands that your online privacy is important to you. We have created the following Privacy and Data Use Policy (the “Policy”) to let you know what information we collect on this Web site and when we serve advertisements on our network of Web sites owned by third-party publishers (collectively, the “CPX Interactive Site Network”), how such information is used, and how it is shared with third parties if shared at all.

Please read this Policy carefully. Use of the CPX Interactive Site Network, this Web site and your sharing of information with us is subject to the terms and conditions of this Policy. By using the CPX Interactive Site Network, this Web site or sharing information with us, you give your agreement to this Policy. The Policy may be revised or updated at any time by us as further described below.

The terms “you,” “your,” and “yours” refer to the Web site visitor or consumer. The terms “CPX Interactive,” “we,” “us,” and “our” refer to CPX Interactive, and the companies under its control (such as subsidiaries), or under common control (such as parent companies, or companies owned by its parent company) (collectively, “CPX Interactive Entities”).

## Information We Collect

##### Ad Delivery & Reporting Across Multiple Sites

As part of our ad delivery and reporting, we log page views and collect information for the purpose of delivering ads or providing advertising-related services, including providing a specific advertisement based on a particular type of browser or time of day; statistical reporting in connection with the activity on a Web site; and tracking the number of ads served on a particular day to a particular Web site. To do so, we collect information about the type of browser and operating system of Web site visitors, as well as the domain name, day and time of visit, and page(s) visited. We do so across multiple Web domains owned or operated by different entities (each, a “Site”).

#### Relevant Advertising

We want to deliver more relevant advertising to you. Delivering more relevant advertising to you and other Web site visitors allows Web site owners to generate more advertising revenue. This revenue pays for the free content that they may publish for you, or free services that they may deliver to you. It also means that you are more likely to see online advertising that meets your interests.

In an effort to deliver relevant advertising to you, we collect data across multiple Web domains owned or operated by different entities to categorize likely consumer interest segments for use in advertising online (“Online Behavioral Advertising” or “OBA”). For example, we can analyze aggregate, anonymous data to determine that a visitor of a particular Site at 6:30PM is more likely to be interested in Pizza, or antique cars, or a classic movie. We can then serve an ad to the Web page the visitor is viewing that offers a discounted Pizza, car show tickets, or classic movie DVD—importantly—without ever knowing the identity or personal information of the visitor.

If you do not wish to benefit from relevant advertising, please feel free opt out OBA as described in the paragraph titled “OBA Opt-Out”, below.

#### Internet Technology

We collect the information described above by using log files, Web beacons and cookies. We often engage or cooperate with service and technology companies to collect this information. While this tracking and collection technology is commonly used, you might not be familiar with it, and we would like to explain it:

  * “Log files” track actions occurring on Web sites and collect data including your IP address, browser type, Internet service provider, referring/exit pages, platform type, date/time stamp, click data and types of advertisements viewed.
  * “Web beacons” are electronic files used to track your navigation of a Web site or collection of sites, the completion of transactions, submittal of applications and browsing behavior.
  * “Cookies” are files (e.g. HTTP cookies) that are stored on your Internet enabled device (which includes your computer, BlackBerry or other PDA). Cookies are mostly used to record what pages and ads you have already viewed. Cookies are used to facilitate Web site navigation (for example, so your bank knows that you logged in), make sure that you are forwarded to the appropriate Web site when you click on an ad, and generally improve your Web browsing experience. Cookies are also used to control the delivery of a series of advertisements to a Web browser, and to limit the number of times a Web browser receives any one advertisement. We also use cookies to estimate the total reach of an advertising campaign, as well as frequency of display. You can learn more about cookies on the Internet Advertising Bureau’s Web site www.allaboutcookies.org/cookies/what-information-in-cookie.html.



We use the information we collect for marketing and advertising purposes, to determine which ads perform well, to better match ads and Web site content to your interests, to assist us in improving the operation of our services, to maintain the quality of our services, to enhance our services to our business partners and clients, to provide general statistics to our business partners and clients regarding use of CPX Interactive’s services, and for the other purposes described below.

#### Personally Identifiable Information

We do not collect data that includes a name, address, telephone number, email address, government-issued identification, or data that likewise would identify a specific individual (“Personal Identifiable Information” or “PII”), except when you may wish to provide PII as a visitor to this Web site or to a member of the CPX Interactive Site Network, for example by completing a customer service form. While we generally will use such information only for the purpose that it was intended, we reserve the right to use and share such information under these terms.

#### Third Party Data Usage: Information Obtained from Other Companies

We license and otherwise obtain all types of information from various other companies, including research companies, financial information companies, data aggregation companies and other third party companies. Data sets may include information about you or your demographic segment that such companies have licensed, purchased or collected. We use this information for all the purposes described in this Policy, and for any other purpose that we chose.

#### Sharing Your Information

CPX Interactive may use and share your information: (1) to enable third party service providers to assist or facilitate in the services we provide to our clients and customers; (2) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information received by us, whether or not a response is required by applicable law; (3) to enforce our terms of use or to protect our rights; (4) to protect the safety of members of the public and users of our services; (5) with other CPX Interactive Entities and third party marketing partners; (6) with third party research companies, vendors, administrative service providers, technology providers, and selected partners for data validation, aggregation, enhancement, verification and suppression purposes, and for research, marketing, advertising, and data aggregation purposes; (7) for the purposes described elsewhere in this Policy; or (8) for any other purpose for which you provide consent. We also may share information with advertisers, publishers and other third parties for marketing and advertising purposes, but such information does not include PII except if you provided it as described above. While CPX Interactive strongly encourages its advertising customers, service providers, partners, and members of the CPX Interactive Site Network to adopt responsible approaches to online marketing, CPX Interactive is not responsible for the information practices of any of third party entities referenced in this paragraph, which may use the information we share with them for the same purposes as we use the information, or for their own independent purposes. The collection, use, and disclosure of information by clients and partners are subject to their respective privacy policies, which may differ from this Policy.

#### Corporate Changes

In the event that CPX Interactive is acquired by or merged with a third party entity, we reserve the right to transfer or assign the information we have collected from you as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equipolicy_texts principles affecting creditors’ rights generally, we may not be able to control how your information is treated, transferred, or used.

#### Information Collected by Third Party Sites

Please be aware that the Sites of our advertiser clients as well as the Sites on which we place advertisements or any Site linked to from one of our Web sites also may collect information from you. Such information may include non-personally identifiable information through the use of cookies and other technology and any personally identifiable information you may choose to give in registering and transacting with such Web site. Although we choose our business partners and clients carefully, CPX Interactive is not responsible for the privacy practices of Web sites operated by such third parties. You should check the applicable privacy policies of such Web sites you visit to determine how they handle any information they collect from you.

#### Data Retention

Your Internet browser stores OBA-related data as cookies. If you have cookies disabled, if you delete your cookies, or if other software deletes the cookies used for that data storage, such data is lost because it is not retained separately by CPX Interactive. The cookies that store data related to CPX Interactive’s OBA will in any case expire one year after the last time such information is stored, barring any technical malfunction.

CPX Interactive retains information regarding ad delivery (see, “Ad Delivery & Reporting” above) for up to six (6) months. However, CPX Interactive may retain aggregate statistics, reports and summaries regarding ad delivery for a longer period.  
  
CPX Interactive may delete any or all of OBA or information regarding ad delivery that relates to you at any time and in CPX Interactive’s sole discretion, notwithstanding its normal data retention policies. Further, CPX Interactive reserves the right to retain and use any information described in this Policy as reasonably necessary to comply with laws or regulations, notwithstanding any limitations described in this Policy to the contrary. If CPX Interactive changes its retention data policies by updating this Policy, its new policies will apply to all data then retained by CPX Interactive.

## Your Choices

#### OBA Opt-Out and Your Choices

Advertisers may collect data about your online browsing activity and use it to show you targeted ads (a process known as “behavioral advertising”).

You can prevent these companies from showing you targeted ads by submitting opt-outs. Opting-out will only prevent targeted ads so you may continue to see generic (non-targeted ads) from these companies after you opt-out.

To opt out you can can visit the the Digital Advertising Alliance’s opt-out page to opt-out by clicking here.

You may opt in to behaviorally targeted ads anytime by deleting your browser’s cookies.

#### Opting Out of Interest-Based Mobile Ads

If you choose to opt out of interest-based ads on your mobile device, you’ll still see ads but they may not be related to factors such as your interests, previous visits to other websites, or demographic details. To do so, please follow directions for your device below:

iOS – https://support.apple.com/en-us/HT202074  
Android – https://support.google.com/ads/answer/2662922?hl=en

#### European Union Privacy

The European Union (“EU”) maintains strict privacy laws. These rules differ significantly from the laws of the United States of America (“US”). To reconcile these differences, the US and the EU have created a safe harbor (“Safe Harbor”) that defines mutually acceppolicy_texts privacy operations. For more information see www.export.gov/safeharbor. By providing information to us, you acknowledge that we operate in the US and you agree to (i) permit us to transmit and use your user information anywhere necessary, including across international boundaries, to better improve the services and transactions provided by CPX Interactive; and (ii) that such use by us shall be subject to the terms and conditions stated in this Policy and our Terms of Use.

#### Security

CPX Interactive employs standard measures to ensure the security of all information. We routinely evaluate our practices to identify security threats or opportunities for the improvement of our services. No transmission of information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. You acknowledge and agree to assume these risks when communicating with us.

#### Changes

CPX Interactive may find it appropriate or necessary, or may be legally obligated, to update this Policy from time to time. When we do, we will post those changes on this page and update the effective date (found at the bottom) so that you have a way to always become aware of the information we collect, how we use it, and under what circumstances we disclose it. For changes to this Policy that may be materially less restrictive on our use or disclosure of information you have already provided to us, we will attempt to obtain your consent (if we have the necessary contact information) before implementing such revisions with respect to such information, or notify you either by placing a prominent notice on the home page of our Web site or by directly sending you a notification. For all other changes, it is your responsibility to review this Policy frequently and remain informed about any changes to it, so we encourage you to visit this page often.

#### Contact Us

If you have questions about this Policy, the practices of or your dealings with us relating to this Policy, please email us at contact@cpxinteractive.com or you can send correspondence to us at the following address:

CPX INTERACTIVE  
1441 BROADWAY  
18TH FLOOR  
NEW YORK, NY 10018