Privacy Policy This Sizmek Privacy Policy was last updated on December 23, 2020 Archived versions may be accessed here Privacy Practices for Our Sizmek Websites (e.g., www.sizmek.com) Sizmek by Amazon (“Sizmek”, “we” and “us”) firmly believes in the importance 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 “Sizmek 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 and browser type, when your device accesses our site, and we also use cookies on Sizmek 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.a.r.l. acts as a data controller for the processing of personal data related to the Sizmek Websites and our business and as a data processor for information we collect and process on behalf of advertisers, advertising agencies, publishers, and other users of Sizmek services in the European Economic Area and the United Kingdom. If you have questions about privacy at Sizmek, you may contact us using the contact details provided under the “If You Have Questions About This Policy” heading below. For What Purposes Does Sizmek Use Your Personal Information? Sizmek uses personal information you provide us or is collected by us when you interact with our Sizmek Websites and other Sizmek content to operate, provide, develop, and improve our products and services. These purposes are listed in more detail below: 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 compliance purposes. 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, 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 information that personally identifies you to display interest-based ads. Fraud Prevention and Credit Risks. We use personal information to prevent and detect fraud 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 Sizmek uses personal information collected and processed through Sizmek services on behalf of our advertising customers, please refer to the “Data Collection through Sizmek Services” section below and related sections. Data Collection through Sizmek Services What does Sizmek do? Through our services, our customers – advertisers, advertising agencies, publishers, and other users of Sizmek services – may collect and use information about your device to provide you with a more tailored online advertising experience. Our customers use Sizmek’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 to you. When providing these services to our customers, Sizmek does not act as a data controller, but generally as a data processor for these customers. This means that the customers are responsible for the processing of personal data relating to you, while Sizmek processes such data based on the customer’s instructions. How does Sizmek deliver advertising on behalf of our customers? Sizmek’s cookies and similar technologies (described below) are deployed on your devices, and through the third-party websites and mobile applications you use. The information we collect is associated with your cookie identifiers and/or mobile advertising identifiers (if you are using a 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, the sites 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 (“ad serving 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 is collected 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 is suitable to be delivered to you. This ad serving information, which does not enable Sizmek to determine your actual identity, may be shared with our customers and Sizmek’s and our customers’ partners for our 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 of the 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 well as the internet browsers and other applications on your devices that interact with the internet. Sizmek may engage in cross-device data collection, which refers to the process of collecting data from separate devices that have been determined through statistical analysis to be linked or related, on behalf of customers. Sizmek, or partners that we employ to provide this service, use cross-device data to provide advertising services to our customers and to deliver tailored ads to users across multiple devices. Information Collected by Customers and their Partners Please note that Sizmek customers sometimes include their own (or their partners’) ad-tags, pixels or similar technologies within advertisements that Sizmek serves to websites for those customers. Sizmek 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 Sizmek services, or click through an ad to the website or online service of one of our customers, those customers may collect additional 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 collect information through mechanisms such as cookies, pixels and similar technologies. Sizmek 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 the online services and interactive ads that you use to understand what information companies collect and how they use that information. On occasion, at the request and on behalf of a customer, Sizmek may collect personal information supplied voluntarily by consumers through their interaction with data collection fields in the body of advertisements or on websites (such as name, email, etc.). This personal information is provided directly to the customer on whose behalf the information was collected, or the customer’s service providers, and is processed by Sizmek only to the extent and as long as is necessary to provide the advertising services for which the personal information was collected. Sizmek is not responsible for its customers’ use of this voluntarily supplied data. Sizmek does not distribute this personal information to any party other than those indicated within the advertisement or, at the customers’ direction, their service providers. Sizmek never associates 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 Sizmek We respect your right to privacy throughout all of the services we provide. In particular, Sizmek 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 a registered vendor on the Global Vendor List. For more information about these organizations, their policies 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 the personal information that is submitted to us voluntarily through our web site or collected through interactions with our services. However, no system can be completely secure, and we make no guarantees as to the safety or security of any information transmitted to or from this site or through our services. Sizmek retains cookie information and information we receive from your device in log files for up to 13 months from the time it is stored, after which time the information is deleted. Our Use of Advertising Technologies This section provides additional information about the various technologies that Sizmek uses to manage Sizmek Websites and to deliver ads to you and services to our customers, including services that collect ad serving information when you interact with our customers’ ads or the sites and applications where their ads are provided. Cookies We use cookies to provide functionality to Sizmek Websites and also to deliver our advertising services to our customers. A cookie is a small text file that can be stored on your computer 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 that enables us to determine your actual identity. Instead, Sizmek uses cookies to collect information such as a computer’s IP address, the type of the computer’s operating system, the type of 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 Opt-Out Options and Additional Information section below. Mobile Advertising Identifiers Most mobile devices include an identifier that allows application publishers and marketers to track user activity on mobile devices for advertising purposes (for example, Google’s Android Advertising Identifier (AAID) and Apple’s Identifier for Advertising (IDFA)). Sizmek 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 Sizmek Websites and on our customers’ behalf when you encounter our customers’ 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 and advertisements 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 and advertisements. 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 of statistical identifiers is not associated with any information that would enable us to determine an individual’s actual identity. Our customers use Sizmek’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 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. Information Relating to Children Our products and services are not designed or intended for children (as defined in applicable data protection laws). We do not knowingly collect personal information from children on the Sizmek 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 Sizmek processes may be transferred to, and processed in, any country in which we, our group companies, or our service providers or partners operate, and this may include countries other than the country in which you are resident. These countries may have data 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 accordance with this Privacy Notice. In particular, Sizmek complies with the EU/UK-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework. Click here to learn more. California Consumer Privacy Act (CCPA) Sizmek is a service provider as defined by CCPA. Click here to read additional disclosures required under the California Consumer Privacy Act. IAB Europe Transparency and Consent Framework Sizmek 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 for collecting 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 the processing 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 collect personal information from you or may otherwise need the personal information to protect your vital interests 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 we collect and use your personal information, please contact us using the contact details provided under the “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 of your 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 e-mails 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 your withdrawal, 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 and use 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 data protection 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 data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of the Sizmek Websites), or who otherwise process personal information for purposes that are described in this privacy policy or 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 the buyer 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 Sizmek 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 information on 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 Sizmek Support by email at support@sizmek.com 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 Sizmek is Amazon Europe Core S.á.r.l., who can be contacted using the details provided above. Sizmek’s representative in the European Economic Area or the United Kingdom may be contacted at dpo@sizmek.com. Opt-Out Options and Additional Information Opt-out choices Sizmek provides the following options for controlling your choices or opting out of Sizmek data collection for ad serving and for interest-based advertising. These settings must be performed on each device (including each internet browser on each device) for which you want to opt out. For more information on Sizmek’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, Sizmek 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-OUT OPTION DESCRIPTION HOW TO SELECT THIS OPT-OUT OPTION AND ADDITIONAL INFORMATION Browser Opt-Out Using the Sizmek Opt-Out Cookie Sets the Sizmek opt-out cookie for the browser in which the user’s opt-out choice is made. Click Here to opt-out of the Sizmek Ad-Serving Cookie. If you have previously opted out, and would like to reverse your setting, Click Here to opt back in. To opt-out on mobile devices and mobile apps, see Mobile Opt-Out Methods below. Advertising Industry Sites for Control of Interest-Based Advertising Sizmek participates in advertising industry self-regulatory programs that allow users to opt-out of interest-based advertising (aka online behavioral advertising) by multiple digital advertising service providers, including Sizmek. To do this, the following advertising industry programs maintain sites that enable user controls for interest-based advertising: Digital Advertising Alliance (DAA) European Interactive Digital Advertising Alliance (EDAA) DAA: To opt-out of interest-based advertising by DAA’s participating companies, visit the DAA site here. EDAA: To opt-out of interest-based advertising by EDAA’s participating companies, visit the EDAA site here. For additional information, visit the sites identified above and see Your Advertising Choices and Third Party Services in our privacy policy. Digital Advertising Alliance AppChoices App After installing the DAA AppChoices app on a mobile device, permits the user to control interest-based advertising in applications on that device. For more information and to download AppChoices for your mobile devices, visit the DAA page here or visit your device’s app store and search for “AppChoices” Mobile Advertising Identifiers Use mobile device settings to stop or limit interest-based advertising on that device. For instructions for using the advertising choice mechanisms provided by the most popular mobile operating systems, visit the NAI’s Mobile Choices page here. For additional information, see Mobile Opt-Out Methods below. Cross-Device Opt-Out Guidance Cross-device solutions attempt to tailor your advertising experience across all devices that may belong to you, such as your computer, mobile phone and tablet. For example, using Sizmek’s cross device solutions, advertisers can limit 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 the same person but don’t actually know if they do. To stop cross device identification by Sizmek, use the opt-out options noted above on each device that you use. For additional information, see Cross Device Opt-Out below. Precise Location Data Precise location data refers to the precise location of your device at a specific time and is used to provide ads and other services to you in real time, if you consent to such use. Sizmek does not use precise location data unless you have provided your consent to Sizmek or our partner who has provided your precise location data to us. You can control the use of your precise location data through the settings on your devices, including specific application settings in mobile phones and browser add-ons. To manage location settings for apps on Google Android devices, see Google’s instructions here. To manage location settings for apps on Apple iOS devices, see Apple’s instructions here. To manage location settings for apps on other mobile devices, see the instructions provided by the device manufacturer or the provider of the operating system for that device. For additional information, see Mobile Opt-Out Methods below. Browser Opt-Out Methods To opt-out on internet browsers, use the Sizmek Opt-Out Cookie option or Advertising Industry Sites for opt-out of Interest-Based Advertising methods described in the menu above. This process will store the Sizmek opt-out cookie in your browser, which allows us to recognize that browser in the future and respect your opt-out preferences for that browser. The cookie will apply to the 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 device-based 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 Sizmek 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 and Mobile 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 section of our Privacy Policy. Privacy Practices for Our Sizmek Websites (e.g., www.sizmek.com)For What Purposes Does Sizmek Use Your Personal InformationData Collection through Sizmek ServicesInformation Collected by Customers and their PartnersLinks to Other SitesPrivacy Practices for Advertising and Content Served by SizmekData Security and RetentionOur Use of Advertising TechnologiesInformation Relating to ChildrenInternational Data Transfers and Privacy Shield ComplianceCalifornia Consumer Privacy Act (CCPA)IAB Europe Transparency and Consent FrameworkLegal Basis and Purposes for ProcessingYour Data Protection RightsThird-Party DisclosuresChanges to this DocumentIf You Have Questions About This Policy Privacy Policy Opt-Out Terms of Use