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Learn more<br>PreferencesDenyAccept Privacy Preference CenterWhen you visit websites, they may store or retrieve data in your browser.
This storage is often necessary for the basic functionality of the website.
The storage may be used for marketing, analytics, and personalization of the site, such as storing your preferences.
Privacy is important to us, so you have the option of disabling certain types of storage that may not be necessary for the basic functioning of the website.
Blocking categories may impact your experience on the website.Reject all cookiesAllow all cookiesManage Consent Preferences by CategoryEssential<strong>Always Active</strong>These items are required to enable basic website functionality.MarketingEssentialThese items are used to deliver advertising that is more relevant to you and your interests.
They may also be used to limit the number of times you see an advertisement and measure the effectiveness of advertising campaigns.
Advertising networks usually place them with the website operator’s permission.PersonalizationEssentialThese items allow the website to remember choices you make (such as your user name, language, or the region you are in) and provide enhanced, more personal features.
For example, a website may provide you with local weather reports or traffic news by storing data about your current location.AnalyticsEssentialThese items help the website operator understand how its website performs, how visitors interact with the site, and whether there may be technical issues.
This storage type usually doesn’t collect information that identifies a visitor.Save preferences and closePoliciesPrivacyAd ChoicesBrand Safety PolicyModern Slavery StatementIntroduction<p>Exponential Interactive, Inc.
doing business as VDX.tv (“we”, “us”, or “our”) is an advertising media services company whose clients and customers are online advertisers (“Advertisers”) and digital content providers (collectively, our “Partners”).
We help our Partners reach their target audiences and grow through ad sales.
Learn more about us at VDX.tv.<br>
</p>
<p>We are active members of advertising industry groups the Digital Advertising Alliance (“DAA”), and the Digital Advertising Alliance of Canada (“DAAC”).
We are signatories to the DAA Self-Regulatory Principles for Online Behavioral Advertising and the DAAC Self-Regulatory Principles for Online Behavioural Advertising.<br>
</p>Purpose<p>This Privacy Policy (“Policy”) describes our practices, both online and offline, regarding the collection, use, disclosure and sale of personal data and personal information, and of the rights of consumers regarding their own personal data and personal information (collectively, “your information”) when you visit our website at VDX.tv (“Site”), in relation to the services we provide our Partners, and any other means in which you interact with us, directly or indirectly.
We are committed to protecting your privacy and processing your information in accordance with all applicable privacy and data protection laws, rules, and regulations, such as the European Union General Data Protection Regulation 2016/679, as amended (“GDPR”) and the California Consumer Privacy Act of 2018, as amended (“CCPA”).<br>
</p>
<p>Please read this Policy carefully.
When you use this Site, you consent to our collection, storage, use, disclosure, and safeguarding of your information as described in this Policy.
If you do not agree with the terms of this Policy, do not use this Site.<br>
</p>Table of contents<p>Please read this Policy carefully.
When you use this Site, you consent to our collection, storage, use, disclosure, and safeguarding of your information as described in this Policy.
If you do not agree with the terms of this Policy, do not use this Site.<br>
</p>
<ol>
<li>Information we collect and how we use it</li>
<li>Opting out</li>
<li>Third parties and categories of information</li>
<li>Data retention</li>
<li>Children’s privacy</li>
<li>Security</li>
<li>Contact information</li>
<li>Changes to this policy</li>
<li>California privacy rights</li>
<li>European privacy rights</li>
<li>International data transfers</li>
</ol>Information we collect and how we use it<p>We may collect, transmit, and store your information provided to us from the following categories of sources (i.e., types or groupings of persons or entities from which a business collects personal information about consumers) and categories of third parties (i.e., types or groupings of third parties with whom the business shares personal information) – directly from you, our online technology, and our Partners.</p>Directly from You<p>We collect your information directly from you and for the following purposes when you:</p>
<ul>
<li>submit a job application, resume, cover letter, or social media profile to a job vacancy, or interview with us;</li>
<li>enter into an employment or consulting services contract with us;</li>
<li>complete forms, post content on our Site, respond to surveys, or use any features on our Site;</li>
<li>provide feedback to us by phone, email, physical mail, or any other means of providing feedback;</li>
<li>interact with us on our social media accounts, including without limitation LinkedIn, Twitter, and Facebook;</li>
<li>subscribe to any of our marketing materials.
and</li>
<li>participate in contests sponsored by us.</li>
</ul>Online Technology<p>We may automatically collect certain information when you use our online technology.
Such information includes:<br>
</p>
<ul>
<li>Internet Protocol (“IP”) Address: An address provided by your internet service provider (“ISP”) to connect you to the internet and enable delivery of your online requests.</li>
<li>Cookie Identifier: A cookie (data file) with a unique identifier that we set from our domain “tribalfusion.com”.</li>
<li>User Agent: Information related to the web browser that acts on your behalf and enables your interaction with web content.</li>
<li>Clickstream Data: Information about your interaction with a webpage (e.g., time and date you visited the page.
webpage address.
title of ad shown.
topics (such as “beach” or “Caribbean”) that we interpret (as “summer vacation”) from the page.</li>
<li>Viewed Content Data: Information related to video content viewed on an internet-connected TV (“Connected TV”).</li>
</ul>
<p>Other information that may be collected include browser session location, ISP, pages that you visit before, during, and after using our Site, links you click, how you use our online technology, and information from any associated devices used to interact with our online technology.<br>
</p>
<strong>Our Partners</strong>
<p>Our Partners receive your information when you visit or use their services or through third parties they work with.
We require our Partners to have lawful rights to collect, use, and share your information before we receive any of your information.
A list of Partners with whom we may share data is available on our Partnerships &.
Accreditations page located at https://vdx.tv/partnerships.
Our Partners perform different services such as advertising brand safety and quality, advertising brand reporting, privacy, data management platforms, and advertising inventory.<br>
</p>
<p>We may use one or more of our partners to onboard offline data which may originally have included Personally Identifiable Information, however we do not use or have access to any PII as part of this process.<br>
</p>
<p>We may also use analytics vendors such as Google Analytics to allow tracking technologies and remarketing services through the use of first- and third-party cookies to analyze and track users’ use of this Site, determine the popularity of certain content, and better understand online activity.
We do not transfer your information to these analytics vendors.<br>
</p>
<p>However, by accessing this Site, you consent to the collection and use of your information by these analytics vendors.
We encourage you to review these vendors’ privacy policies.
If you do not want your information to be collected and used by these analytics vendors, contact the responsible analytics vendor directly or use the DAA Opt-Out Tool, or DAAC Opt-Out Tool.<br>
</p>Opting Out<p>We and our Partners may use web beacons, tags, advertising identifiers, and similar technology (collectively, “cookies”) related to your use of this Site and in providing our services.</p>
<p>Cookies may transmit information about you and your use of this Site, such as your browser type, IP address, data relating to ads displayed to you or ads that you have interacted with, and the date and time of your use.
Cookies may be persistent (e.g., stored on your device until it expires or until you delete them) or stored only during an individual web browsing session.
Our tracking cookies automatically expire (i.e., are automatically deleted from your web browser) ninety (90) days from the last time we encounter you.
</p>
<p>Generally, cookies help make ads more relevant to you and remove ads you already viewed.
Cookies also make ads more valuable to our Partners by improving reporting on campaign performance (e.g., whether an advertiser reached its audience or not.
how many ads were shown.
how many clicks an ad received.
etc.).</p>
<p>We use cookies for the following purposes:<br>
</p>
<ul>
<li>Create audience segments, build targeting profiles, and delivering ads based on automated decision-making related to those profiles;</li>
<li>Help our Partners to measure the effectiveness and distribution of their ads and digital content, and to understand the consumers who use Partner services;</li>
<li>Detect and prevent fraud;</li>
<li>Troubleshoot problems to increase the efficiency and operation of this Site.
and</li>
<li>As required by applicable law, rule, or regulation if we believe your information is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect our rights or the rights of others.</li>
</ul>Opting Out of Our Cookies<p>If you do not want our cookies on your device, you can choose to Opt-Out.
For Opt-Out or Opt-In kindly use the below mentioned link:<br></p>Click here to Opt-Out <p>
<br>When you Opt-Out, your device will overwrite our cookie with a non-identifying Opt-Out cookie (“Opt-Out Cookie”).
The Opt-Out Cookie indicates that your data should not be used for behaviorally-targeted advertising.
The details of the Opt-Out Cookie are shown below.<br></p>Cookie NameCookie ValueSort by (Domain)PartyTypeExpiryANON_IDOptOuttribalfusion.comThirdPersistent3 months<p>If you reject our cookie, you may still use our Site, but your ability to use some features or areas of our Site may be limited.
If you have any questions about opting out of our cookies, please contact us as outlined in Section 7 (Contact Information) below.</p>
<p>If you do not want targeted advertising cookies from us or similar companies, please use one of the Opt-Out mechanisms provided by DAA or DAAC.
If you do not want any cookies on your device, you can change your browser or device settings to reject cookies or visit About Cookies.<br></p>Opting Out on Connected TV devices<p>To manage privacy preferences around digital advertising on TV streaming devices, please refer to https://www.networkadvertising.org/internet-connected-tv-choices/ or the device manufacturer’s instructions.<br>
</p>Third Parties And Categories Of Information<p>The categories of third parties that may receive your information include Partners.<br>
</p>
<ul>
<li>We may share your information with our Partners for the purpose of conducting general business analysis.
We may also share your information with our Partners for marketing purposes, as permitted by law.
We adhere to the DAA Self-Regulatory Principles for Online Behavioral Advertising and the DAAC Self-Regulatory Principles for Online Behavioural Advertising.
Partners may be able to associate the information we share with other information they have about you from other sources.
We do not have full access to or control over the cookies our Partners use, but you may be able to opt out of some of their practices by contacting the responsible Partner or via the DAA Opt-Out Tool or DAAC Opt-Out Tool.<br>Please note that even after you withdraw your consent, we may, to the extent required or permitted by law, continue to process your personal information.<br>
</li>
</ul>
<p>The categories of information related to third parties include:<br>
</p>
<ul>
<li>Aggregated and Deidentified Information: We receive and share aggregated and deidentified information with third parties in connection with advertising programs and data analytics.
For example, we may provide our Partners with the number of users who have been exposed to or interacted with certain ads.<br>
</li>
<li>Business Transfers: We may share information from or about you with companies under common control with us and require those companies to also honor this Policy.
If another company acquires us, or all or substantially all of our assets, such company will possess the same information.<br>
</li>
<li>Investigations and Legal Disclosures: We may investigate and disclose your information if we have a good faith belief that such investigation or disclosure: (i) is reasonably necessary to comply with legal, regulatory or law enforcement processes, such as a search warrant, subpoena, statute, judicial proceeding, or other legal or regulatory process or law enforcement request.
(ii) is helpful to identify, investigate, or prevent possible wrongdoing related to our Site or Partners.
or (iii) is necessary to protect our rights or the rights of others.<br>
</li>
<li>Links: The Site may link to the websites of third party (non-Partners) that we are not affiliated with.
We do not share your information with third party (non-Partners) and are not responsible for their privacy practices.<br>
</li>
</ul>Data Retention<p>Our tracking cookie automatically expires (i.e., is automatically deleted from your web browser) ninety (90) days from the last time we encounter you.<br>
</p>
<p>We retain log file data including cookie ID and IP address for one hundred (100) days for troubleshooting purposes or Subject Access Requests.
It is archived beyond that point if required as part of our legal and regulatory obligations, to a total duration of three (3) years.<br>
</p>Children's Privacy<p>Our Site and services are not intended for children.
We do not knowingly collect, maintain, or sell the personal information of children under the age of sixteen (16).
If you are under the age of sixteen (16), please do not access our Site or use our services.
If we learn that we have inadvertently collected personal information of children under the age of sixteen (16), we will delete such information unless otherwise required by applicable law, regulation, or rule.<br>
</p>Security<p>We use commercially reasonable administrative, technical, and physical security measures to safeguard your information.
Despite our efforts, please note that any information disclosed online is inherently vulnerable to interception and misuse by unauthorized parties.
As such, we cannot absolutely guarantee total security of your information.<br>
</p>Contact Information<p>Please contact us with any questions about this Policy using the information below:<br>
</p>
<p>
<strong>United States Address<br>
</strong>Exponential Interactive, Inc.
d/b/a VDX.tv<br>Attn: Legal Department<br>2340 Powell Street, #378<br>Emeryville, CA 94608<br>
</p>
<p>U.S.
Phone<br>U.S.
toll-free number +1 (800) 480-0816<br>Emeryville local office number +1 (510) 250-5500<br>
</p>
<p>
<strong>United Kingdom Address<br>
</strong>Exponential Interactive, Inc.
d/b/a VDX.tvAttn: Data Protection Officer30 Stamford Street London, SE19LQ<br>
</p>
<p>
<strong>Email<br>
</strong>privacy@vdx.tv<br>
</p>
<p>To protect the security of your information, we will take steps as we deem necessary to confirm your identity or the identity of your Authorized Agent or valid power of attorney before completing a request or sharing any personal information with you or your Authorized Agent or valid power of attorney.<br>
</p>Changes To This Policy<p>We reserve the right to update this Policy at any time and for any reason.
Any changes or modifications will be effective as of the “Effective Date” at the top of this Policy.
We will notify you about any changes to this Policy by updating the “Last updated” date at the top of this Policy.
In some cases, we may also notify you of Policy updates by adding a statement to our Site homepage, via email, or by any other means of communication allowed by law.<br>
</p>
<p>We encourage you to review this Policy from time to time to stay informed about our privacy practices and your options.
By continuing to access or use this Site after those updates become effective, you agree to be bound to the terms of the then-current Policy.<br>
</p>California Privacy Rights<p>Under the CCPA, California residents and households have certain rights around the collection, use, and sharing of their personal information.<br>
</p>
<p>
<strong>Disclosure or Sale of Personal Information</strong>
<br>
</p>
<p>We have not disclosed or sold any personal information to third parties for any business or commercial purpose in the preceding twelve (12) months.
We do not and will not disclose or sell your personal information without giving you notice and an opportunity to opt out of such disclosure or sale as required by law.<br>
</p>
<p>
<strong>We do not offer financial incentives associated with our collection, use, or disclosure of your personal information.</strong>
<br>
</p>
<p>We collect various categories of personal information when you use this Site or our Partner sites, including identifiers, commercial information, internet or other electronic network or device activity, geolocation data, and professional information.
A detailed description of the information we collect and how we use it is provided in Section 1 (Information We Collect and How We Use It) above.
Section 3 (Third Parties and Categories of Information) above describes the categories of third parties with whom we share personal information, and what information may be shared and under what circumstances.<br>
</p>
<p>
<strong>Information We Collect</strong>
<br>
</p>
<p>We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”).
In particular, we have collected the following categories of personal information from consumers from the following within the last twelve (12) months:<br>
</p>CategoryExamplesCollectedA.
IdentifiersA real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.YesB.
Personal information categories listed in the California Customer Records statute (Cal.
Civ.
Code § 1798.80(e))A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information in this category may overlap with other categories.YesC.
Protected classification characteristics under California or federal lawAge (forty (40) years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).YesD.
Commercial informationRecords of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.YesE.
Biometric informationGenetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.NoF.
Internet or other similar network activityBrowsing history, information on a consumer’s interaction with a website, application, or advertisement.YesG.
Geolocation dataPhysical location or movements.YesH.
Sensory dataAudio, electronic, visual, thermal, olfactory, or similar information.NoI.
Professional or employment-related informationCurrent or past job history or performance evaluations, and administering employment benefits including retirement, health, and other benefit programs, services, or products to which consumers and their dependents or their beneficiaries receive access through the consumer’s employer.YesJ.
Non-public education information (Family Educational Rights and Privacy Act (20 U.S.C.
§ 1232g, 34 C.F.R.
Part 99))Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.NoK.
Inferences drawn from other personal informationProfile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.Yes<p>Under the CCPA, personal information does not include:<br>
</p>
<ul>
<li>Publicly available information from government records;<br>
</li>
<li>Deidentified or aggregated consumer information;<br>
</li>
<li>Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996, and the California Confidentiality of Medical Information Act, or clinical trial data.
or<br>
</li>
<li>Sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994.<br>
</li>
</ul>
<p>We receive the categories of personal information listed in the chart above from the following sources:<br>
</p>
<ul>
<li>Directly from you;<br>
</li>
<li>Partners or their agents (e.g., information that our Partners give to us related to the services for which they engage us).
and<br>
</li>
<li>Directly and indirectly from activity on our Site (e.g., usage details collected automatically).<br>
</li>
</ul>
<p>
<strong>Use of Personal Information</strong>
<br>
</p>
<p>We may use or disclose the personal information we collect for some or more of the following business purposes:<br>
</p>
<ul>
<li>To fulfill or meet the reason for which such personal information is provided;<br>
</li>
<li>To provide you with information, products, or services that you request from us;<br>
</li>
<li>To improve our Site and its contents to you;<br>
</li>
<li>For testing, research, analysis, and product development;<br>
</li>
<li>As necessary or appropriate to protect our rights or the rights of others;<br>
</li>
<li>To respond to law enforcement requests and as required by applicable law, regulation, rule, or court order;<br>
</li>
<li>As otherwise set forth in the CCPA.
or<br>
</li>
<li>To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.<br>
</li>
</ul>
<p>We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without notifying you as required by law.<br>
</p>
<p>
<strong>Sharing Personal Information</strong>
<br>
</p>
<p>We may disclose your personal information to a third party (i.e., our Partners) for a business purpose.
When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep that personal information confidential and not use it for any purpose except performing the contract.<br>
</p>
<p>In the preceding twelve (12) months, we have disclosed the following categories of personal information (listed above) for a business purpose with two (2) categories of third parties: (1) service providers (“Service Providers”).
and (2) third parties to whom you or your agents authorized us to disclose your information in connection with our products or services (“Authorized Third Parties”) – detailed in the chart below:<br>
</p>CategoryExamplesCategories of Third Parties We Shared Personal Information WithA.
IdentifiersA real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.Service Providers.
and Authorized Third PartiesB.
Personal information categories listed in the California Customer Records statute (Cal.
Civ.
Code § 1798.80(e))A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information in this category may overlap with other categories.Service Providers.
and Authorized Third PartiesC.
Protected classification characteristics under California or federal lawAge (forty (40) years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).Service Providers.
and Authorized Third PartiesD.
Commercial informationRecords of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.Service Providers.
and Authorized Third PartiesF.
Internet or other similar network activityBrowsing history, information on a consumer’s interaction with a website, application, or advertisement.Service Providers.
and Authorized Third PartiesG.
Geolocation dataPhysical location or movements.Service Providers.
and Authorized Third PartiesI.
Professional or employment-related informationAudio, electronic, visual, thermal, olfactory, or similar information.Service Providers.
and Authorized Third PartiesK.
Inferences drawn from other personal informationCurrent or past job history or performance evaluations, and administering employment benefits including retirement, health, and other benefit programs, services, or products to which consumers and their dependents or their beneficiaries receive access through the consumer’s employer.Service Providers.
and Authorized Third Parties<p>
<strong>Your Data Privacy Rights Under CCPA</strong>
<br>
</p>
<p>Generally, California resident or household consumers have the following data privacy rights under the CCPA:<br>
</p>
<ul>
<li>
<strong>Right to Know</strong>: You may request that a business tell you what specific personal information it collected, shared, or sold about you, and why it was collected, shared, or sold;<br>
</li>
<li>
<strong>Right to Delete</strong>: You may request that a business delete personal information that it collected from you, subject to some exceptions;<br>
</li>
<li>
<strong>Right to Opt-Out</strong>: You may request that a business stop selling your personal information;<br>
</li>
<li>
<strong>Rights for Minors</strong>: A business cannot sell the personal information of minors under the age of sixteen (16) without their permission and, for children under thirteen (13), without parental consent.
and<br>
</li>
<li>
<strong>Right to Non-Discrimination</strong>: A business may not discriminate against consumers who exercise their rights under the CCPA.<br>
</li>
</ul>
<p>
<strong>Right to Know (i.e., Information About and Access to Your Personal Information)</strong>
<br>
</p>
<p>You have the right to request that we disclose personal information we collected about you pursuant to Civil Code sections 1798.100, 1798.110, or 1798.115 including any or all of the following:<br>
</p>
<ul>
<li>Specific pieces of personal information that we collected about you;<br>
</li>
<li>Categories of personal information we collected about you;<br>
</li>
<li>Categories of sources from which your personal information is collected;<br>
</li>
<li>Categories of personal information that we sold or disclosed for a business purpose about you;<br>
</li>
<li>Categories of third parties to whom your personal information was sold or disclosed for a business purpose.
and<br>
</li>
<li>The business or commercial purpose for collecting or selling your personal information.<br>
</li>
</ul>
<p>In responding to your verified consumer request to know, we will provide information on:<br>
</p>
<ul>
<li>The categories of personal information we collected about you (e.g., IP address, geolocation data, internet activity such as web browsing histories, and professional or employment-related information) in the preceding twelve (12) months from the date we receive your request;<br>
</li>
<li>The categories of sources from which your personal information was collected (e.g., cookies);<br>
</li>
<li>The business or commercial purpose for which we collected or sold your personal information (e.g., fraud prevention, marketing, etc.);<br>
</li>
<li>The categories of third parties with which we share your personal information;<br>
</li>
<li>The categories of personal information that we sold in the preceding twelve (12) months, and for each category identified, the categories of third parties to which we sold that particular category of personal information.
and<br>
</li>
<li>The categories of personal information that we disclosed for a business purpose in the preceding twelve (12) months, and for each category identified, the categories of third parties to whom we disclosed that particular category of personal information.<br>
</li>
</ul>
<p>The CCPA also requires that if requested, we provide you with responsive materials in a readily usable format that allows you to transmit your information from one (1) entity to another without hindrance.<br>
</p>
<p>
<strong>Right to Delete</strong>
<br>
</p>
<p>The CCPA generally permits you to request that we and our direct service providers (i.e., Partners) delete personal information collected from you in accordance with Civil Code section 1798.105.
However, we are not required to delete your personal information for any of the following reasons:<br>
</p>
<ul>
<li>if we need your information to complete the transaction for which it was collected;<br>
</li>
<li>to comply with a legal obligation;<br>
</li>
<li>to comply with the California Electronic Communications Privacy Act (Cal.
Penal Code § 1546 <em>et seq</em>.), as amended;<br>
</li>
<li>to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;<br>
</li>
<li>to identify and repair errors that impair existing and intended functionality.
or<br>
</li>
<li>to make other internal and lawful uses of your information that are compatible with the context in which you provided it.<br>
</li>
</ul>
<p>
<strong>
<em>Verifiable Consumer Requests</em>
</strong>
<br>
</p>
<p>The CCPA considers the right to know and the right to delete as verifiable consumer requests.
Verifiable consumer requests must: (i) provide sufficient information that allows us to reasonably verify that you are in fact the California resident or Household about whom we collected personal information or an authorized representative.
and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.<br>
</p>
<p>We may deny a request to know or a request to delete if we cannot verify your identity or authority to make the request or confirm that the requested personal information relates to you.<br>
</p>
<p>We will only use personal information that you provide us to verify your identity or authority.<br>
</p>
<p>
<strong>
<em>How to Submit a Request to Know or a Request to Delete</em>
</strong>
<br>
</p>
<p>Submit your request using the information in Section 7 (Contact Information) above and include the value of your tribalfusion.com ANON_ID cookie (“TF ANON_ID Cookie Value” or “Cookie Value”) as explained below.<br>
</p>
<p>
<strong>
<em>Verifying Your Identity with Your TF ANON_ID Cookie Value</em>
</strong>
<br>
</p>
<p>Your Cookie Value is the only repository where consumer identifying information may be stored.
To find your TF ANON_ID Cookie Value (highlighted blue in example below):<br>
</p>
<ul>
<li>Open your web browser and go to “tribalfusion.com”;<br>
</li>
<li>Locate the ANON_ID cookie (see image below) in your browser’s privacy or cookie settings (location will vary by browser).
and<br>
</li>
<li>Copy the TF ANON_ID Cookie Value and email it to privacy@VDX.tv.<br>
</li>
</ul>
<p>Your Cookie Value is the only repository where consumer identifying information may be stored.
To find your TF ANON_ID Cookie Value (highlighted blue in example below):<br>
</p>
<p>
<strong>
<em>Our Confirmation of or Response to Your Request to Know or Request to Delete</em>
</strong>
<br>
</p>
<p>The CCPA generally permits you to request that we and our direct service providers (i.e., Partners) delete personal information collected from you in accordance with Civil Code section 1798.105.
However, we are not required to delete your personal information for any of the following reasons:<br>
</p>
<ul>
<li>permanently and completely erasing your personal information on our existing systems (except archived or back-up systems);<br>
</li>
<li>deidentifying your personal information.
or<br>
</li>
<li>aggregating your personal information.<br>
</li>
</ul>
<p>If we deny your request, we will (unless otherwise prohibited by law):<br>
</p>
<ul>
<li>describe the basis for the denial, including any conflict with federal or state law, or CCPA exception;<br>
</li>
<li>delete any personal information that is not subject to the exception (if any).
and<br>
</li>
<li>will not use your personal information retained for any other purpose than provided for by the CCPA exception.<br>
</li>
</ul>
<p>If we are unable to verify your identity, we may deny your request.
However, we will inform you that your identity cannot be verified.<br>
</p>
<p>
<strong>Right to Opt-Out of the Sale of Your Information</strong>
<br>
</p>
<p>Under the CCPA, you may Opt-Out of the sale of your personal information from a business to third parties.
<strong>While we do not sell your personal information suppression of any sharing of your personal information can be applied by following the same steps laid out in the Right to Delete above.</strong>
<br>
</p>
<p>
<strong>Rights for Minors</strong>
<br>
</p>
<p>Our Site and services are not intended for children.
We do not knowingly collect, maintain, or sell the personal information of children under the age of sixteen (16).<br>
</p>
<p>
<strong>Right to Non-Discrimination</strong>
<br>
</p>
<p>We will not discriminate against you for exercising any of your CCPA rights.
We will not:<br>
</p>
<ul>
<li>Deny you services;<br>
</li>
<li>Charge you different prices or rates for services by granting discounts or other benefits, or imposing penalties;<br>
</li>
<li>Provide you a different level or quality of services.
or<br>
</li>
<li>Suggest that you may receive a different price or rate for services or a different level or quality of services.<br>
</li>
</ul>
<p>
<strong>Who May Exercise Your CCPA Rights</strong>
<br>
</p>
<p>Only you, a valid power of attorney under the California Probate Code, as amended, or a natural person or business entity registered with the Secretary of State to conduct business in California that you authorize to act on your behalf (“Authorized Agent”), may make a verifiable consumer request to know or delete related to your information.<br>
</p>
<p>If you wish to submit a request to know or a request to delete via an Authorized Agent, your Authorized Agent must provide us with written and signed permission from you to submit the request(s).
“Signed” means that the written attestation, declaration, or permission has either been physically signed or provided electronically per the Uniform Electronic Transactions Act, Civil Code section 1633.7 <em>et seq.
</em>
<br>
</p>
<p>Next, contact us (as outlined in Section 7 (Contact Information) above) so we may verify your identity and confirm that you provided the requesting Authorized Agent permission to submit the request(s).<br>
</p>
<p>
<strong>Fees</strong>
<br>
</p>
<p>We will not charge a fee to process or respond to your verifiable consumer request unless it is excessive.
If we reasonably determine that the request requires a fee, we will tell you why we made that decision and give you a cost estimate in writing before completing your request.<br>
</p>
<p>
<strong>Shine The Light Law</strong>
<br>
</p>
<p>Separate from the CCPA, California Civil Code Section 1798.83, as amended, also known as the “Shine The Light” law gives California residents the right to request and obtain what personal information we share with third parties for those third parties’ direct marketing purposes.
We do not disclose your personal information to third parties for such third parties to directly market their services to you.
If you have any questions about our Shine The Light Law practices, please contact us as outlined in Section 7 (Contact Information) above.<br>
</p>
<p>
<strong>Do Not Track</strong>
<br>
</p>
<p>California law requires us to tell you how we respond to web browser Do Not Track (“DNT”) signals.
DNT allows users a way to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services.
We do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.<br>
</p>
<p>
<strong>Disclosure of Consumer Requests</strong>
<br>
</p>
<p>As required by the California Consumer Privacy Act (“CCPA”), VDX.tv handled the following types of consumer requests during the year 2020:<br>
</p>Type of RequestReceivedFulfilledDeniedAverage Response TimeSubject Access252508 daysData Removal484805 daysOpt-Out/Delete6362010 days<p>Note, these are global numbers, not only from California residents.<br>
</p>
<p>In terms of the data we use, “Opt-Out” is the same as “delete”.
“Data Removal” in the table above means that if we receive a request regarding data on one of our partner publisher websites, over which we have no editorial control, we will forward the request to the partner publisher for further action.<br>
</p>European Privacy Rights<p>This Section 10 applies to European Residents only.
A “European Resident” is a resident of a country in the European Economic Area (“EEA”).<br>
</p>
<p>The GDPR describes situations in which companies are permitted to collect or reuse your personal information.<br>
</p>
<p>Our legal basis for collecting and using your information depends on the specific information at issue and the corresponding circumstances of collecting such information.
We collect your personal information only with your consent or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.
We may also have legal obligations to collect your information or may otherwise need your information to protect your vital interests or those of another person.<br>
</p>
<p>If we ask you to provide personal information to comply with a legal requirement, we will specify the legal requirement and the information we require.
If we collect and use your information in reliance on our legitimate interests (or those of any third party), our legitimate interests will generally involve operating and improving this Site, communicating with you, marketing purposes, or detecting or preventing fraud.
For more information about GDPR, please visit the EU’s “Data protection and online privacy” page.
If you have questions about our compliance with GDPR, please contact us as outlined in Section 7 (Contact Information) above.<br>
</p>International Data Transfers<p>If you reside in the European Union, your personal information may be processed outside of EEA.
We take all necessary steps to ensure that your information is adequately protected and processed in accordance with this Policy, using the European Commission’s Standard Contractual Clauses – European Commission-approved contracts that offer personal information the same protection as under European law.<br>
</p>California Privacy Rights<p>Under the CCPA, California residents and households have certain rights around the collection, use, and sharing of their personal information.<br>
</p>
<p>
<strong>Disclosure or Sale of Personal Information</strong>
<br>
</p>
<p>We have not disclosed or sold any personal information to third parties for any business or commercial purpose in the preceding twelve (12) months.
We do not and will not disclose or sell your personal information without giving you notice and an opportunity to opt out of such disclosure or sale as required by law.<br>
</p>
<p>
<strong>We do not offer financial incentives associated with our collection, use, or disclosure of your personal information.</strong>
<br>
</p>
<p>We collect various categories of personal information when you use this Site or our Partner sites, including identifiers, commercial information, internet or other electronic network or device activity, geolocation data, and professional information.
A detailed description of the information we collect and how we use it is provided in Section 1 (Information We Collect and How We Use It) above.
Section 3 (Third Parties and Categories of Information) above describes the categories of third parties with whom we share personal information, and what information may be shared and under what circumstances.<br>
</p>
<p>
<strong>Information We Collect</strong>
<br>
</p>
<p>We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”).
In particular, we have collected the following categories of personal information from consumers from the following within the last twelve (12) months:<br>
</p>CategoryExamplesCollectedA.
IdentifiersA real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.YesB.
Personal information categories listed in the California Customer Records statute (Cal.
Civ.
Code § 1798.80(e))A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information in this category may overlap with other categories.YesC.
Protected classification characteristics under California or federal lawAge (forty (40) years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).YesD.
Commercial informationRecords of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.YesE.
Biometric informationGenetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.NoF.
Internet or other similar network activityBrowsing history, information on a consumer’s interaction with a website, application, or advertisement.YesG.
Geolocation dataPhysical location or movements.YesH.
Sensory dataAudio, electronic, visual, thermal, olfactory, or similar information.NoI.
Professional or employment-related informationCurrent or past job history or performance evaluations, and administering employment benefits including retirement, health, and other benefit programs, services, or products to which consumers and their dependents or their beneficiaries receive access through the consumer’s employer.YesJ.
Non-public education information (Family Educational Rights and Privacy Act (20 U.S.C.
§ 1232g, 34 C.F.R.
Part 99))Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.NoK.
Inferences drawn from other personal informationProfile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.Yes<p>Under the CCPA, personal information does not include:<br>
</p>
<ul>
<li>Publicly available information from government records;<br>
</li>
<li>Deidentified or aggregated consumer information;<br>
</li>
<li>Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996, and the California Confidentiality of Medical Information Act, or clinical trial data.
or<br>
</li>
<li>Sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994.<br>
</li>
</ul>
<p>We receive the categories of personal information listed in the chart above from the following sources:<br>
</p>
<ul>
<li>Directly from you;<br>
</li>
<li>Partners or their agents (e.g., information that our Partners give to us related to the services for which they engage us).
and<br>
</li>
<li>Directly and indirectly from activity on our Site (e.g., usage details collected automatically).<br>
</li>
</ul>
<p>
<strong>Use of Personal Information</strong>
<br>
</p>
<p>We may use or disclose the personal information we collect for some or more of the following business purposes:<br>
</p>
<ul>
<li>To fulfill or meet the reason for which such personal information is provided;<br>
</li>
<li>To provide you with information, products, or services that you request from us;<br>
</li>
<li>To improve our Site and its contents to you;<br>
</li>
<li>For testing, research, analysis, and product development;<br>
</li>
<li>As necessary or appropriate to protect our rights or the rights of others;<br>
</li>
<li>To respond to law enforcement requests and as required by applicable law, regulation, rule, or court order;<br>
</li>
<li>As otherwise set forth in the CCPA.
or<br>
</li>
<li>To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.<br>
</li>
</ul>
<p>We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without notifying you as required by law.<br>
</p>
<p>
<strong>Sharing Personal Information</strong>
<br>
</p>
<p>We may disclose your personal information to a third party (i.e., our Partners) for a business purpose.
When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep that personal information confidential and not use it for any purpose except performing the contract.<br>
</p>
<p>In the preceding twelve (12) months, we have disclosed the following categories of personal information (listed above) for a business purpose with two (2) categories of third parties: (1) service providers (“Service Providers”).
and (2) third parties to whom you or your agents authorized us to disclose your information in connection with our products or services (“Authorized Third Parties”) – detailed in the chart below:<br>
</p>CategoryExamplesCategories of Third Parties We Shared Personal Information WithA.
IdentifiersA real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.Service Providers.
and Authorized Third PartiesB.
Personal information categories listed in the California Customer Records statute (Cal.
Civ.
Code § 1798.80(e))A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information in this category may overlap with other categories.Service Providers.
and Authorized Third PartiesC.
Protected classification characteristics under California or federal lawAge (forty (40) years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).Service Providers.
and Authorized Third PartiesD.
Commercial informationRecords of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.Service Providers.
and Authorized Third PartiesF.
Internet or other similar network activityBrowsing history, information on a consumer’s interaction with a website, application, or advertisement.Service Providers.
and Authorized Third PartiesG.
Geolocation dataPhysical location or movements.Service Providers.
and Authorized Third PartiesI.
Professional or employment-related informationAudio, electronic, visual, thermal, olfactory, or similar information.Service Providers.
and Authorized Third PartiesK.
Inferences drawn from other personal informationCurrent or past job history or performance evaluations, and administering employment benefits including retirement, health, and other benefit programs, services, or products to which consumers and their dependents or their beneficiaries receive access through the consumer’s employer.Service Providers.
and Authorized Third Parties<p>
<strong>Your Data Privacy Rights Under CCPA</strong>
<br>
</p>
<p>Generally, California resident or household consumers have the following data privacy rights under the CCPA:<br>
</p>
<ul>
<li>
<strong>Right to Know</strong>: You may request that a business tell you what specific personal information it collected, shared, or sold about you, and why it was collected, shared, or sold;<br>
</li>
<li>
<strong>Right to Delete</strong>: You may request that a business delete personal information that it collected from you, subject to some exceptions;<br>
</li>
<li>
<strong>Right to Opt-Out</strong>: You may request that a business stop selling your personal information;<br>
</li>
<li>
<strong>Rights for Minors</strong>: A business cannot sell the personal information of minors under the age of sixteen (16) without their permission and, for children under thirteen (13), without parental consent.
and<br>
</li>
<li>
<strong>Right to Non-Discrimination</strong>: A business may not discriminate against consumers who exercise their rights under the CCPA.<br>
</li>
</ul>
<p>
<strong>Right to Know (i.e., Information About and Access to Your Personal Information)</strong>
<br>
</p>
<p>You have the right to request that we disclose personal information we collected about you pursuant to Civil Code sections 1798.100, 1798.110, or 1798.115 including any or all of the following:<br>
</p>
<ul>
<li>Specific pieces of personal information that we collected about you;<br>
</li>
<li>Categories of personal information we collected about you;<br>
</li>
<li>Categories of sources from which your personal information is collected;<br>
</li>
<li>Categories of personal information that we sold or disclosed for a business purpose about you;<br>
</li>
<li>Categories of third parties to whom your personal information was sold or disclosed for a business purpose.
and<br>
</li>
<li>The business or commercial purpose for collecting or selling your personal information.<br>
</li>
</ul>
<p>In responding to your verified consumer request to know, we will provide information on:<br>
</p>
<ul>
<li>The categories of personal information we collected about you (e.g., IP address, geolocation data, internet activity such as web browsing histories, and professional or employment-related information) in the preceding twelve (12) months from the date we receive your request;<br>
</li>
<li>The categories of sources from which your personal information was collected (e.g., cookies);<br>
</li>
<li>The business or commercial purpose for which we collected or sold your personal information (e.g., fraud prevention, marketing, etc.);<br>
</li>
<li>The categories of third parties with which we share your personal information;<br>
</li>
<li>The categories of personal information that we sold in the preceding twelve (12) months, and for each category identified, the categories of third parties to which we sold that particular category of personal information.
and<br>
</li>
<li>The categories of personal information that we disclosed for a business purpose in the preceding twelve (12) months, and for each category identified, the categories of third parties to whom we disclosed that particular category of personal information.<br>
</li>
</ul>
<p>The CCPA also requires that if requested, we provide you with responsive materials in a readily usable format that allows you to transmit your information from one (1) entity to another without hindrance.<br>
</p>
<p>
<strong>Right to Delete</strong>
<br>
</p>
<p>The CCPA generally permits you to request that we and our direct service providers (i.e., Partners) delete personal information collected from you in accordance with Civil Code section 1798.105.
However, we are not required to delete your personal information for any of the following reasons:<br>
</p>
<ul>
<li>if we need your information to complete the transaction for which it was collected;<br>
</li>
<li>to comply with a legal obligation;<br>
</li>
<li>to comply with the California Electronic Communications Privacy Act (Cal.
Penal Code § 1546 <em>et seq</em>.), as amended;<br>
</li>
<li>to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;<br>
</li>
<li>to identify and repair errors that impair existing and intended functionality.
or<br>
</li>
<li>to make other internal and lawful uses of your information that are compatible with the context in which you provided it.<br>
</li>
</ul>
<p>
<strong>
<em>Verifiable Consumer Requests</em>
</strong>
<br>
</p>
<p>The CCPA considers the right to know and the right to delete as verifiable consumer requests.
Verifiable consumer requests must: (i) provide sufficient information that allows us to reasonably verify that you are in fact the California resident or Household about whom we collected personal information or an authorized representative.
and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.<br>
</p>
<p>We may deny a request to know or a request to delete if we cannot verify your identity or authority to make the request or confirm that the requested personal information relates to you.<br>
</p>
<p>We will only use personal information that you provide us to verify your identity or authority.<br>
</p>
<p>
<strong>
<em>How to Submit a Request to Know or a Request to Delete</em>
</strong>
<br>
</p>
<p>Submit your request using the information in Section 7 (Contact Information) above and include the value of your tribalfusion.com ANON_ID cookie (“TF ANON_ID Cookie Value” or “Cookie Value”) as explained below.<br>
</p>
<p>
<strong>
<em>Verifying Your Identity with Your TF ANON_ID Cookie Value</em>
</strong>
<br>
</p>
<p>Your Cookie Value is the only repository where consumer identifying information may be stored.
To find your TF ANON_ID Cookie Value (highlighted blue in example below):<br>
</p>
<ul>
<li>Open your web browser and go to “tribalfusion.com”;<br>
</li>
<li>Locate the ANON_ID cookie (see image below) in your browser’s privacy or cookie settings (location will vary by browser).
and<br>
</li>
<li>Copy the TF ANON_ID Cookie Value and email it to privacy@VDX.tv.<br>
</li>
</ul>
<p>Your Cookie Value is the only repository where consumer identifying information may be stored.
To find your TF ANON_ID Cookie Value (highlighted blue in example below):<br>
</p>
<p>
<strong>
<em>Our Confirmation of or Response to Your Request to Know or Request to Delete</em>
</strong>
<br>
</p>
<p>The CCPA generally permits you to request that we and our direct service providers (i.e., Partners) delete personal information collected from you in accordance with Civil Code section 1798.105.
However, we are not required to delete your personal information for any of the following reasons:<br>
</p>
<ul>
<li>permanently and completely erasing your personal information on our existing systems (except archived or back-up systems);<br>
</li>
<li>deidentifying your personal information.
or<br>
</li>
<li>aggregating your personal information.<br>
</li>
</ul>
<p>If we deny your request, we will (unless otherwise prohibited by law):<br>
</p>
<ul>
<li>describe the basis for the denial, including any conflict with federal or state law, or CCPA exception;<br>
</li>
<li>delete any personal information that is not subject to the exception (if any).
and<br>
</li>
<li>will not use your personal information retained for any other purpose than provided for by the CCPA exception.<br>
</li>
</ul>
<p>If we are unable to verify your identity, we may deny your request.
However, we will inform you that your identity cannot be verified.<br>
</p>
<p>
<strong>Right to Opt-Out of the Sale of Your Information</strong>
<br>
</p>
<p>Under the CCPA, you may opt-out of the sale of your personal information from a business to third parties.
<strong>While we do not sell your personal information suppression of any sharing of your personal information can be applied by following the same steps laid out in the Right to Delete above.</strong>
<br>
</p>
<p>
<strong>Rights for Minors</strong>
<br>
</p>
<p>Our Site and services are not intended for children.
We do not knowingly collect, maintain, or sell the personal information of children under the age of sixteen (16).<br>
</p>
<p>
<strong>Right to Non-Discrimination</strong>
<br>
</p>
<p>We will not discriminate against you for exercising any of your CCPA rights.
We will not:<br>
</p>
<ul>
<li>Deny you services;<br>
</li>
<li>Charge you different prices or rates for services by granting discounts or other benefits, or imposing penalties;<br>
</li>
<li>Provide you a different level or quality of services.
or<br>
</li>
<li>Suggest that you may receive a different price or rate for services or a different level or quality of services.<br>
</li>
</ul>
<p>
<strong>Who May Exercise Your CCPA Rights</strong>
<br>
</p>
<p>Only you, a valid power of attorney under the California Probate Code, as amended, or a natural person or business entity registered with the Secretary of State to conduct business in California that you authorize to act on your behalf (“Authorized Agent”), may make a verifiable consumer request to know or delete related to your information.<br>
</p>
<p>If you wish to submit a request to know or a request to delete via an Authorized Agent, your Authorized Agent must provide us with written and signed permission from you to submit the request(s).
“Signed” means that the written attestation, declaration, or permission has either been physically signed or provided electronically per the Uniform Electronic Transactions Act, Civil Code section 1633.7 <em>et seq.
</em>
<br>
</p>
<p>Next, contact us (as outlined in Section 7 (Contact Information) above) so we may verify your identity and confirm that you provided the requesting Authorized Agent permission to submit the request(s).<br>
</p>
<p>
<strong>Fees</strong>
<br>
</p>
<p>We will not charge a fee to process or respond to your verifiable consumer request unless it is excessive.
If we reasonably determine that the request requires a fee, we will tell you why we made that decision and give you a cost estimate in writing before completing your request.<br>
</p>
<p>
<strong>Shine The Light Law</strong>
<br>
</p>
<p>Separate from the CCPA, California Civil Code Section 1798.83, as amended, also known as the “Shine The Light” law gives California residents the right to request and obtain what personal information we share with third parties for those third parties’ direct marketing purposes.
We do not disclose your personal information to third parties for such third parties to directly market their services to you.
If you have any questions about our Shine The Light Law practices, please contact us as outlined in Section 7 (Contact Information) above.<br>
</p>
<p>
<strong>Do Not Track</strong>
<br>
</p>
<p>California law requires us to tell you how we respond to web browser Do Not Track (“DNT”) signals.
DNT allows users a way to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services.
We do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.<br>
</p>
<p>
<strong>Disclosure of Consumer Requests</strong>
<br>
</p>
<p>As required by the California Consumer Privacy Act (“CCPA”), VDX.tv handled the following types of consumer requests during the year 2020:<br>
</p>Type of RequestReceivedFulfilledDeniedAverage Response TimeSubject Access252508 daysData Removal484805 daysOpt-out/Delete6362010 days<p>Note, these are global numbers, not only from California residents.<br>
</p>
<p>In terms of the data we use, “opt-out” is the same as “delete”.
“Data Removal” in the table above means that if we receive a request regarding data on one of our partner publisher websites, over which we have no editorial control, we will forward the request to the partner publisher for further action.<br>
</p>
<p>The Ad Choices program is an industry initiative which aims to provide Internet users with appropriate information at the point of advertising delivery.
Full information on the use of the Ad Choices icon can be found at http://www.youradchoices.com/.</p>
<p>The Ad Choices icon is part of the DAA’s Self-Regulatory Principles and the DAAC’s Principles.
VDX.tv is a signatory to these self-regulatory initiatives.</p>
<p>You can opt out of being behaviorally targeted by VDX.tv and other companies employing online advertising via the Digital Advertising Alliance or the DAAC’s Opt-out tool.</p>
<p>Further information is included in our Privacy policy, including full contact details if you have any queries you wish to raise with us.</p>1.
Adding Publishers into the Network1.1 Adding Publishers into the network<p>Strict policies are in place to ensure that only high-quality sites are selected for VDX.tv’s network.
Adding publishers evolves from a two-step process:</p>
<p>
<strong>Site Acceptance:</strong>
</p>
<ul>
<li>Publishers must meet the VDX.tv Publisher Code of Conduct before being accepted</li>
<li>Manual quality checks are performed by VDX.tv employees to ensure compliance</li>
<li>Sites are also constantly scanned by our proprietary PageGuard<sup>TM</sup> technology and are removed if questionable content is found</li>
<li>Transparent site lists are always made available for advertisers to approve or remove sites that are not an appropriate match for their brand</li>
</ul>
<p>
<strong>Domain Verification:</strong>
</p>
<ul>
<li>Before a new site goes live, they must identify all domains that they will/might run an VDX.tv ad on</li>
<li>After the publisher submits the domain(s), VDX.tv employees manually vet the domain for brand-safety purposes</li>
<li>If the domain is approved, it is added into the ‘approved domain’ list.
VDX.tv’s ad server references this approved list to learn where it is and is not allowed, to serve an impression</li>
<li>If a non-approved domain calls our ad server for an ad, the ad server rejects the request and will NOT serve that domain an ad</li>
<li>This process and proprietary technology prevents publishers from accidentally or intentionally retrafficking our ads to questionable sites</li>
</ul>1.2 Publisher Code of Conduct Overview<ul>
<li>The VDX.tv Publisher Code of Conduct defines types of prohibited content (i.e.
pornography, copyright infringement, spam, fraud, pyramid schemes, etc…) and types of prohibited actions (i.e.
tag re-trafficking, altering ad creative, pay for clicks/impressions, timed rotations/auto-refresh, etc…)</li>
<li>Publisher domains are approved at VDX.tv’s discretion (i.e.
no publishers with downloadable software, no publishers that may be harmful to the business reputation of VDX.tv)</li>
</ul>1.3 Inventory acquired through RTB<ul>
<li>We supplement our on-network activity with inventory acquired off-network.</li>
<li>We typically use TAG-certified (https://www.tagtoday.net/registry) exchange partners, where feasible.</li>
<li>We always run activity via a pre-vetted domain Accept list, unless otherwise agreed with the client.</li>
<li>Our list of partners is available for review, although please note, this is subject to change.</li>
</ul>1.4 Ads.txt<ul>
<li>We support ads.txt and have done so since its launch in 2017.</li>
<li>We continue to work with publishers who have an ads.txt file enabled and enter us as an approved seller of their inventory.</li>
<li>Any inventory acquired through RTB is also ads.txt compliant.</li>
<li>We are committed to our role in creating a cleaner, more transparent advertising ecosystem for everyone.</li>
</ul>2.
Brand Safety<p>The following section outlines the various roles that both proprietary and 3rd party technology plays in ensuring delivery to the audience intended by the agency/brand.</p>
<p>
<strong>2.1 PageGuard™</strong>
</p>
<p>PageGuard™ is VDX.tv’s proprietary answer to ensuring that all campaigns are delivered to safe environments.
It uses a 3 step processes to provide a comprehensive and proactive solution to prevent the possibility of ads appearing on inappropriate content:</p>
<ul>
<li>
<strong>Site acceptance </strong>(covered in section 1.1)</li>
<li>
<strong>Domain Verification </strong>(covered in section 1.1)</li>
<li>
<strong>Page Level Contextualization:</strong> Pages are scanned daily according to traffic priority.
Our proprietary page-level contextualization technology then categorizes these pages, assessing the safety of the content.
In the event a page is deemed to be an unsafe brand environment, VDX.tv will not serve an ad.</li>
</ul>
<p>
<strong>2.2 3rd Party Content Verification</strong>
</p>
<p>In addition to PageGuard, we can also layer on 3<sup>rd</sup> party verification via one of our integrated partners, or via a vendor of the client’s choice.
This works as follows:</p>
<ol>
<li>An agency/brand decides they want to run a 3rd party verification tool </li>
<li>Agency either works directly with the verification provider to create verification specifications OR allows VDX.tv to pick a preferred vendor</li>
<li>Agency sends the specifications to VDX.tv – specs might include an Accept/Block list, intended or violating website categorizations, violating keywords, intended geo targeting, etc…</li>
<li>VDX.tv targets the campaign in our ad server per the agency’s specifications</li>
<li>Campaign is set live after applying the verification code in either the agency’s ad server or VDX.tv’s ad server</li>
<li>VDX.tv starts to receive reporting from the agency ad server AND the verification tool</li>
</ol>
<ul>
<li>If no violations are seen, continue to run campaign</li>
<li>If violations are seen, adjust campaign targeting until the violations go below the predetermined threshold or disappear altogether</li>
</ul>
<p>
<em>**Due to occasionally inaccurate categorizations by the 3rd party vendors, VDX.tv account managers are trained to vet the site categorization from the vendors against their own personal categorization.
If the AM categorization vastly disagrees with the vendor’s categorization engine, the AM may pursue the agency to add the site to a whitelist OR the verification vendor to re-categorize the site.</em>
</p>
<p>
<strong>2.3 Take Down Policy</strong>
</p>
<p>If violations are seen, we adjust the campaign targeting until the violations go below the predetermined threshold or disappear altogether.
Correction of flagged violations will occur within 48 hours, but best endeavors will be made to rectify immediately.
The contractual consequences of not responding appropriately to a takedown request in the specified time frame will be subject to the terms of individual IOs.</p>3.
Geo Targeting<p>We utilize the leading databases for effective geo-targeting.
Please note that there may be minor discrepancies as a result of different vendors using different databases. </p>4.
Malware<p>VDX.tv uses The Media Trust as its 3rd party malware detection service. </p>
<p>4.1 Media Trust Integration</p>
<p>We have an API integration with the Media Trust that allows them to programmatically scan our ad tags looking for malware.
If malware is detected on a tag, this is immediately flagged for internal review and where necessary, the campaign paused and client notified. </p>5.
Fraud<p>VDX.tv has a number of safeguards in place to help keep our network clean and free of invalid traffic: PageGuard, click fraud algorithms, impression fraud algorithms, and a proprietary ad server that allows us to monitor and adjust accordingly.</p>
<p>
<strong>5.1 Impression Fraud</strong>
</p>
<p>We do not serve any campaigns to robotic impressions</p>
<ul>
<li>For every impression, we compare the user agent with a list of known user agents and if found, we mark the request origination from a robot</li>
<li>Apart from the above static list, we maintain a count of ads served to a user over a certain amount of time.
If that gets too high, we flag the activity as potentially invalid and any subsequent impressions for the remaining browsing session will not be counted.
That flag can be removed if the activity returns to normal behavior for a sufficient period of time.</li>
<li>Bots are detected and blocked in the future both by means of built-in logic inside our ad server and offline processes.</li>
</ul>
<p>
<strong>5.2 Click Fraud</strong>
</p>
<ul>
<li>The ad server first checks the combination of creative id (via the mediadata_id), user_id (the unique id associated with a cookie) and timestamp.
If we’ve seen the combination before, disregard the click request (it’s a duplicate).
The ad server has a strong algorithm to detect all duplicate clicks and disregard those duplicate requests.</li>
<li>Next, check the IP address and user agent requesting the click against our list of known robots.
If either is found, the click request will not be honored.</li>
<li>If a user has clicked more than a certain number in a preset amount of time, it will be treated as ROBOT for all subsequent views/clicks</li>
<li>Bots are detected and blocked in the future both by means of built-in logic inside our ad server and having offline processes.</li>
</ul>
<p>
<strong>5.3 Manual Monitoring</strong>
</p>
<p>We look for suspicious patterns in the data that may indicate bots or purchased traffic</p>
<ul>
<li>
<strong>
<em>Pre-launch monitoring:</em>
</strong> Prior to approval, a domain is manually vetted using a combination of licensed tools and proprietary methodology to help determine the likelihood that the domain engages in nefarious behavior</li>
<li>
<strong>
<em>Post-launch monitoring:</em>
</strong> After domain approval and traffic starts flowing, pubs are monitored on certain distributions of inventory types, as well as fluctuations of various metrics</li>
<li>
<strong>
<em>Consultative technology monitoring:</em>
</strong> various services are leveraged as an additional safeguard</li>
</ul>
<p>VDX.tv’s dedicated publisher team manually monitors this publisher activity on an ongoing basis.
If irregularities are noticed, we will either:</p>
<ul>
<li>Remove the publisher immediately, OR</li>
<li>Start a conversation regarding the infraction(s).
If the publisher is forthcoming with information, we will entertain a second chance.
If not, they will be removed</li>
</ul>6.
Verified Services Used<p>Please refer to our list of services that are leveraged by VDX.tv’s display network to guarantee accurate delivery of advertiser campaigns.
Some of these services are used on request, while others are used at regular or consistent intervals.</p>
<p>VDX.tv reserves the right, at its sole discretion, to modify, discontinue or terminate these Safety Guidelines at any time and without advance notice.
Continued access to or use of VDX.tv’s services after any such revision constitutes agreement to the revised Safety Guidelines.</p>
<p></p>
<p>
<em>Last modified July 2022</em>
</p>
<p>Copyright © 2022 VDX.tv</p>
<p></p>
<p>
</p>
<p>VDX.tv takes a zero-tolerance approach towards slavery and human trafficking within its supply chain and expects the same commitment from its suppliers, contractors, and business partners.
This statement sets out the steps it has taken during the financial year to reflect this commitment.</p>
<strong>Organisational structure</strong>
<p>VDX.tv is an international video advertising effectiveness company.
We employ over 500 people in a number of offices located across North America, Europe, Middle East, Africa and Asia Pacific.</p>
<strong>Our Supply Chains</strong>
<p>Our key supply chains comprise:</p>
<ul>
<li>Digital advertising marketplaces, exchanges, supply-side platforms and publishers;</li>
<li>Other companies supplying services connected to the serving, monitoring and verification of on-line advertisements;</li>
<li>Data suppliers.
and</li>
<li>Other IT and technical service companies.</li>
</ul>
<p>These businesses are predominantly staffed by highly-skilled employees.
We consider that the sector that we operate in, the transactions that we undertake and any business relationships that we enter into all carry a negligible risk in terms of slavery and human trafficking.</p>
<p>In light of the above, VDX.tv assesses that the overall risk from slavery and human trafficking within its business is negligible.</p>
<strong>Our Approach</strong>
<p>VDX.tv acts ethically and with integrity in all its business relationships.
VDX.tv is committed to ensuring that there is no slavery or human trafficking in its supply chains or in any part of our business.
We hire individuals directly via interview process, whether permanent staff or contractor.
The vast majority of our employees are permanent staff.
</p>
<strong>Due Diligence</strong>
<p>VDX.tv will not support or deal with any business knowingly involved in slavery or human trafficking.</p>
<p>VDX.tv will remain alert to any risk from slavery and human trafficking.
If VDX.tv has any reason to suspect that any of its suppliers are affected by slavery or human trafficking, it will carry out reasonable and proportionate investigations and take whatever action it considers appropriate.</p>
<strong>Further Steps</strong>
<p>We will review the risk from slavery and human trafficking annually and assess whether the risk has increased.
If the risk has increased, we will consider what further actions are required to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains.
Such further actions may include adapting the supply chain and/or extending training about slavery and human trafficking more widely across employees.</p>
<p>This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015.</p>
<p>
</p>Introduction<p>Exponential Interactive, Inc.
doing business as VDX.tv (“we”, “us”, or “our”) is an advertising media services company whose clients and customers are online advertisers (“Advertisers”) and digital content providers (collectively, our “Partners”).
We help our Partners reach their target audiences and grow through ad sales.
Learn more about us at VDX.tv.<br>
</p>
<p>We are active members of advertising industry groups the Digital Advertising Alliance (“DAA”), and the Digital Advertising Alliance of Canada (“DAAC”).
We are signatories to the DAA Self-Regulatory Principles for Online Behavioral Advertising and the DAAC Self-Regulatory Principles for Online Behavioural Advertising.<br>
</p>Purpose<p>This Privacy Policy (“Policy”) describes our practices, both online and offline, regarding the collection, use, disclosure and sale of personal data and personal information, and of the rights of consumers regarding their own personal data and personal information (collectively, “your information”) when you visit our website at VDX.tv (“Site”), in relation to the services we provide our Partners, and any other means in which you interact with us, directly or indirectly.
We are committed to protecting your privacy and processing your information in accordance with all applicable privacy and data protection laws, rules, and regulations, such as the European Union General Data Protection Regulation 2016/679, as amended (“GDPR”) and the California Consumer Privacy Act of 2018, as amended (“CCPA”).<br>
</p>
<p>Please read this Policy carefully.
When you use this Site, you consent to our collection, storage, use, disclosure, and safeguarding of your information as described in this Policy.
If you do not agree with the terms of this Policy, do not use this Site.<br>
</p>Table of contents<p>Please read this Policy carefully.
When you use this Site, you consent to our collection, storage, use, disclosure, and safeguarding of your information as described in this Policy.
If you do not agree with the terms of this Policy, do not use this Site.<br>
</p>
<ol>
<li>Information we collect and how we use it</li>
<li>Opting out</li>
<li>Third parties and categories of information</li>
<li>Data retention</li>
<li>Children’s privacy</li>
<li>Security</li>
<li>Contact information</li>
<li>Changes to this policy</li>
<li>California privacy rights</li>
<li>European privacy rights</li>
<li>International data transfers</li>
</ol>Information we collect and how we use it<p>We may collect, transmit, and store your information provided to us from the following categories of sources (i.e., types or groupings of persons or entities from which a business collects personal information about consumers) and categories of third parties (i.e., types or groupings of third parties with whom the business shares personal information) – directly from you, our online technology, and our Partners.</p>Directly from You<p>We collect your information directly from you and for the following purposes when you:</p>
<ul>
<li>submit a job application, resume, cover letter, or social media profile to a job vacancy, or interview with us;</li>
<li>enter into an employment or consulting services contract with us;</li>
<li>complete forms, post content on our Site, respond to surveys, or use any features on our Site;</li>
<li>provide feedback to us by phone, email, physical mail, or any other means of providing feedback;</li>
<li>interact with us on our social media accounts, including without limitation LinkedIn, Twitter, and Facebook;</li>
<li>subscribe to any of our marketing materials.
and</li>
<li>participate in contests sponsored by us.</li>
</ul>
<p>Online Technology</p>
<p>We may automatically collect certain information when you use our online technology.
Such information includes:<br>
</p>
<ul>
<li>Internet Protocol (“IP”) Address: An address provided by your internet service provider (“ISP”) to connect you to the internet and enable delivery of your online requests.</li>
<li>Cookie Identifier: A cookie (data file) with a unique identifier that we set from our domain “tribalfusion.com”.</li>
<li>User Agent: Information related to the web browser that acts on your behalf and enables your interaction with web content.</li>
<li>Clickstream Data: Information about your interaction with a webpage (e.g., time and date you visited the page.
webpage address.
title of ad shown.
topics (such as “beach” or “Caribbean”) that we interpret (as “summer vacation”) from the page.</li>
<li>Viewed Content Data: Information related to video content viewed on an internet-connected TV (“Connected TV”).</li>
</ul>
<p>Other information that may be collected include browser session location, ISP, pages that you visit before, during, and after using our Site, links you click, how you use our online technology, and information from any associated devices used to interact with our online technology.<br>
</p>
<p>
<strong>Our Partners</strong>
<br>
</p>
<p>Our Partners receive your information when you visit or use their services or through third parties they work with.
We require our Partners to have lawful rights to collect, use, and share your information before we receive any of your information.
A list of Partners with whom we may share data is available on our Partnerships &.
Accreditations page located at https://vdx.tv/partnerships.
Our Partners perform different services such as advertising brand safety and quality, advertising brand reporting, privacy, data management platforms, and advertising inventory.<br>
</p>
<p>We may use one or more of our partners to onboard offline data which may originally have included Personally Identifiable Information, however we do not use or have access to any PII as part of this process.<br>
</p>
<p>We may also use analytics vendors such as Google Analytics to allow tracking technologies and remarketing services through the use of first- and third-party cookies to analyze and track users’ use of this Site, determine the popularity of certain content, and better understand online activity.
We do not transfer your information to these analytics vendors.<br>
</p>
<p>However, by accessing this Site, you consent to the collection and use of your information by these analytics vendors.
We encourage you to review these vendors’ privacy policies.
If you do not want your information to be collected and used by these analytics vendors, contact the responsible analytics vendor directly or use the DAA Opt-Out Tool, or DAAC Opt-Out Tool.<br>
</p>Opting Out<p>We and our Partners may use web beacons, tags, advertising identifiers, and similar technology (collectively, “cookies”) related to your use of this Site and in providing our services.</p>
<p>Cookies may transmit information about you and your use of this Site, such as your browser type, IP address, data relating to ads displayed to you or ads that you have interacted with, and the date and time of your use.
Cookies may be persistent (e.g., stored on your device until it expires or until you delete them) or stored only during an individual web browsing session.
Our tracking cookies automatically expire (i.e., are automatically deleted from your web browser) ninety (90) days from the last time we encounter you.
</p>
<p>Generally, cookies help make ads more relevant to you and remove ads you already viewed.
Cookies also make ads more valuable to our Partners by improving reporting on campaign performance (e.g., whether an advertiser reached its audience or not.
how many ads were shown.
how many clicks an ad received.
etc.).</p>
<p>We use cookies for the following purposes:<br>
</p>
<ul>
<li>Create audience segments, build targeting profiles, and delivering ads based on automated decision-making related to those profiles;</li>
<li>Help our Partners to measure the effectiveness and distribution of their ads and digital content, and to understand the consumers who use Partner services;</li>
<li>Detect and prevent fraud;</li>
<li>Troubleshoot problems to increase the efficiency and operation of this Site.
and</li>
<li>As required by applicable law, rule, or regulation if we believe your information is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect our rights or the rights of others.</li>
</ul>Opting Out of Our Cookies<p>If you do not want our cookies on your device, you can opt-out by visiting our Opt-Out page at http://exponential.com/privacy/opt-out and clicking on the Opt-Out link.
The Opt-Out page will automatically confirm whether or not your opt-out request was successful.</p>
<p>When you opt-out, your device will overwrite our cookie with a non-identifying opt-out cookie (“Opt-Out Cookie”).
The Opt-Out Cookie indicates that your data should not be used for behaviorally-targeted advertising.
The details of the Opt-Out Cookie are shown below.</p>
<p>If you reject our cookie, you may still use our Site, but your ability to use some features or areas of our Site may be limited.
If you have any questions about opting out of our cookies, please contact us as outlined in Section 7 (Contact Information) below.</p>
<p>If you do not want targeted advertising cookies from us or similar companies, please use one of the opt-out mechanisms provided by DAA or DAAC.
If you do not want any cookies on your device, you can change your browser or device settings to reject cookies or visit About Cookies.<br></p>Opting Out on Connected TV devices<p>To manage privacy preferences around digital advertising on TV streaming devices, please refer to https://www.networkadvertising.org/internet-connected-tv-choices/ or the device manufacturer’s instructions.<br>
</p>Third Parties And Categories Of Information<p>The categories of third parties that may receive your information include Partners.<br>
</p>
<ul>
<li>We may share your information with our Partners for the purpose of conducting general business analysis.
We may also share your information with our Partners for marketing purposes, as permitted by law.
We adhere to the DAA Self-Regulatory Principles for Online Behavioral Advertising and the DAAC Self-Regulatory Principles for Online Behavioural Advertising.
Partners may be able to associate the information we share with other information they have about you from other sources.
We do not have full access to or control over the cookies our Partners use, but you may be able to opt out of some of their practices by contacting the responsible Partner or via the DAA Opt-Out Tool or DAAC Opt-Out Tool.<br>Please note that even after you withdraw your consent, we may, to the extent required or permitted by law, continue to process your personal information.<br>
</li>
</ul>
<p>The categories of information related to third parties include:<br>
</p>
<ul>
<li>Aggregated and Deidentified Information: We receive and share aggregated and deidentified information with third parties in connection with advertising programs and data analytics.
For example, we may provide our Partners with the number of users who have been exposed to or interacted with certain ads.<br>
</li>
<li>Business Transfers: We may share information from or about you with companies under common control with us and require those companies to also honor this Policy.
If another company acquires us, or all or substantially all of our assets, such company will possess the same information.<br>
</li>
<li>Investigations and Legal Disclosures: We may investigate and disclose your information if we have a good faith belief that such investigation or disclosure: (i) is reasonably necessary to comply with legal, regulatory or law enforcement processes, such as a search warrant, subpoena, statute, judicial proceeding, or other legal or regulatory process or law enforcement request.
(ii) is helpful to identify, investigate, or prevent possible wrongdoing related to our Site or Partners.
or (iii) is necessary to protect our rights or the rights of others.<br>
</li>
<li>Links: The Site may link to the websites of third party (non-Partners) that we are not affiliated with.
We do not share your information with third party (non-Partners) and are not responsible for their privacy practices.<br>
</li>
</ul>Data Retention<p>Our tracking cookie automatically expires (i.e., is automatically deleted from your web browser) ninety (90) days from the last time we encounter you.<br>
</p>
<p>We retain log file data including cookie ID and IP address for one hundred (100) days for troubleshooting purposes or Subject Access Requests.
It is archived beyond that point if required as part of our legal and regulatory obligations, to a total duration of three (3) years.<br>
</p>Children's Privacy<p>Our Site and services are not intended for children.
We do not knowingly collect, maintain, or sell the personal information of children under the age of sixteen (16).
If you are under the age of sixteen (16), please do not access our Site or use our services.
If we learn that we have inadvertently collected personal information of children under the age of sixteen (16), we will delete such information unless otherwise required by applicable law, regulation, or rule.<br>
</p>Security<p>We use commercially reasonable administrative, technical, and physical security measures to safeguard your information.
Despite our efforts, please note that any information disclosed online is inherently vulnerable to interception and misuse by unauthorized parties.
As such, we cannot absolutely guarantee total security of your information.<br>
</p>Contact Information<p>Please contact us with any questions about this Policy using the information below:<br>
</p>
<p>
<strong>United States Address<br>
</strong>Exponential Interactive, Inc.
d/b/a VDX.tv<br>Attn: Legal Department<br>2340 Powell Street, #378<br>Emeryville, CA 94608<br>
</p>
<p>U.S.
Phone<br>U.S.
toll-free number +1 (800) 480-0816<br>Emeryville local office number +1 (510) 250-5500<br>
</p>
<p>
<strong>United Kingdom Address<br>
</strong>Exponential Interactive, Inc.
d/b/a VDX.tvAttn: Data Protection Officer30 Stamford Street London, SE19LQ<br>
</p>
<p>
<strong>Email<br>
</strong>privacy@vdx.tv<br>
</p>
<p>To protect the security of your information, we will take steps as we deem necessary to confirm your identity or the identity of your Authorized Agent or valid power of attorney before completing a request or sharing any personal information with you or your Authorized Agent or valid power of attorney.<br>
</p>Changes To This Policy<p>We reserve the right to update this Policy at any time and for any reason.
Any changes or modifications will be effective as of the “Effective Date” at the top of this Policy.
We will notify you about any changes to this Policy by updating the “Last updated” date at the top of this Policy.
In some cases, we may also notify you of Policy updates by adding a statement to our Site homepage, via email, or by any other means of communication allowed by law.<br>
</p>
<p>We encourage you to review this Policy from time to time to stay informed about our privacy practices and your options.
By continuing to access or use this Site after those updates become effective, you agree to be bound to the terms of the then-current Policy.<br>
</p>California Privacy Rights<p>Under the CCPA, California residents and households have certain rights around the collection, use, and sharing of their personal information.<br>
</p>
<p>
<strong>Disclosure or Sale of Personal Information</strong>
<br>
</p>
<p>We have not disclosed or sold any personal information to third parties for any business or commercial purpose in the preceding twelve (12) months.
We do not and will not disclose or sell your personal information without giving you notice and an opportunity to opt out of such disclosure or sale as required by law.<br>
</p>
<p>
<strong>We do not offer financial incentives associated with our collection, use, or disclosure of your personal information.</strong>
<br>
</p>
<p>We collect various categories of personal information when you use this Site or our Partner sites, including identifiers, commercial information, internet or other electronic network or device activity, geolocation data, and professional information.
A detailed description of the information we collect and how we use it is provided in Section 1 (Information We Collect and How We Use It) above.
Section 3 (Third Parties and Categories of Information) above describes the categories of third parties with whom we share personal information, and what information may be shared and under what circumstances.<br>
</p>
<p>
<strong>Information We Collect</strong>
<br>
</p>
<p>We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”).
In particular, we have collected the following categories of personal information from consumers from the following within the last twelve (12) months:<br>
</p>CategoryExamplesCollectedA.
IdentifiersA real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.YesB.
Personal information categories listed in the California Customer Records statute (Cal.
Civ.
Code § 1798.80(e))A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information in this category may overlap with other categories.YesC.
Protected classification characteristics under California or federal lawAge (forty (40) years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).YesD.
Commercial informationRecords of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.YesE.
Biometric informationGenetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.NoF.
Internet or other similar network activityBrowsing history, information on a consumer’s interaction with a website, application, or advertisement.YesG.
Geolocation dataPhysical location or movements.YesH.
Sensory dataAudio, electronic, visual, thermal, olfactory, or similar information.NoI.
Professional or employment-related informationCurrent or past job history or performance evaluations, and administering employment benefits including retirement, health, and other benefit programs, services, or products to which consumers and their dependents or their beneficiaries receive access through the consumer’s employer.YesJ.
Non-public education information (Family Educational Rights and Privacy Act (20 U.S.C.
§ 1232g, 34 C.F.R.
Part 99))Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.NoK.
Inferences drawn from other personal informationProfile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.Yes<p>Under the CCPA, personal information does not include:<br>
</p>
<ul>
<li>Publicly available information from government records;<br>
</li>
<li>Deidentified or aggregated consumer information;<br>
</li>
<li>Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996, and the California Confidentiality of Medical Information Act, or clinical trial data.
or<br>
</li>
<li>Sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994.<br>
</li>
</ul>
<p>We receive the categories of personal information listed in the chart above from the following sources:<br>
</p>
<ul>
<li>Directly from you;<br>
</li>
<li>Partners or their agents (e.g., information that our Partners give to us related to the services for which they engage us).
and<br>
</li>
<li>Directly and indirectly from activity on our Site (e.g., usage details collected automatically).<br>
</li>
</ul>
<p>
<strong>Use of Personal Information</strong>
<br>
</p>
<p>We may use or disclose the personal information we collect for some or more of the following business purposes:<br>
</p>
<ul>
<li>To fulfill or meet the reason for which such personal information is provided;<br>
</li>
<li>To provide you with information, products, or services that you request from us;<br>
</li>
<li>To improve our Site and its contents to you;<br>
</li>
<li>For testing, research, analysis, and product development;<br>
</li>
<li>As necessary or appropriate to protect our rights or the rights of others;<br>
</li>
<li>To respond to law enforcement requests and as required by applicable law, regulation, rule, or court order;<br>
</li>
<li>As otherwise set forth in the CCPA.
or<br>
</li>
<li>To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.<br>
</li>
</ul>
<p>We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without notifying you as required by law.<br>
</p>
<p>
<strong>Sharing Personal Information</strong>
<br>
</p>
<p>We may disclose your personal information to a third party (i.e., our Partners) for a business purpose.
When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep that personal information confidential and not use it for any purpose except performing the contract.<br>
</p>
<p>In the preceding twelve (12) months, we have disclosed the following categories of personal information (listed above) for a business purpose with two (2) categories of third parties: (1) service providers (“Service Providers”).
and (2) third parties to whom you or your agents authorized us to disclose your information in connection with our products or services (“Authorized Third Parties”) – detailed in the chart below:<br>
</p>CategoryExamplesCategories of Third Parties We Shared Personal Information WithA.
IdentifiersA real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.Service Providers.
and Authorized Third PartiesB.
Personal information categories listed in the California Customer Records statute (Cal.
Civ.
Code § 1798.80(e))A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information in this category may overlap with other categories.Service Providers.
and Authorized Third PartiesC.
Protected classification characteristics under California or federal lawAge (forty (40) years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).Service Providers.
and Authorized Third PartiesD.
Commercial informationRecords of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.Service Providers.
and Authorized Third PartiesF.
Internet or other similar network activityBrowsing history, information on a consumer’s interaction with a website, application, or advertisement.Service Providers.
and Authorized Third PartiesG.
Geolocation dataPhysical location or movements.Service Providers.
and Authorized Third PartiesI.
Professional or employment-related informationAudio, electronic, visual, thermal, olfactory, or similar information.Service Providers.
and Authorized Third PartiesK.
Inferences drawn from other personal informationCurrent or past job history or performance evaluations, and administering employment benefits including retirement, health, and other benefit programs, services, or products to which consumers and their dependents or their beneficiaries receive access through the consumer’s employer.Service Providers.
and Authorized Third Parties<p>
<strong>Your Data Privacy Rights Under CCPA</strong>
<br>
</p>
<p>Generally, California resident or household consumers have the following data privacy rights under the CCPA:<br>
</p>
<ul>
<li>
<strong>Right to Know</strong>: You may request that a business tell you what specific personal information it collected, shared, or sold about you, and why it was collected, shared, or sold;<br>
</li>
<li>
<strong>Right to Delete</strong>: You may request that a business delete personal information that it collected from you, subject to some exceptions;<br>
</li>
<li>
<strong>Right to Opt-Out</strong>: You may request that a business stop selling your personal information;<br>
</li>
<li>
<strong>Rights for Minors</strong>: A business cannot sell the personal information of minors under the age of sixteen (16) without their permission and, for children under thirteen (13), without parental consent.
and<br>
</li>
<li>
<strong>Right to Non-Discrimination</strong>: A business may not discriminate against consumers who exercise their rights under the CCPA.<br>
</li>
</ul>
<p>
<strong>Right to Know (i.e., Information About and Access to Your Personal Information)</strong>
<br>
</p>
<p>You have the right to request that we disclose personal information we collected about you pursuant to Civil Code sections 1798.100, 1798.110, or 1798.115 including any or all of the following:<br>
</p>
<ul>
<li>Specific pieces of personal information that we collected about you;<br>
</li>
<li>Categories of personal information we collected about you;<br>
</li>
<li>Categories of sources from which your personal information is collected;<br>
</li>
<li>Categories of personal information that we sold or disclosed for a business purpose about you;<br>
</li>
<li>Categories of third parties to whom your personal information was sold or disclosed for a business purpose.
and<br>
</li>
<li>The business or commercial purpose for collecting or selling your personal information.<br>
</li>
</ul>
<p>In responding to your verified consumer request to know, we will provide information on:<br>
</p>
<ul>
<li>The categories of personal information we collected about you (e.g., IP address, geolocation data, internet activity such as web browsing histories, and professional or employment-related information) in the preceding twelve (12) months from the date we receive your request;<br>
</li>
<li>The categories of sources from which your personal information was collected (e.g., cookies);<br>
</li>
<li>The business or commercial purpose for which we collected or sold your personal information (e.g., fraud prevention, marketing, etc.);<br>
</li>
<li>The categories of third parties with which we share your personal information;<br>
</li>
<li>The categories of personal information that we sold in the preceding twelve (12) months, and for each category identified, the categories of third parties to which we sold that particular category of personal information.
and<br>
</li>
<li>The categories of personal information that we disclosed for a business purpose in the preceding twelve (12) months, and for each category identified, the categories of third parties to whom we disclosed that particular category of personal information.<br>
</li>
</ul>
<p>The CCPA also requires that if requested, we provide you with responsive materials in a readily usable format that allows you to transmit your information from one (1) entity to another without hindrance.<br>
</p>
<p>
<strong>Right to Delete</strong>
<br>
</p>
<p>The CCPA generally permits you to request that we and our direct service providers (i.e., Partners) delete personal information collected from you in accordance with Civil Code section 1798.105.
However, we are not required to delete your personal information for any of the following reasons:<br>
</p>
<ul>
<li>if we need your information to complete the transaction for which it was collected;<br>
</li>
<li>to comply with a legal obligation;<br>
</li>
<li>to comply with the California Electronic Communications Privacy Act (Cal.
Penal Code § 1546 <em>et seq</em>.), as amended;<br>
</li>
<li>to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;<br>
</li>
<li>to identify and repair errors that impair existing and intended functionality.
or<br>
</li>
<li>to make other internal and lawful uses of your information that are compatible with the context in which you provided it.<br>
</li>
</ul>
<p>
<strong>
<em>Verifiable Consumer Requests</em>
</strong>
<br>
</p>
<p>The CCPA considers the right to know and the right to delete as verifiable consumer requests.
Verifiable consumer requests must: (i) provide sufficient information that allows us to reasonably verify that you are in fact the California resident or Household about whom we collected personal information or an authorized representative.
and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.<br>
</p>
<p>We may deny a request to know or a request to delete if we cannot verify your identity or authority to make the request or confirm that the requested personal information relates to you.<br>
</p>
<p>We will only use personal information that you provide us to verify your identity or authority.<br>
</p>
<p>
<strong>
<em>How to Submit a Request to Know or a Request to Delete</em>
</strong>
<br>
</p>
<p>Submit your request using the information in Section 7 (Contact Information) above and include the value of your tribalfusion.com ANON_ID cookie (“TF ANON_ID Cookie Value” or “Cookie Value”) as explained below.<br>
</p>
<p>
<strong>
<em>Verifying Your Identity with Your TF ANON_ID Cookie Value</em>
</strong>
<br>
</p>
<p>Your Cookie Value is the only repository where consumer identifying information may be stored.
To find your TF ANON_ID Cookie Value (highlighted blue in example below):<br>
</p>
<ul>
<li>Open your web browser and go to “tribalfusion.com”;<br>
</li>
<li>Locate the ANON_ID cookie (see image below) in your browser’s privacy or cookie settings (location will vary by browser).
and<br>
</li>
<li>Copy the TF ANON_ID Cookie Value and email it to privacy@VDX.tv.<br>
</li>
</ul>
<p>Your Cookie Value is the only repository where consumer identifying information may be stored.
To find your TF ANON_ID Cookie Value (highlighted blue in example below):<br>
</p>
<p>
<strong>
<em>Our Confirmation of or Response to Your Request to Know or Request to Delete</em>
</strong>
<br>
</p>
<p>The CCPA generally permits you to request that we and our direct service providers (i.e., Partners) delete personal information collected from you in accordance with Civil Code section 1798.105.
However, we are not required to delete your personal information for any of the following reasons:<br>
</p>
<ul>
<li>permanently and completely erasing your personal information on our existing systems (except archived or back-up systems);<br>
</li>
<li>deidentifying your personal information.
or<br>
</li>
<li>aggregating your personal information.<br>
</li>
</ul>
<p>If we deny your request, we will (unless otherwise prohibited by law):<br>
</p>
<ul>
<li>describe the basis for the denial, including any conflict with federal or state law, or CCPA exception;<br>
</li>
<li>delete any personal information that is not subject to the exception (if any).
and<br>
</li>
<li>will not use your personal information retained for any other purpose than provided for by the CCPA exception.<br>
</li>
</ul>
<p>If we are unable to verify your identity, we may deny your request.
However, we will inform you that your identity cannot be verified.<br>
</p>
<p>
<strong>Right to Opt-Out of the Sale of Your Information</strong>
<br>
</p>
<p>Under the CCPA, you may opt-out of the sale of your personal information from a business to third parties.
<strong>While we do not sell your personal information suppression of any sharing of your personal information can be applied by following the same steps laid out in the Right to Delete above.</strong>
<br>
</p>
<p>
<strong>Rights for Minors</strong>
<br>
</p>
<p>Our Site and services are not intended for children.
We do not knowingly collect, maintain, or sell the personal information of children under the age of sixteen (16).<br>
</p>
<p>
<strong>Right to Non-Discrimination</strong>
<br>
</p>
<p>We will not discriminate against you for exercising any of your CCPA rights.
We will not:<br>
</p>
<ul>
<li>Deny you services;<br>
</li>
<li>Charge you different prices or rates for services by granting discounts or other benefits, or imposing penalties;<br>
</li>
<li>Provide you a different level or quality of services.
or<br>
</li>
<li>Suggest that you may receive a different price or rate for services or a different level or quality of services.<br>
</li>
</ul>
<p>
<strong>Who May Exercise Your CCPA Rights</strong>
<br>
</p>
<p>Only you, a valid power of attorney under the California Probate Code, as amended, or a natural person or business entity registered with the Secretary of State to conduct business in California that you authorize to act on your behalf (“Authorized Agent”), may make a verifiable consumer request to know or delete related to your information.<br>
</p>
<p>If you wish to submit a request to know or a request to delete via an Authorized Agent, your Authorized Agent must provide us with written and signed permission from you to submit the request(s).
“Signed” means that the written attestation, declaration, or permission has either been physically signed or provided electronically per the Uniform Electronic Transactions Act, Civil Code section 1633.7 <em>et seq.
</em>
<br>
</p>
<p>Next, contact us (as outlined in Section 7 (Contact Information) above) so we may verify your identity and confirm that you provided the requesting Authorized Agent permission to submit the request(s).<br>
</p>
<p>
<strong>Fees</strong>
<br>
</p>
<p>We will not charge a fee to process or respond to your verifiable consumer request unless it is excessive.
If we reasonably determine that the request requires a fee, we will tell you why we made that decision and give you a cost estimate in writing before completing your request.<br>
</p>
<p>
<strong>Shine The Light Law</strong>
<br>
</p>
<p>Separate from the CCPA, California Civil Code Section 1798.83, as amended, also known as the “Shine The Light” law gives California residents the right to request and obtain what personal information we share with third parties for those third parties’ direct marketing purposes.
We do not disclose your personal information to third parties for such third parties to directly market their services to you.
If you have any questions about our Shine The Light Law practices, please contact us as outlined in Section 7 (Contact Information) above.<br>
</p>
<p>
<strong>Do Not Track</strong>
<br>
</p>
<p>California law requires us to tell you how we respond to web browser Do Not Track (“DNT”) signals.
DNT allows users a way to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services.
We do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.<br>
</p>
<p>
<strong>Disclosure of Consumer Requests</strong>
<br>
</p>
<p>As required by the California Consumer Privacy Act (“CCPA”), VDX.tv handled the following types of consumer requests during the year 2020:<br>
</p>Type of RequestReceivedFulfilledDeniedAverage Response TimeSubject Access252508 daysData Removal484805 daysOpt-out/Delete6362010 days<p>Note, these are global numbers, not only from California residents.<br>
</p>
<p>In terms of the data we use, “opt-out” is the same as “delete”.
“Data Removal” in the table above means that if we receive a request regarding data on one of our partner publisher websites, over which we have no editorial control, we will forward the request to the partner publisher for further action.<br>
</p>European Privacy Rights<p>This Section 10 applies to European Residents only.
A “European Resident” is a resident of a country in the European Economic Area (“EEA”).<br>
</p>
<p>The GDPR describes situations in which companies are permitted to collect or reuse your personal information.<br>
</p>
<p>Our legal basis for collecting and using your information depends on the specific information at issue and the corresponding circumstances of collecting such information.
We collect your personal information only with your consent or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.
We may also have legal obligations to collect your information or may otherwise need your information to protect your vital interests or those of another person.<br>
</p>
<p>If we ask you to provide personal information to comply with a legal requirement, we will specify the legal requirement and the information we require.
If we collect and use your information in reliance on our legitimate interests (or those of any third party), our legitimate interests will generally involve operating and improving this Site, communicating with you, marketing purposes, or detecting or preventing fraud.
For more information about GDPR, please visit the EU’s “Data protection and online privacy” page.
If you have questions about our compliance with GDPR, please contact us as outlined in Section 7 (Contact Information) above.<br>
</p>International Data Transfers<p>If you reside in the European Union, your personal information may be processed outside of EEA.
We take all necessary steps to ensure that your information is adequately protected and processed in accordance with this Policy, using the European Commission’s Standard Contractual Clauses – European Commission-approved contracts that offer personal information the same protection as under European law.<br>
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