The Trade Desk

Website Privacy Policy

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Last updated: March 29, 2021 WHAT THIS POLICY COVERS INFORMATION WE COLLECT HOW WE USE YOUR INFORMATION HOW WE SHARE INFORMATION COOKIES ON OUR WEBSITES YOUR CHOICES YOUR RIGHTS INTERNATIONAL TRANSFERS SECURITY AND RETENTION CHANGES TO THIS POLICY CONTACT US WHAT THIS POLICY COVERS This privacy policy covers data that the Trade Desk collects, uses and discloses from our owned and operated corporate websites, client-facing portals and by other means, including through your contact with us (“Websites”). It also describes the choices available to you regarding our use of your personally identifiable information (“PII”) and how you can access and update this information. This policy does not cover data that is collected, used or disclosed through the Trade Desk’s advertising technology platform and systems (the “Platform”). For more information on privacy as it relates to the Platform, please see The Trade Desk Platform Privacy Policy. Additionally, this policy does not apply to the privacy practices of other websites that are linked to from our Websites. The Trade Desk is not responsible for the privacy practices of these other websites. We encourage you to read the privacy policies of those websites to understand their data privacy practices. The Trade Desk is a member of the Network Advertising Initiative (NAI) and adheres to the NAI’s 2020 Code of Conduct. The Trade Desk also follows the industry self-regulatory guidelines of the Digital Advertising Alliance, the Digital Advertising Alliance of Canada, and the European Digital Advertising Alliance. The Trade Desk also implements and adheres to the policies of the IAB EU Transparency &amp. Consent Framework as part of our compliance with EU data protection law. See http://advertisingconsent.eu for more information. INFORMATION WE COLLECT PII We Collect From Our Websites We may collect PII such as your name, email address and phone number when you interact with us in the manners described below. PII is distinguished from “pseudonymous” data we collect about your browser or device (as described below) in that PII links to, or is, data which can directly identify you as an individual, client or prospective client. PII we collect may be voluntarily provided, for example when you request more information through a form on the Websites or apply for employment. The PII that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your PII. Pseudonymous Data We may automatically collect pseudonymous data, distinguished from the PII described above, that does not directly identify you personally but is linked to your computer or device. We collect this data from you in the normal course of operating our Websites. When you visit our Websites, we and/or our third-party partners automatically collect information about your computer that your browser sends, such as IP address, browser type and language, access times, pages visited, and referring website addresses. We may also collect information about your mobile device such as the type and model, operating system, carrier name, mobile browser, applications using our Websites, and identifiers assigned to your device, such as IDFA and AAID. We may also collect your location information, such as your zip code or the approximate geographic area derived from your IP address or location positioning information provided by the location services and GPS features of your mobile device when location services have been enabled. Pseudonymous data may contain cookie data. To understand more about how cookies are used on our Websites, see the COOKIES ON OUR WEBSITES section below. HOW WE USE YOUR INFORMATION Any PII you provide to or through the Websites shall be used for the purposes for which you provided it that were disclosed at the time it was collected, including the following: <ul> <li>We respond to inquiries initiated by individuals and provide requested information regarding our products and services </li> <li>We send you marketing communications related to our products, such as our newsletter, if you are a client or have chosen to receive it </li> <li>We create a unique identifier and associate it with other pseudonymous identifiers for marketing, operational and business purposes, such as recommend our features, products, and services that might be of interest to you, identify your preferences, and personalize your experience with The Trade Desk </li> <li>We may use data that is not directly identifying to find other users who may have an interest in our products and services</li> <li>We alert you to changes and provide updates on specific features, products and services that you may be receiving from us</li> </ul> If you no longer wish to receive marketing email communications or wish to opt out, you can follow the unsubscribe instructions contained in the emails you receive or by contacting us at privacy@thetradedesk.com. HOW WE SHARE INFORMATION We will share your information with third parties only in the ways that are described in this policy. In addition, we do not, and will not, sell your information collected through our Websites to any third party. We may disclose your information to companies that provide data processing services to help us with our business activities, such as sending email communications on our behalf. These companies are authorized to use your information only as necessary to provide these services to us. We will also disclose your information: <ul> <li>As required by law, such as to comply with a subpoena, or similar legal process,</li> <li>When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request,</li> <li>If the Trade Desk is involved in a merger, acquisition, or sale of all or a portion of its assets, in such case you will be notified via email and/or a prominent notice on our Websites of any change in ownership or uses of your information, as well as any choices you have regarding your information, or</li> <li>any other third party with your prior consent to do so.</li> </ul> COOKIES ON OUR WEBSITES “Cookies” are data files that are stored on your browser or device and are used to remember user preferences and behaviors over time. Cookies allow us to recognize your device and remember information, such as your preferred language and other general settings. Cookies set by the website owner (in this case, the Trade Desk) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Our Websites use both first party and third-party cookies. For more information about specific cookies on this site, please see here. First Party Cookies First party cookies on our Websites are used for a variety of reasons, including purposes which may be strictly necessary for our Websites to function properly. Because these cookies are strictly necessary to deliver our Websites, we do not seek consent for such uses. Third Party Cookies Our Websites may contain content, pixels or cookie syncs from third parties, as outlined below. Note also that, in jurisdictions where consent is required for the placement of cookies, the appearance of any third parties on our Websites is subject to these consents being obtained by or on behalf of these third parties through, for example, the IAB’s Transparency and Consent Framework. We do not control these third parties, and you should refer to the privacy statements of our partners and service providers listed below to find out how they use cookies on our Websites and any data derived from such cookies. Our Websites may contain content or pixels from service providers providing certain services on our behalf, as well as content, pixels or cookie syncs from other ad tech partners, including the Trade Desk and our pixels. These third parties may collect data about your web viewing behavior on our Websites and combine this data with information collected from other websites over time for purposes that include targeted advertising. Most advertising networks offer you a way to opt-out of targeted advertising. If you would like more information, please refer to the YOUR CHOICES section below. You can remove or manage cookies by following directions provided in your browser or device’s “help” or “preferences” areas. Note: if you reject cookies, you may still use our Websites, but some functionalities and areas of our Websites may be limited. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information. You may also seek additional information here. Other Technologies Our third-party partners or service providers may employ other tracking technologies like clear gifs (sometimes called “web Beacons” or “tracking pixels”), that are pieces of code that can be embedded on websites and can be used to learn how you interact with that website. Clear gifs help us better manage content on our Websites by informing us what content is effective. We also use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functionality. Social Media Our Websites may include social media features, such as the Facebook “like” button. These features may allow the social media provider, like Facebook, to collect certain information, such as your IP address, cookies and page you are visiting. Your interactions with these features and data collection enabled by such social media features are governed by the privacy policy of the social media provider offering them. Please note that links to social media platforms or content from our Website does not mean that we endorse the linked social media platform and/or content. YOUR CHOICES Industry opt-out pages. The online advertising industry provides websites from which you may opt out of interest-based advertising from the Trade Desk and other companies that participate in self-regulatory programs. The US-based opt out pages are www.aboutads.info/choices and www.networkadvertising.org/choices. The European based page is www.youronlinechoices.com. In Canada, use youradchoices.ca/choices. For mobile apps. You can opt out of the Trade Desk using information about your usage of mobile apps that are targeted to your interests by using your device settings, for most devices. We are not able to directly access the Mobile App Opt Out on devices that offer it. To learn how to use the mobile app opt out, consult your device instructions. To find information on Opting out on Mobile Devices please visit http://www.networkadvertising.org/mobile-choice. The Trade Desk’s Data Control Page. You are able to opt out of having new data associated with your device and to request that we disassociate from your device data we already have. You can directly access The Trade Desk’s opt out, which will cease data collection and disassociate data from your device, by visiting http://www.adsrvr.org . Cookies For more information about opting out of cookies on our Websites or otherwise blocking or deleting cookies, please refer to COOKIES ON OUR WEBSITES. Adherence to Do Not Track Signals (“DNT”) DNT is a privacy preference that you may set in certain browsers or may be preset in certain instances. Please note that the Trade Desk does not currently honor DNT signals sent by browsers or otherwise included through third party intermediaries. YOUR RIGHTS You have the right to request access to or deletion of the information we have collected about you through our Websites. If you’d like to access, update, correct, or request deletion of your information that you have provided to us on our Websites or elsewhere, please send your request to us at dsr@thetradedesk.com. We may take reasonable steps to confirm your identity. You will not be discriminated against for the exercise of such rights (for example, we will not provide you with a different level or quality of goods or services). INTERNATIONAL TRANSFERS The Trade Desk operates its Websites from servers located in the United States. Laws governing the collection and use of data in the United States may not be equivalent to those in the country where you reside. We transfer data from the EU or Switzerland to the US under a valid legal framework. If there is any conflict between the terms in this policy and such mechanism, the terms of the transfer mechanism shall govern. We commit to resolve complaints about our collection or use of your personal data and are subject to enforcement by the US Federal Trade Commission. EU and Swiss individuals with inquiries or complaints regarding our privacy policy should first contact us at privacy ((at)) thetradedesk ((dot)) com or at the address listed in the “Contact Us” section of this policy. If you have unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S. based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request on Privacy Shield: On July 16, 2020, the European Court of Justice issued a judgement declaring Privacy Shield invalid. We now rely on other transfer mechanisms for the cross-border transfer of data. However, The Trade Desk continues to live up to its obligations under the program. Under certain conditions specified by the Privacy Shield Principles, you may also be able to invoke binding arbitration to resolve your complaint. Please click here for more information or to submit a complaint. SECURITY AND RETENTION We retain the PII you provide to us for as long as your account is active or as needed to provide you services or perform the purposes for which it was supplied. We will retain and use your PII as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We retain the pseudonymous data collected on our Websites for up to 18 months. After 18 months (or sooner) the data is de-identified or aggregated and stored for up to 3 additional years. We have implemented commercially reasonable security measures, including physical, electronic and administrative safeguards, to prevent the unauthorized access to, loss, misuse, or alteration of the information collected through our Websites. We believe these measures are appropriate given the nature of our data and our systems, but we make no assurances in this policy about our ability to prevent any such event or the possible harm to you or any third party that could arise from it. CHANGES TO THIS POLICY We may revise this policy at any time. However, if we make material changes, we will not apply them retroactively. CONTACT US You may contact us regarding privacy. Email: privacy ((at)) thetradedesk ((dot)) com Global Data Protection Officer (DPO) The Trade Desk, Global Privacy Office 42 N. Chestnut St., Ventura, CA 93001 Email: dpo ((at)) thetradedesk ((dot)) com If you have a concern regarding our privacy practices, please contact us via the contacts above. If after reasonable efforts, you believe your concern has not been satisfactorily addressed by us: <ul> <li>In the US, our privacy practices are regulated by the Federal Trade Commission.</li> <li>Otherwise, in the EU, we recommend you contact the Information Commissioner’s Office (ICO) of the United Kingdom.</li> </ul>