TRANCOS PRIVACY POLICY

Last Modified: February 19, 2020

INTRODUCTION:

Welcome to the Trancos Privacy Policy ("Privacy Policy"). By visiting our Privacy Policy, you've taken the first step in educating yourself about advertising businesses such as ours that contribute to the Internet's ability to remain largely an ecosystem of free content, as well as to provide a better user experience for consumers.

At Trancos, Inc., or any of its subsidiaries, including Freeflys, CoregMedia, Adfish, Trancos affiliate networks ("Trancos," "we," "us," or "our"), we provide online advertising services. To do this, we follow information usage practices based on two beliefs: first, that protecting user privacy is essential to the growth and prosperity of the Internet; second, that a personalized web experience can provide significant benefits to Internet end users if done properly. In accordance with these beliefs, Trancos creates results for advertisers and publishers in revolutionary ways without compromising individual privacy.

 

If you have questions or concerns regarding this statement, please contact us by emailing: info@trancos.com

By visiting any Trancos website or mobile application, or any website or mobile application of one of its subsidiaries or affiliates (collectively, "Site" or "Sites") or sharing any information with us, you agree to be bound by this Privacy Policy.

Please take some time to read about what our business does, learn how we ensure that data you share with us is collected and used safely, and visit resources that provide more depth on our industry.

SHORT FORM PRIVACY POLICY

We have included a table summarizing our practices solely for your convenience and reference purposes. This table is not an exhaustive description of our privacy practices and should not be construed to define, limit, and/or describe the scope or extent of this Privacy Policy. As a result, we urge you to read the entire Privacy Policy. This table may not align with the definitions and privacy rights under California law, so if you are a California resident, then please scroll down to "CALIFORNIA PRIVACY RIGHTS".

To start, it is important for you to know two definitions that are key to understanding our programs and privacy practices:

Personally Identifiable Information ("PII"): Information that can be linked to an identifiable individual person. This type of data includes things like full name, home address, telephone number, or email address.

Non-Personally Identifiable Information ("Non-PII"): Information that cannot identify an individual person, such as IP address, browser types, operating systems, domain names, access dates and times, referring website addresses, online transactions and browsing and search activity.

 
Information Collection: PIIWe do not collect PII except as expressly provided for herein. For example, PII may be collected should a consumer contact Trancos on his/her own initiative, register with a publisher to download a mobile app, or as part of our lead generation business.
Information Collection: Non-PIIThe Non-PII we collect may include, as an example, IP address, browser types, operating systems, domain names, platform type, language preference, access dates and times, referring website addresses, online transactions and browsing and search activity.
How Information is UsedWe may use your Non-PII for purposes such as enhancement of our services, marketing, and to more effectively match advertisements, applications, and website content to your interests.
Sharing Your InformationWe may share your information with third party service providers with whom we have contracted, our subsidiaries and affiliates, third party marketing partners, business partners and our clients and publishers, and as expressly provided for herein.
Your ChoicesYou may regulate the collection and use of Non-PII via the opt-out options provided herein or by uninstalling or electing not to install a web browser or mobile application.
SecurityWe use reasonable and appropriate security measures to protect your data.
RetentionWe retain online Non-PII for IBA for no more than eighteen (18) months. Aggregate reports generated from such data may be retained for a longer period, as ad delivery and reporting data.
ChangesWe may change this Privacy Policy at any time by posting the revised Privacy Policy on the Site along with the date such Privacy Policy was last updated.
Contact UsIf you have any questions about this Privacy Policy, or the practices discussed herein, please contact us by emailing: info@trancos.com

SCOPE

This Privacy Policy is primarily intended to provide a description of the ways in which we collect and use information to deliver advertising across the Internet. For more on how we handle information collected from clients and publishers or visitors to our Sites, please see "Use of the Trancos Sites as a Visitor or Client" below. For more information on your privacy rights as a California resident, please scroll down to "CALIFORNIA PRIVACY RIGHTS".

This Site is not intended for use by those who are not legal residents of the United States. Neither the Sites, nor our online activities or services for our clients, are directed toward or intended for children. We do not collect PII from any person of whom we have actual knowledge is under the age of 13. By using our website, the website of any of our publishers in our networks or submitting information to us, you consent to our use and sharing of the information collected or submitted as described in this Privacy Policy.

Please be aware that in addition to our Sites, the websites of our clients and publishers, applications on which we place advertisements and any third party websites linked to one of our Sites, may also collect information from you for various purposes, including, but not limited to, providing advertisements about goods and services likely to be of greater interest to you. Such information collected by such websites and mobile applications and their affiliated or third party partners may include Non-PII through the use of cookies and other technologies. It may also include any PII you choose to provide in registering and transacting with such websites and mobile applications. Although we choose our business partners and clients carefully, Trancos is not responsible for the privacy practices of websites and mobile applications operated by such third parties. You should check the applicable privacy policies of such websites and mobile applications you visit to determine how they handle any information they collect from you.

WHAT TRANCOS DOES

While you may only visit certain websites and mobile applications, there are other companies working behind the scenes to help provide you with a great digital experience. These third party companies provide vital services such as analytics, advertising and fraud prevention for retailers, publishers, and other organizations. These services enable these third party companies to, among other things, provide the advertising that keeps your favorite blogs free, your favorite stores in business, and your advertising experience more relevant.

We help companies provide digital advertising on browsers, mobile applications and televisions, and we do it in a variety of ways, from banner and video ads to coupon codes. To make some of these things possible, we need to utilize information to provide smarter decision making. Technologies such as cookies and mobile device IDs enable companies like ours to provide more relevant advertising while keeping your identity anonymous to Trancos.

PRIVACY BY DESIGN

Our philosophy on privacy follows the framework of Privacy by Design. We integrate privacy in strategy, product development, and more. We set the tone for privacy protection early and often, proactively working to keep PII out of Trancos's systems, and building technologies that are effective without the use of PII. We can protect consumer privacy AND provide relevant advertising, which benefits everyone involved, especially advertisers, consumers, and small business websites and mobile applications. Ensuring the protection of privacy throughout the entire lifecycle of the data is of the utmost importance, and we are careful to protect privacy as data is collected, used, and destroyed responsibly.

We constantly strive to maintain unparalleled visibility with consumers. We provide transparency and choice through our website, encourage the same practice throughout the Internet tailored to consumers' interests.

Trancos has developed a strong privacy foundation and has a company culture aimed at the prevention of the receipt and use of PII. We respect consumer privacy and give consumers the ability to opt out of interest-based advertising ("IBA").

INFORMATION COLLECTION AND USE

Information Collected by Trancos

Trancos only collects Non-PII from you (unless PII is provided by you voluntarily), and may collect this in a variety of ways. We may use technologies such as cookies, log files, pixel tags or other similar technologies to collect Non-PII about the browser or device you are using, including browsing activity, online transactions, and IP addresses. We may also receive similar Non-PII from third parties, which may additionally include the types of programming you view on your television. Some clients contribute PII such as your name, address, email address, and associated transactional information directly to a third party with whom Trancos has a contractual relationship. This third party removes the PII data points and provides Trancos only the Non-PII for our use in providing advertising to you. All Non-PII received and collected by Trancos from the various sources may be combined and used to provide you relevant advertising, and for other purposes as determined by Trancos.

We may also conduct surveys by serving interactive ads that ask you to provide information such as your gender and age range, which information may be associated with a device ID or a cookie ID. If you decide to respond, your demographic information will also be associated with a device ID or cookie ID and used only for the purposes described in this Privacy Policy.

"Cookies" are files that are stored on your web-enabled device and are used to improve your experience when seeing web and mobile advertisements. We may use cookies to estimate the total reach of an advertising campaign, as well as frequency of display, and to serve advertisements which are relevant to you. This allows advertisers to determine with greater accuracy the composition of the audience they reach and attempt to reach an audience that is interested in their products or services. There are many misconceptions about cookies. Cookies cannot erase your hard drive, install programs, or collect PII from your browser or device.

"Local Storage Data" are similar to cookies in that they allow data to be persisted in your browser when you visit a website. Local storage data are used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information. Information set in local storage data are only accessible from the same website domain that set the local storage data, and can only be set or accessed using JavaScript on pages from that same website. Local storage data have many of the same restrictions as cookies - if you delete cookies or your internet cache, local storage data are also deleted. Similarly, if you block cookies then local storage data are also blocked. Since local storage data are so similar to cookies and we treat local storage data with the same privacy and data protection principles as cookies, when we use the term "cookies" on this page or any other material on our website or elsewhere, we are including both cookies and local storage data.

"Device IDs" are unique identifiers associated with your mobile device to be used for advertising. These identifiers are assigned by your mobile device operating system, such as Apple's iOS and Google's Play Services for Android, and do not reveal your identity. Device IDs can be reset in your mobile device settings.

"Log files" track actions occurring on Sites and collect data including, as an example, your IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamp, click data and types of advertisements viewed.

"Web beacons" are objects that are embedded in a web page or e-mail and are usually invisible to the user but are used to track a web user's navigation of a website or collection of websites or pages, interaction with an e-mail, use of mobile applications, the completion of transactions, submittal of applications and browsing behavior.

"Location Data" recognizes a consumer's location while they are on their device which is utilized by Trancos to deliver advertisements. As with all data Trancos collects, this is limited to non-precise as defined by the Network Advertising Initiative's current definition of imprecise location data unless the consumer has opted in to allow their precise location to be used for IBA.

The Non-PII collected is used for marketing purposes, enables us to determine which advertisements perform well, allows us to more effectively match ads, mobile application and website content to your interests, assists us in improving the operation of our services, helps us to maintain the quality of our services, enhances our services to our business partners and clients and enables us to provide general statistics to our business partners and clients regarding use of Trancos's services. Trancos may also act as a delivery agent when its products and services are used directly by a client to facilitate advertisements and other communications.

Trancos supports the NAI Code of Conduct's obligations around the collection and use of health information for interest-based advertising. This health-related information, when collected and/or used for relevant advertising, is non-sensitive and consumers may exercise choice through an opt-out basis. The NAI also permits Trancos to collect and use sensitive health information when the user provides explicit opt-in consent in the United States.

When a consumer responds to or views an Internet advertisement served by Trancos (such as through third-party websites or email solicitations) or visits a Trancos site, we may assign an anonymous, unique identifier to the end user's Internet browser or device, often via a cookie. One function of these technologies is to provide Trancos with information for the purpose of paying third-parties affiliate commissions when an Internet user clicks on a link, creates a lead, or makes a purchase on an advertiser's website. If the Internet user re-visits the advertiser's site directly, Trancos is able to continue to track the user's activities (excluding PII) on the advertiser's site and credit the third-party website that referred the user. In other words, if a user reads a blog about a pair of shoes and decides to visit that advertiser's website and purchase that pair of shoes, we would ensure that the blog gets compensated for referring the user to that advertiser's website.

We also may use Internet browsing, cross-mobile application browsing and online purchase data associated with a user, on a Non-PII level, across multiple devices to develop a predictive statistical user profile of the end user's needs and interests for the purpose of sending them relevant advertisements on multiple browsers and devices. This is called cross-device IBA. We may also use this cross-device functionality for the purpose of more accurately paying third-parties affiliate commissions, as described in the paragraph directly above.

To opt out of Trancos IBA, please follow the opt-out instructions below in the "Your Choices" and "Mobile Device Choices" sections of our Privacy Policy. Upon opt-out, we will no longer collect behavioral data on your browser and will also no longer send behavioral data to other browsers or devices associated with you. However, data that was collected on your browser or device prior to you opting out may still impact the advertisements you see on other browsers and devices associated with you. We will attempt to opt you out across all of your browsers and devices. However, since we don't collect data which directly identifies you, we cannot guarantee that all of your browsers and devices will be opted out. To ensure you are opted out across all of your browsers and devices, we recommend that you opt out of each one individually. If you delete your cookies, we recommend that you renew your opt out choices. If cookies aren't enabled in your browser or if you're using ad-blocking tools, our opt-out mechanism may not work. Please note that opting out does not necessarily mean that you will no longer receive any advertising from Trancos, it means that you will no longer receive advertising tailored to your interests.

Information Sharing by Trancos

Trancos will only share your information for limited purposes such as those provided in this Privacy Policy. This may include sharing information (1) to enable third party service providers to assist or facilitate in the services we provide to our clients; (2) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information received by us, whether or not a response is required by applicable law; (3) to enforce our terms of use and other agreements or to protect our rights ; (4) to protect the safety of members of the public and users of the service; (5) with Trancos affiliates and clients for marketing purposes; (6) with vendors, administrative service providers, technology providers, and carefully selected partners for services including, but not limited to, data validation, enhancement, information verification and suppression services; or (7) for any other purpose for which you provide consent. None of this information will include PII except as provided herein. While Trancos strongly encourages clients and partners to adopt responsible approaches to online marketing, Trancos is not responsible for the information practices of such clients and partners. With respect to IBA, Trancos and other third parties may use Non-PII collected or shared with respect to your visits to websites with whom we have relationships for various purposes, including, but not limited to, providing advertisements about goods and services likely to be of greater interest to you.

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

Service-specific Provisions for Information Collection and Use:

Some products and services offered by Trancos have privacy considerations unique to those offerings. These considerations are covered here:

Lead Generation:

Trancos provides lead generation services to clients where we work with website publishers who utilize their display, search and email distribution channels to generate consumer interest or inquiry into advertiser products and services. The co-registration component refers to the process in which Trancos facilitates the exchange of consumer information (typically PII held by website publisher in accordance with their Privacy Policy) from website publishers to advertisers.

We may receive PII that our clients have collected in connection with our services for our clients or that clients have collected for access or transmittal purposes to other clients. We may hold such information and/or transmit or allow access to such information to the intended recipients or categories of recipients as requested by our clients.

As part of the Lead Gen services, online forms hosted by us, our clients, or third parties acting on the behalf of us or our clients may collect PII that a consumer has voluntarily provided. This information may be used for the same purposes listed in "Information Sharing by Trancos," above. This information may also be used to verify any information submitted to use or any of our clients, and for any suppression or opt-out purposes.

Trancos may serve advertisements to you based, in part, on the demographic and geographic information you submitted to our clients during the website registration process, and lifestyle information about you that we obtain from them and other Trancos entities and third parties.

Security

The security of your information is important to us. We have implemented appropriate security measures to protect the information in our care, both during transmission and once we receive it. We take physical and technical security measures to protect our data from unauthorized access, as well as unauthorized disclosure or destruction of data.

No transmission of data over the Internet is guaranteed to be completely secure. While we strive to protect your data, it may be possible for third parties not under the control of Trancos to unlawfully intercept or access transmissions or private communications. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. Trancos cannot ensure or warrant the security of information you transmit to us. You acknowledge and assume this risk when communicating with Trancos.

Retention

We retain online Non-PII for IBA for no more than eighteen (18) months. Aggregate reports generated from such data may be retained for a longer period, as ad delivery and reporting data.

SELF-REGULATION & VOLUNTARY COMPLIANCE

Our industry has a rigorous voluntary self-regulatory regime, and we support members of industry groups such as the Network Advertising Initiative (NAI), Interactive Advertising Bureau (IAB), Digital Advertising Alliance (DAA) and Digital Advertising Alliance of Canada (DAAC) who promulgate codes of conduct to which their members must adhere. These codes impose requirements on participating companies such as transparency and choice around the use of data for IBA, and require regular audits of member privacy practices.

Trancos supports these and other groups, and where Trancos engages in activities regulated by these programs, we comply with the NAI Codes of Conduct. We also support the DAA Self-Regulatory Principles and the DAAC Self-Regulatory Principles.

YOUR CHOICES

We hope that after reading through this Privacy Policy that you feel comfortable we are collecting and using data responsibly, and that the cumulative benefits of our work are valuable to the Internet as a whole and your individual browsing experience. As part of our commitment to consumer privacy, we give consumers the ability to opt out of IBA provided by Trancos. If you would like to opt out of IBA from Trancos, please email: info@ trancos.com to opt out.

We will attempt to opt you out across all of your browsers and devices. However, since we don't collect data which directly identifies you, we cannot guarantee that all of your browsers and devices will be opted out. To ensure you are opted out across all of your browsers and devices, we recommend that you opt out of each one individually. If cookies aren't enabled in your browser or if you're using ad-blocking tools, our opt-out mechanism may not work.

Please note that opting out does not necessarily mean that you will no longer receive any advertising from Trancos, it means that you will no longer receive advertising tailored to your interests.

Trancos may place ads on websites that are part of the Google Display Network. Based on your visits to these websites, Google uses an advertising cookie (from DoubleClick) to associate your browser with interest and demographic categories. Google then uses these categories for IBA on these websites. To learn more about this and your choices from Google, please click here.

Mobile Device Choices

For mobile websites, you can follow the opt-out instructions provided above. To learn how to opt out receiving relevant advertisements on mobile applications, please visit this page: http://www.networkadvertising.org/mobile-choices.

USE OF THE TRANCOS SITES AS A VISITOR OR CLIENT

You can browse the Trancos Sites without providing any PII. You may choose to provide PII to us voluntarily if you interact with our Site in certain ways, such as applying for employment with Trancos, responding to an advertisement for Trancos, or using one of our contact forms. This information is used only for the reasons it was collected, such as responding to your communication, and is not shared with third parties other than to fulfill the purpose for which it was collected.

Trancos may also collect Non-PII, through the use of technologies such as cookies, including IP address, browser type, operating system, domain name, language preference, access dates and times, referring website addresses, online transactions and browsing and search activity. We may use this Non-PII for purposes including enhancement of our services, marketing, IBA, and to more effectively match website content to your interests. We may share your information with our third party service providers, Trancos and its subsidiaries and affiliates, third party marketing partners, our clients and publishers, and as expressly provided for herein.

We also use cookies to simplify login and to facilitate secure navigation through the password protected areas of the Site. Visitors who choose to reject all cookies may have difficulty navigating the password protected areas of the Site depending on the nature of their connection (dynamic IP, proxy server, etc.).

We may also partner with third parties who collect information on our Sites, and we may maintain links to other websites on our Sites. This Privacy Policy does not apply to the privacy practices of other websites or of third parties who collect information on our Sites. We would encourage you to visit the applicable policies of those third parties, or visit www.AboutAds.info to learn more about interest-based advertising and to see your opt-out choices from other participating companies that may be collecting and using data on Trancos's websites.

For Clients and Publishers

The Trancos network includes our clients and publishers involved in advertising campaign transactions. Information collected from clients and publishers includes PII that is necessary to conduct business, such as name, phone number, and email address. Payments made to and from Trancos require the collection of PII that may include credit card numbers and bank account information. Phone numbers may be used for sales or inventory acquisition purposes. This information is collected, modified and stored in a password protected environment and is used for purposes including service, media delivery, contact, billing and accounts payable. We will not sell or rent this information to non-Trancos entities. All client and publisher information collected for these purposes is explicit, voluntary, manually entered, and can be opted-out.

Security:

See "Security" under Information Collection and Use, above.

Information Sharing:

This client and publisher information is not shared with any third party outside Trancos and its affiliated companies, except for that necessary to conduct business, such as clearing a credit card transaction for an advertising campaign purchase or making an ACH direct deposit to pay a publisher, or as required by law. The security of this information is crucial to our success in the highly competitive field of online advertising. Trancos may, from time to time, use "gallery" pages to identify clients or publishers by business identity ONLY (e.g. freeflys.com is a new Publisher in the Trancos Network).

Log Files:

We record the IP address of new clients and publishers at sign-up. This can assist in administering the Site and client or publisher accounts, including features designed to enhance the Client experience. This information is part of the secure member database and is password protected.

Our Communications:

We send all new clients and publishers a welcoming email to verify password and user name, and may communicate with you about program or other information at the contact information you provide. We me also email individuals that have provided us with their contact info so that we can communicate information about Trancos's services. You can request to opt out of these emails by emailing: info@trancos.com

Site and Service Updates:

We may send Site and service announcement updates by email. Because these announcements contain important information about services, it is not possible to unsubscribe. We also communicate with clients and publishers to provide requested services and in regards to issues relating to their account via email or phone.

Correction/Updating PII:

If a client's or publisher's PII changes (such as email address) or they would like PII removed from our system, we provide several ways to correct or update PII. The following options are provided:

Make the changes online by entering the member area.

Contact your account manager.

All requests to remove a client or publisher from our system will be verified prior to removal to ensure the proper identity of the requester.

CONTACT US

Have a question on something not addressed or have a complaint? Please use email: info@trancos.com

YOUR REPRESENTATIONS

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND APPLICABLE SITE TERMS AND CONDITIONS. You also agree that you have provided notice to, and obtained consent from, any third party individuals whose information you supply to us with regard to: (a) the purposes for which such third party's information has been collected; (b) the intended recipients or categories of recipients of the third party's information; (c) which of the third party's data are obligatory and which data, if any, are voluntary; and (d) how the third party can access and, if necessary, rectify the data held about them. It is the express wish of the parties that the Privacy Policy and all related documents have been drawn up in the English language and that the English version of this Privacy Policy shall be the sole version used in interpreting and enforcing this Privacy Policy.

YOU AGREE THAT OUR LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY US TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY OUR TERMS AND CONDITIONS.

CALIFORNIA PRIVACY RIGHTS

NOTICE TO CALIFORNIA RESIDENTS - CALIFORNIA CONSUMER PRIVACY ACT

The California Consumer Privacy Act of 2018 ("CCPA") provides certain rights to residents of California. This section of the Privacy Policy applies if you are a natural person who is a resident of California ("California Consumer") and uses our Services. This Addendum supplements the information in our Privacy Policy. However, this Addendum is intended solely for, and is applicable only as to, California Consumers: if you are not a California Consumer (or a resident of California), this does not apply to you and you should not rely on it.

Under the CCPA, "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household. Please note that Personal Information is different from the term Personally Idenfitied Information ("PII") mentioned in our Privacy Policy.

In the below tables and sections, we describe (as required by the CCPA):

  1. Our Collection of Personal Information - the types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from,
  2. Our Disclosure and Sale of Personal Information - the types of recipients to whom we disclose or sell Personal Information.
  3. Our Business Purposes - our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.
  4. Your California Privacy Rights and Choices - what rights you have under the CCPA, for instance, to request that we "opt out" your information from our marketing database (also called "do not sell" rights), or to request categories and personal information that we may have collected about you.

The following sets forth the categories of information we collect and purposes for which we may use California Consumers' personal information:

1. OUR COLLECTION OF PERSONAL INFORMATION

Depending on how you interact with us, we may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.
CategoryCategories of Sources
Identifiers, e.g., obfuscated name, obfuscated address, obfuscated email address, obfuscated phone number, online identifiers, and IP address.
  • From advertising networks, advertisers, publishers, internet service providers, data analytics providers and data compilers, operating systems, government sources such as publicly available home addresses, and consumer surveys.
Categories of personal information described in Cal. Civ. Code ยง 1798.80(e). e.g., estimated household income
  • From data analytics providers and data compilers
Characteristics of protected classifications under California or US law
E.g., race; sex/gender; marital status; medical condition; and age.
  • From advertisers, data analytics and data compilers, and consumer surveys
Commercial or transactions information
E.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
  • From advertising networks, advertisers, publishers, internet service providers, and data analytics providers and data compilers, and consumer surveys
Internet or other electronic network activity information
E.g., browsing history; search history; online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer's interaction with a website, application, or advertisement.
  • From advertising networks, advertisers, publishers, internet service providers, and data analytics providers and data compilers, and consumer surveys
Geolocation data
  • From advertising networks, advertisers, publishers, internet service providers, and data analytics providers and data compilers, and consumer surveys
Professional or employment-related information
E.g., current or past job history
  • From data analytics providers and data compilers and consumer surveys

2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION

We will share the information collected from and about you as discussed above for various business purposes, with service providers and with third parties including our customers. The chart below how and with whom we share or disclose personal information, and whether (based on the CCPA's definition of "sell") we believe we have "sold" a particular category of information in the prior 12 months.
CategoryCategories of Third PartiesWe Share With Whether We "Sold" This Category of Personal Information in the Last 12 Months
Identifiers, e.g., obfuscated name, obfuscated address, obfuscated email address, obfuscated phone number, online identifiers, and IP address.Advertising networks, advertisers, and publishersAdvertising networks, advertisers, and publishers
Characteristics of protected classifications under California or US law
E.g., race; sex/gender; marital status; medical condition; and age.
AdvertisersAdvertisers
Commercial or transactions information. E.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendenciesAdvertisers and publishersAdvertisers
Internet or other electronic network activity information. E.g., browsing history; search history; online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer's interaction with a website, application, or advertisement.Advertisers and publishersAdvertisers
Geolocation dataAdvertising networks, advertisers, and publishersAdvertisers
Professional or employment-related information
E.g., current or past job history
AdvertisersAdvertisers

We also may share any of the personal information we collect as follows:

Sharing for Legal Purposes: In addition, we may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.

Sharing In Event of a Corporate Transaction: We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.

Sharing With Service Providers: We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device ("Aggregate/De-Identified Information"). We may use ("Aggregate/De-Identified Information") for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

3. OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION

Generally speaking, we collect and share the Personal Information that we collect for the following purposes, as we also have described in our Privacy Policy, in the section titled "Personal Information That We Collect and Use":

Our Purposes for collecting, using and sharing Personal Information

Online targeting, for example:

Additional marketing and analytics services, for example (which may overlap with "Online targeting," above):

Operating our Services, for example:

Other internal purposes, for example:

For internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance. We use the information collected from our own website for the above, as well as for our own marketing purposes.

4. YOUR CALIFORNIA RIGHTS AND CHOICES

Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests, to the extent as act as a "business" (as opposed to a "service provider") for purposes of handling personal information. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.)

a. Right to Opt-out of the sale of your personal information.

California residents may opt out of the "sale" of their personal information. California law broadly defines what constitutes a "sale" - including in the definition making available a wide variety of information in exchange for "valuable consideration." We may act as a "business" or a "service provider" under the CCPA. When we act as a business under the CCPA, you may "opt out" of our "sale" of your personal information (as those terms are defined by the CCPA) by emailing: info@trancos.com. Please note that this is not an opt out of interest-based advertising. To opt out of interest-based advertising, please visit the Network Advertising Initiative.

b. Right to request deletion of your personal information

You may also request that we delete any personal information that we collected from you, including data provided to us by our clients. (Note that this is different from your right to "opt out" of us selling your personal information, which is described above; also note that we do not generally collect personal information directly from consumers, in which case "deletion" rights generally do not apply.) However, we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations, and (f) as necessary to comply with client contracts, including allowing advertisers to properly compensate publishers for driving traffic to their web properties. California residents can delete your personal information by emailing: info@trancos.com or by contacting us at 916.234.6110.

c. Right to request access to your personal information

California residents also have the right to request that we disclose what categories of your personal information we collect, use, or sell. As a California resident, you may request access to the specific pieces of personal information that we have collected from you. California residents can access their personal information by emailing: info@trancos.com or by contacting us at 916.234.6110.

However, we may withhold some personal information where the risk to you or our business is too great to disclose the information, or where we cannot verify your identity in relation to such personal information. Thus, for security purposes (and as required under California law), we will verify your identity - in part by requesting certain information from you -- when you request to exercise certain of your California privacy rights.

In addition, please read our privacy policy to learn more about:

If we are unable to complete your requests, we will provide you additional information about the reasons that we could not comply with your request.

d. Right to nondiscrimination.

We do not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.

e. Information About Persons Under 16 Years of Age

We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).

f. Authorized Agents

You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.

MODIFICATIONS TO THIS PRIVACY POLICY

We may occasionally make changes to this Privacy Policy. If we do, we will update the "Last Modified" date above. If we make a material change, such as the ways in which we use PII, we will notify you via a prominent notice on our Site.