SERVICE PRIVACY POLICY

Updated 21 April 2020

This policy applies to the information Placements, Inc. (“Placements.io”, “we”, “us”, “our”) collects and receives from individuals (“Users” or “you”) who access and interact with the Placements Service (defined below) https://app.placements.io. Placements.io is committed to transparency, and we want you to fully understand how we may collect, use, and share information relating to Users, and the choices that are available to you.

This privacy policy does not govern (i) the collection and use of information about visitors to our website (https://placements.io) – that information can be found here or (ii) our Customer’s collection, use and disclosure of information through their Third Party Integration Partners (defined below), which is governed by their own privacy policies and practices.

About Us

Placements.io has developed a proprietary enterprise software as a service platform designed for media publishers (“Placements Service”). The Placements Service is designed to streamline and automate certain manual business processes that customer publishers undertake in selling their premium direct advertising inventory. Placements.io directly integrates with third parties such as salesforce.com and Google DFP (“Third Party Integration Partners”). With the Placements Service, customer publishers (“Customer”) can create proposals and insertion orders, check inventory availability in real-time and push ad campaigns directly into the ad server. The Placements Service also provides reporting and analytics on both pipeline and actual delivery allowing a publisher to have a better view into the health of their business. The Placements Service further reduces the manual processes required for invoicing by tying both 1st and 3rd party delivery data into the system for revenue and billing calculations.

Information We Collect

Placements collects certain information from Users that may be considered “personal data” or personal information” under applicable privacy or data protection laws (“Personal Data”). In particular, we collect general business information from Users such as name, email address, phone, company name and title. We also collect identifiers such as your IP addresses and cookie identifiers. We also collect information about your activity within the Placements Service (collectively, “User Information”).

The Placements Service does not directly identify any Personal Information of Customer’s end- users. Rather, such data is aggregated and pseudonymous when ingested by the Placements Service from Third Party Integration Partners, which means that it does not directly identify people.

How We Collect User Information

Manual Input

User Information may be provided directly into the Placements Service by a User.

Cookies and Other Technologies
We also use cookies and other standard web technologies to collect information automatically from your device when you use the Placements Service.

We engage with Google Analytics and HEAP Analytics who process certain activity information, including without limitation the date and time of visits, the pages viewed, IP addresses, links to/from any page, and time spent within the Placements Service. Cookies also allow our servers to remember your account information for future visits and to provide personalized and streamlined information across related pages of the Placements Service.

How We Use User Information

Personal Information provided to Placements.io through the Placements Service is used to provide the Services under the Master Services Agreement executed between Customer and Placements.io, or contacting you about the Placements Service or any other information requested by you from Placements.io, and may be shared between our offices in the U.S. and England for this purpose.

We also use the User Information for our legitimate business interests, including:

  • To operate and improve the functionality of the Placements Service;
  • Understand the sources of traffic and transactions within the Placements Service;
  • To compile statistics and conduct research and development for our internal business purposes – all of which is done in aggregate without identifying you;
  • To prepare reports that summarize visitor activity;
  • To analyze and report on performance (such as tracking campaign reporting, campaign forecasting); and
  • To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.

Sharing of User Information

We may share User Information that we collect as follows:

  • Placements.io Affiliates: We share User Information with other companies within Placements.io’ group of companies to use for any of the purposes described in this Services Privacy Policy.
  • Business Transfers: We may share User Information in connection with an actual or proposed sale or transfer of all or a part of our business or assets, corporate merger, consolidation, or bankruptcy.
  • Vital interest, legal rights and compliance with laws: We may share User Information with law enforcement, regulatory authorities, courts with competent jurisdictions, emergency services or other necessary third parties for legal, protection, security, and safety purposes, including:
    • to comply with laws or regulatory requirements and to respond to lawful requests and legal process;
    • to protect the rights and property of Placements.io, our agents, customers, and others, including enforcing our agreements, policies, and terms of use and protecting our network and physical assets; and/or
    • to protect the safety of our employees and agents, our customers, or any person.
  • Vendors, partners and other service providers: We may share User Information with our vendors and partners who perform functions on our or our Customer’s behalf and require access to such information to provide us with services or do work for us. Examples include: analyzing data, fraud prevention, hosting data, engaging technical support for our technology platform, and performing analysis related to our technology platform and related services

Individual Rights

You have the right to request the exercise of the following individual rights where relevant:

  • To access information Placements.io maintains about you.
  • To correct information Placements.io maintains about you.
  • To request that Placements.io erase information Placements.io maintains about you.
  • To restrict processing of information Placements.io maintains about you.
  • To object to processing, or exercise your right to data portability.

In order to exercise these rights you can contact us at [email protected]. Note, Placements.io may be unable to facilitate these rights in all cases.

Security Measures and Retention

Placements.io maintains reasonable security measures to protect against the loss, misuse or alteration of any personal information we maintain. However, Placements.io is unable to guarantee that the reasonable security measures we employ will not be penetrated or
compromised for reasons outside of our control, or that your information will remain secure under any and all circumstances. For more information about the technical security practices related to the Placements Services, please contact us at [email protected].

We will store any Personal Information or User Information provided for as long as is necessary to respond to your inquires, provide you with the Placements Service, Placements Application, Placements System and/or Placements Support and in order to maintain our relationship with you.

International Transfers

We operate the Placements Service 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.

Placements.io complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Placements.io has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Under the Privacy Shield, 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 Shield policy should first contact us at [email protected] or at the address listed in the “Contact Us” section of this policy. In the event we are unable to resolve your concern, you may contact JAMS, which provides an independent third-party dispute resolution body based in the United States, and they will investigate and assist you free of charge. A binding arbitration option may also be available to you in order to address residual complaints not resolved by any other means.

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.

Liability for Onward Transfers

Placements.io complies with the Privacy Shield’s Principle regarding accountability for onward transfers. We remain liable under the Principles if its onward transfer recipients process personal data in a manner inconsistent with the Principles, unless we prove that it was not responsible for the event giving rise to the damage.

Additional Terms

This Policy is effective as of the date listed above and remains subject at all times to the terms and conditions of the Master Services Agreement executed between Placements.io and Customer. We provide links to third-party sites or reference third-party data practices in this Policy. These sites and practices are maintained by third parties. Please be aware that Placements.io is not responsible for and cannot control the privacy and/or security practices of these other linked sites or third parties. We suggest that you visit those sites directly for more information on their privacy, security, data collection and processing policies, as they may differ from this policy or the Placements Service. We are not responsible for any acts or omissions committed by our Third Party Integration Partners and third party service providers, and are unable to guarantee that the security measures we employ will not be penetrated or compromised or that your information will remain completely secure under and any and all circumstances. Any capitalized terms used in this policy, but not defined, shall have the meaning as set forth in your Master Services Agreement with Placements.

How To Contact Us

We may change this policy from time to time and will notify you of any such changes. If you wish to contact us about this policy you can reach us by email at [email protected] or at:

Placements, Inc.
Attn: Legal Department
506 2nd Avenue, Suite 1825
Seattle, WA 98104

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