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PRIVACY POLICY – SERVICES


PRIVACY POLICY FOR KARGO GLOBAL, INC.

1. Introduction to Our Services Privacy Policy

Kargo is committed to transparency concerning its data practices.  Our goal is
to provide you with clear and meaningful information on the data we collect, use
and share and make sure you understand and can exercise your rights concerning
your personal data.

This privacy policy (“Policy”) describes how Kargo Global, Inc. (“Kargo”, “we,”
“our,” or “us”) collects, uses, and discloses information, which may include
personal data or personal information protected by applicable laws, in
connection with our services related to digital advertising (“Services”). This
Policy also describes the choices you can make about the information we collect
in connection with the Services. This Policy does not describe how we collect
and use information from our corporate websites, such as Kargo.com. For
information on how Kargo uses information collected from our corporate websites,
please click here: https://kargo.com/websiteprivacy.

As part of its commitment to consumer privacy, Kargo is a member of the Network
Advertising Initiative (NAI) and adheres to the NAI Code of Conduct.  Kargo also
adheres to the Digital Advertising Alliance (DAA) Self-Regulatory Principles. 
In addition, Kargo has implemented and follows the specifications and policies
of the IAB EU Transparency & Consent Framework (TCF) as part of our compliance
with EU data protection law. See https://iabeurope.eu/tcf-2-0/ for more
information. Kargo’s vendor identification number within the TCF is 972.

2. Introduction to Kargo

When we refer to “Kargo,” “we,” or “us” in this Privacy Policy, we mean the
Kargo entity that acts as the controller or processor of your information, as
explained in more detail in Section 6 below.

Through its Services, Kargo facilitates the buying and selling of digital ads
for our business partners, which include advertising partners, brands,
advertising agencies, marketing companies, and online publishers (“publisher
partners”). The collection, use and sharing of data may enable these partners,
using the Services, to conduct interest-based advertising. Interest-based
advertising involves showing you ads on the websites you visit that may be of
interest to you based on your browsing history.  Ads will appear on the websites
you visit whether or not the ads are interest-based.  Digital publishers of all
sizes, from bloggers to international news organizations, rely on advertiser
revenue to support their content.  Click here to learn more about interest-based
advertising.

3. Information We Collect

Our goal is to provide you with relevant, engaging advertising content in a way
that respects your right to privacy. As described below, we deliver the Services
using device data and browsing history. We do not collect or know your name,
address, email, date of birth, phone number, or other personal identifying
information unless you choose to provide it to us (e.g., if you contact us with
an inquiry).

Through the Services, we collect information that allows us to make inferences
about your interests for advertising purposes.  This data may constitute
personal information or personal data protected by applicable laws. Collecting
the types of information described below allows us to work with our business
partners to show you interest-based advertisements and to measure the success of
those advertisements.

Technical Identifiers We use certain types of technical identifiers to identify
your device, including:

 * Kargo-developed proprietary identifiers

 * Cookies (small text files)

 * Mobile advertising identifiers (such as Apple IDFA and Google AAID)

 * IP address 

 * Non-personal data inferred from an IP address or other technical identifier,
   such as non-precise geo-location data, which may include inferred
   longitude/latitude. 

 * Device-related data such as phone-type, browser, operating system, connection
   type.

Online Behavioral Information We collect information about your online browsing
activity to determine what types of activities and products you may be
interested in. This includes:

 * Websites and content viewed 

 * Mobile applications used

 * Dates and times of visits to partner websites

 * Engagement with advertisements (e.g. views, clicks, whether a full video was
   viewed)

Client and Partner IDs Our clients and business partners sometimes create
technical identifiers for their own purposes. We may use information from
different sources to associate these identifiers with additional information.

Location Information We may collect and process information about your general
location. The information we collect may tell us which country, city or zip code
you are in, but it does not tell us your precise location.

De-Identified Information Kargo may use de-identified information to support our
interest-based advertising activities. We do not retain any personal information
connected with the de-identified information.

You do not have to provide any personal information to Kargo, and if you
previously consented to providing the data, you can manage your data choices as
set out in Section 8 below.

If you opt-out of providing personal data, you will still see advertising on
webpages you visit. Without the use of your data, any advertising delivered on
our Services may be less relevant to your interests.

4. How We Collect Information

To collect the information described above, we and our business partners may use
cookies, which are small text files that online services often store on device
hard drives or mobile devices of visitors to their sites. A cookie contains a
unique number, which is used to recognize your device when a user of your device
returns to a website that it has visited previously.

We use cookies to enable us and our business partners to present you with more
relevant advertising by collecting information about your online activities over
time and across our business partners’ websites and mobile properties, from
which we may be able to infer the topics, products and services that may
interest you. We also use cookies to collect information about how visitors use
and access our business partners’ websites and mobile properties and to develop
reports on website usage on an aggregate basis.

You can find out more information about cookies at
https://www.allaboutcookies.org/

In addition to cookies, we use local web storage on the browser that is used to
access our publisher partners’ websites.  Local storage, like cookies, is
contained on the browser you are using when you see a Kargo advertisement on our
publisher partners’ websites. Like cookies, the browser or window type (e.g.,
private browsing) you utilize on your device may restrict the data that can be
stored and the length of time it persists.

5. How We Use the Information We Collect

We may use the information we collect to:

 * deliver or enable our advertising partners to deliver personalized messages
   that match your interests, including interest-based advertisements;

 * understand the interests of our publisher partners’ users;

 * customize user experiences when they use our advertising partners’ services;

 * generate and analyze reports and statistics about the performance of
   advertising campaigns, and improve performance over time, for our business
   partners and for our own use;

 * fulfill the purposes described to you at the point of collection or in
   accordance with your consent.

We may combine or aggregate any of the information we collect through our
Services for any of these purposes.

6. Information of EU Area Users

If you are located in the European Union, European Economic Area, Switzerland or
the UK (referred to in this policy as the “EU area”), and your information is
subject to applicable EU area laws.  Kargo’s legal basis for processing your
personal data depends upon the specific context in which we collect or use it.
For EU area users, Kargo uses the IAB Europe Transparency and Consent Framework
(TCF) as one mechanism for establishing our legal basis. The TCF is designed to
allow a publisher to present information and choices to users about third-party
vendors, like Kargo, that process data based on you accessing the publisher’s
content. The TCF will display information about the purposes for which Kargo
processes data and allow you to make choices with respect to those purposes. You
can change your preferences at any time as set out in Section 8 below.

In addition, we may use information that we collect when we believe in good
faith that disclosure is necessary (a) to protect our rights, the integrity of
our Services, or your safety or the safety of others, or (b) to detect, prevent,
or respond to fraud, intellectual property infringement, violations of Terms of
Use related to the Service, or violations of law. For EU area users, our legal
basis for use of information under these circumstances is the legitimate
interest of Kargo or our business partners.   Such use is compatible with your
legal rights, as no additional personal information is processed, and there is
no effect on your web or app experience, or other intrusive processing.

Kargo may act as a “controller” as defined under applicable law when processing
your personal data. We may also act as a “processor” as defined under applicable
law to the extent that we process your personal data on behalf of and at the
instruction of another party, for example a publisher or an advertiser.

7. How We Share the Information We Collect 

We may share information we collect in connection with the provision of our
Services for purposes that include but are not limited to the following:

 * with our advertising partners and technical service providers to enable our
   advertising partners to deliver personalized messages that match your
   interests, including interest-based advertisements. These include:
   
   * providers of IT-related services (e.g. data storage, hosting, management,
     or maintenance)
   
   * data analytics providers (e.g. measuring which advertisements receive the
     most views, clicks or sales, or categorizing data into interest groups)
   
   * advertising technology companies (e.g. data management platforms, demand
     side platforms, or ad-servers);

 * with our affiliates, representatives and advisors around the world who are
   involved in the provision of the Services and performing and enforcing our
   contracts and terms of service;

 * with our business partners, such as web publishers, advertisers or
   advertising agencies, for the purposes described in this Policy;

 * as required by law, such as to comply with a subpoena or other legal,
   regulatory or law enforcement process, or to comply with government reporting
   obligations;

 * when we believe in good faith that disclosure is necessary (a) to protect our
   rights, the integrity of our Services, or your safety or the safety of
   others, or (b) to detect, prevent, or respond to fraud, intellectual property
   infringement, violations of Terms of Use related to the Service, or
   violations of law;

 * with affiliates, service providers, advisors, and other third parties to the
   extent reasonably necessary to proceed with the negotiation or completion of
   a merger, acquisition, or sale of all or a portion of our assets.

For users in the EU area, your information will be stored in the United States,
and our affiliates and technical service providers outside the EU area may have
access to information in order to assist us in providing our Services. In each
case, we have in place safeguards that enable these transfers to happen in a way
that ensures that the information is handled in accordance with our instructions
and using similar standards to those applicable in the EU area. These safeguards
may include standard contractual clauses for data exports as approved by the
European Commission or other supervisory authorities. A copy of these documents
may be made available if we receive a valid request.

Subsequent to the exit of the United Kingdom (“UK) from the European Union
(“EU”), we intend to continue to transfer personal data from the UK to the EU
and the European Economic Area (“EEA”). For transfers from the EU or the EEA to
the UK, we will rely on the Standard Contractual Clauses. When our services
involve the storage and/or processing of personal data involving transfers of
personal data out of the EEA or the UK to a jurisdiction that is not the object
of an EU“adequacy” decision, then we will also rely on the Standard Contractual
Clauses.

In order to operate our business efficiently, we have to store and process
transferred personal data in the United States, the UK, the EU and/or any other
country where our partners, processors or subprocessors maintain facilities. We
will only do so as long as those partners, processors and subprocessors transfer
data via a valid legal mechanism such as the European Commission Standard
Contractual Clauses which commit them to similar data protection standards as in
the EU and the UK.

8. Your Choices About the Information We Collect

You are able to exercise control over the use of information collected by Kargo
to serve you interest-based advertisements. These tools are browser-specific, so
you should repeat this process for each browser that you use.

You may opt out of or withdraw your consent for our use of information collected
for interest-based advertising purposes by using one of the “opt out” procedures
described below:

Browser Opt-out: If you prefer not to see targeted ads via interest-based
advertising from our platform on mobile websites, you may opt-out of or withdraw
your consent for such interest-based advertising from Kargo by clicking “Click
to Opt-Out” below to place an opt-out cookie on your device, if your device
accepts such cookies. Kargo will set this opt-out cookie for a period of at
least ten (10) years, unless you reset your device or clear your cache or
cookies as set forth herein. This opt-out requires that you have cookies enabled
and will need to be repeated if cookies are cleared on your browser (which can
happen if you clear your browsing history or re-install your browser). This opt
out cookie can also be impacted by browser technologies that impact the ability
of javascript cookies to persist in your browser. In the event the browser
resets your cookie, your cookie opt out might not persist for as long as our
technologies attempt to place. But in this case, please note that your browser
is attempting to utilize native privacy features.


Click to opt out.

Even if you opt out, you will still see advertising on the web pages you visit.
However, such advertising may be less relevant to your interests.

You also may opt out of or withdraw your consent for our use of information
collected for interest-based advertising purposes on mobile websites and have an
opt-out cookie placed on your device if your device accepts such cookies by
visiting either one of the following industry-developed sites and selecting
Kargo:

 * Digital Advertising Alliance Consumer Choice Page: www.aboutads.info/choices.

 * Network Advertising Initiative Consumer Choice Page:
   www.networkadvertising.org/choices.

Please note that all of the options provided in this policy are
browser-specific, so you should opt out on each device and browser for which you
would like your preferences to apply. These tools also use cookies and cached
files to record your preferences. If you delete your cookies or clear your
browser cache, you may have deleted your opt-out status and may need to opt out
again.

App Opt-Out: You may select a system level advertising preference feature on
your device and Kargo will honor this preference to opt out your device from
interest-based advertising in apps. On Apple iOS devices, this system level
advertising preference may be accessed via Settings – Privacy – Advertising –
Limit Ad Tracking. On Android devices, open the Google Settings app from your
app drawer or from your operating system’s settings menu, tap Ads, and select
“Opt-out of Interest-based ads.”

9. Other US State Laws

Consumers who are resident in US states such as California, Colorado, Virginia,
Connecticut, or Utah may have additional rights under state privacy legislation
which defines personal information more broadly, ensures greater transparency
and accountability and provides consumers with extended rights as to the
collection and use of their personal information.

Your rights under US State Privacy Laws:

If you are resident in one of the states where specific privacy legislation is
in effect then, depending on the particular provisions of applicable local laws,
you may have some or all of the following rights:

 * Right to correction: Consumers have the right to request a business that
   possesses inaccurate personal information about the consumer to correct such
   inaccurate personal information, taking into the account the nature of the
   personal information and the purposes of the processing of the personal
   information.

 * Right to notice: Businesses must inform consumers at or before the point of
   collection what categories of personal information will be collected and the
   purposes for which these categories will be used.

 * Right to access: Consumers have the right to request that a business disclose
   the categories of personal information collected; the categories of sources
   from which personal information is collected; the business or commercial
   purpose; the categories of third parties with which the business shares
   personal information; and the specific pieces of personal information the
   business holds about a consumer. If a business sells personal information or
   discloses it for business purposes, consumers have the right to request the
   categories of information so sold or disclosed.

 * Right to opt out: Consumers have the right—at any time—to direct businesses
   that sell or share personal information about the consumer to third parties
   to stop such sales or sharing, known as the right to opt out. If a consumer
   is a minor, this becomes a right to opt in to the sale or sharing of data
   (exercised by the minor if the consumer is between 13 and 16 years of age, or
   by the minor’s parent or guardian if the consumer is under 13 years old).
   Businesses must wait at least 12 months before asking consumers to opt back
   in.

 * Right to request deletion: Consumers also have the right to request deletion
   of personal information, but only where that information was collected from
   the consumer. Like the right to erasure under the GDPR, this right is subject
   to exceptions. For instance, businesses need not delete personal information
   necessary for detecting security incidents, exercising free speech,
   protecting or defending against legal claims, or—in what is potentially a
   broad and likely contentious category—for internal uses reasonably aligned
   with the consumer’s expectations.

 * Right to limit use of sensitive information; Consumers have the right to
   restrict a business’s use of sensitive personal information e.g. to use that
   is necessary to provide goods or services requested, to certain business
   purposes, or other legally permitted purposes.

 * Right to equal services and prices: Businesses must not discriminate against
   consumers by denying goods or services, charging a different price or rate
   for goods or services, providing a different level or quality of goods or
   services, or suggesting that they will do any of these things based upon a
   consumer’s exercise of any of their legal rights relating to their personal
   information. Put differently, consumers have a right to equal services and
   prices.

Exercising your rights under US state laws:

If you want to make a request for exercise of any of the above rights, you (or
your authorized agent) can write to privacyinfo [at] kargo.com and we will
respond within 45 days as per the law.

If you make such a request, including through an authorized agent, we reserve
the right to verify your identity and the agent’s authorization.

However, we may not be able to respond to your request if it is not permitted or
foreseen under applicable law.

(Please note that we do transfer personal information collected through our
network of partners to third parties and as such are considered as having
disclosed or sold or shared data over the past twelve months. Please see Section
10 below for more information).  

10. Additional Information for California Consumers

10.1. Personal Information Collected in the past 12 months

Category

Examples

Source

Business or Commercial Purpose

Categories of third parties disclosed to

Identifiers

Unique personal identifier , online identifier, Internet Protocol address (e.g.
device and cookie IDs)

From partner websites and apps

From third party data providers

From our clients

Providing and improving our targeted advertising services which include creating
and enriching profiles and audiences for our clients

- Our clients

- Our data hosting and storage providers

- Our providers of advertising technology and services such as demand side
providers, data management platforms, and ad networks

- Our data processing service providers (for purposes such as analytics,
database management, customer support)

- Our other group companies

Commercial information

Records of products or services purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies (e.g. sites visited, apps used,
searches, views, clicks, and purchases)

As above

As above

As above

Internet or other electronic network activity information

Information regarding your interaction with websites and applications (e.g.
sites visited, apps used, searches, views, clicks, and purchases)

As above

As above

As above

Geolocation Data

Approximate location from information provided by your device (e.g. IP address)

As above

As above

As above

Inferences

Inferences drawn from any of the information above to create a profile

As above

As above

As above

Sensitive personal information

Personal information revealing a consumer’s racial or ethnic origin; information
concerning a consumer’s health

Inferred from the above information

As above

As above

*“Personal Information” does not include publicly available information,
including information that we have a reasonable basis to believe is lawfully
made available to the general public by you; from widely distributed media; or
by a person to whom you have disclosed it and not restricted the information to
a specific audience.

10.2. Personal Information Sold or Shared in the past 12 months

We have sold and/or shared the following categories of Personal information in
the past 12 months: (a) Identifiers; (b) Commercial information; (c) Internet or
other electronic network activity information; (d) Geolocation Data; and (e)
Inferences.

Such information is contained in audiences or profiles that we provide to our
clients.

10.3. Personal Information disclosed for a business purpose in the past 12
months

We have disclosed the following categories of Personal Information for a
business purpose in the past 12 months: (a) Identifiers; (b) Commercial
information; (c) Internet or other electronic network activity information; (d)
Geolocation Data; and (e) Inferences.

These business purposes comprise:

 * Auditing related to  counting ad impressions to unique visitors, verifying
   positioning and quality of ad impressions, and auditing compliance with this
   specification and other standards.

 * Helping to ensure security and integrity.

 * Debugging to identify and repair errors that impair existing intended
   functionality.

 * Performing services on our behalf, including maintaining or servicing
   accounts, providing customer service, processing or fulfilling orders and
   transactions, verifying customer information, processing payments, providing
   financing,  providing analytic services, providing storage, or providing
   similar services on our behalf.

 * Undertaking internal research for technological development and
   demonstration.

Undertaking activities to verify or maintain the quality or safety of our
services, and to improve, upgrade, or enhance our services.

For more information about how to exercise these rights with respect to Kargo
and data we process, please refer to our California Privacy Notice.


11. Your EU Area Rights

If you are an EU area user and your information is subject to applicable EU area
laws, you have additional rights in relation to information that we process
about you. These rights include:

 * to ask for access to the data

 * to ask for errors in the data to be corrected

 * to ask for the data to be erased (the “right to be forgotten”)

 * if not erased, then to ask us to restrict processing of the data

 * to object to its processing for specific purposes

 * to ask for a copy of the data to take to another service provider (“data
   portability”)

Where we process any information based on consent that you have previously
given, you are permitted to withdraw your consent at any time (though the
processing that took place before withdrawal will still be legal). You may
withdraw consent by (1) managing online choices as set out above; or (2)
visiting the websites where you have previously indicated your consent.

As indicated above, Kargo does not process contact or ID information such as
names or emails. Therefore, unless you provide us with a relevant technical ID
from your device, while we will always investigate any request thoroughly, it
may be impossible for us to know whether or not we are processing any
information relating to you. In these cases, we normally take the approach that
it is more protective for you to use the systems referred to above that enable
you to directly manage your online choices and cookie settings, and not to ask
you for (and then to process) additional information about you in order to
investigate such a request.

We are always available through the contacts in Section 15 below to help resolve
any issues or questions in relation to processing of your information. If you
believe that your rights have not been respected then you are also entitled to
make a complaint to the Supervisory Authority or Personal Data Protection
Authority in your country to ask them for a resolution.

12. Users Under 16 Years Old 

Kargo does not knowingly collect personal information from users under 16 years
old. If you become aware that Kargo may have collected information from a user
under 16 through the Services, please contact us (see Section 15) and we will
take steps to delete such information. 

13. Security

We strive to maintain reasonable administrative, technical, and physical
safeguards designed to safeguard the information we collect from unauthorized
access, corruption or loss. In general, information is kept in pseudonymous form
(i.e. you cannot be personally identified from it without additional data) and
we apply security measures such as password protection and Transport Layer
Security technology (TLS). However, no information system can be 100% secure, so
we cannot guarantee the absolute security of your information.

14. Information Retention

We retain information collected for interest-based advertising purposes for up
to eighteen months from the date of its collection, unless you reset your device
or clear your cache or cookies as referred to above.

If we need to keep your information longer than eighteen months for reporting,
accounting, regulatory or legal reasons, then we will retain it only for as long
as necessary under the applicable laws, policies or agreement and will use the
information only for the purpose for which it was retained..

15. Request for Information Disclosures

Reporting period Jan. 1 2020 - Dec. 31 2020

From Jan. 1 2020 - Dec. 31 2020, Kargo Global Inc. received a total of four (4)
requests via the contact information listed in section 15. These requests can be
categorized as deletion requests or information requests. Two (2) requests can
be categorized as deletion. Two (2) requests can be categorized as information.
While no specific requests were made to opt out via direct contact, Kargo
provides an opt out link on this page and via the NAI as mentioned in section 1.
In the cases of all requests in 2020, we issued a response to the data subject
within an average of 6 days (median of 5 days). A member of the team responded
to these requests either in the context of requesting more information to verify
the identity of the data subject, or providing the data subject a link to an
online portal where they could view additional information within their browsers
which may be utilized by Kargo technologies. In all cases of the requests in
2020, Kargo did not receive a further reply after our initial response from the
data subject.

16. Changes to This Policy

We may update this Policy from time to time to address changes in the Services,
changes in the laws or regulations, or for other reasons.  If we update this
Policy, we will notify you by posting a new Policy on this page. If we make a
change that materially affects the way in which we use or share the information
previously collected from you through our Services, we will not apply that
change to information collected prior to the date of the change.

17. Contact Us

If you have any questions about this Policy or our use of your information,
please contact us by email at privacyinfo@kargo.com, or by mail at Kargo Global,
Inc., 826 Broadway, 4th Floor, New York, NY 10003, Attn: Legal. We welcome your
questions and feedback.

This Policy was last updated on December 22, 2022.

Kargo HQ
826 Broadway, 4th Floor,
New York, New York 10003
2129799000 mobilize@kargo.com
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