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PRIVACY POLICY

Last Updated: January 29, 2021


INTRODUCTION

Welcome to MediaMath’s Privacy Policy (“Policy”). In this Policy, we use the
terms “MediaMath“, “our“, “us” and “we” to refer to MediaMath, Inc. and our
affiliates.

MediaMath is committed to protecting the privacy of individuals (“users”, “you“,
“your“) when we process data about them via our proprietary TerminalOne™
platform (the “Platform“), when they visit our website at www.mediamath.com (the
“Website“) and when we engage in marketing activities based on contact
information they provide to MediaMath through other means described in this
Policy.

This Policy is provided in a layered format, so you can click through to the
specific sections that may interest you.


1. IMPORTANT INFORMATION AND WHO WE ARE

Purposes of this Policy

This Policy sets out how MediaMath collects and processes personal data,
personal information or the equivalent terminology in your jurisdiction
(“personal data” or “personal information“) about you via the Platform, when you
visit the Website, and when we engage in marketing activities based on contact
information you provide to MediaMath through other means described in this
Policy. It also sets out our practices regarding our use of such personal data,
the steps we take to protect it, the parties to whom we disclose it, and the
choices and rights that you have regarding how we collect and process personal
data about you.

You should read this Policy carefully so that you are fully aware of how and why
we are using your personal data.

Who we are

MediaMath is a global provider of digital advertising media and data management
technology. We provide a technology platform and services which help advertisers
do a more effective job of reaching their desired audiences. This technology
delivers greater performance, transparency, and control to advertisers and a
better Internet experience to users. Our Demand-Side Platform enables our
clients, including advertisers and advertising agencies, to purchase advertising
inventory, including display, video, audio, social, native, digital out-of-home
(e.g., billboards or ads you may see in taxis or buses) and mobile ads, from
publishers in an automated fashion. Our Data Management Platform provides our
clients with tools to onboard, segment, activate, and understand their data.

When MediaMath processes your personal data as a controller in the context of
operating the Platform, the Website and our marketing activities, the controller
of your personal data is MediaMath, Inc. If our clients have contracted with
MediaMath GmbH, both MediaMath, Inc. and MediaMath GmBH are controllers of your
personal data.

MediaMath is an active member of the industry associations that govern policies
around user privacy in the context of digital advertising, including at the time
this Policy was written: the Network Advertising Initiative (“NAI”); the Digital
Advertising Alliance (“DAA”), the DAA Canada, and the European Interactive DAA;
the Interactive Advertising Bureau in the US, Europe and various countries
around the world; and the Association of National Advertisers. MediaMath
complies with the “NAI Code of Conduct”, the DAA “Self-Regulatory Principles for
Online Behavioral Advertising”, and their “Application of Self-Regulatory
Principles to the Mobile Environment”. We believe that these programs’
principles help protect user privacy.

 

        

 

Changes to the Policy

From time to time, MediaMath may revise this Policy. The date of the last update
can be found at the top of the Policy, and this policy describes how we have
handled personal data in the twelve months prior to the date indicated. If we
make revisions that materially change or affect whether or how we collect or use
personal data, we will notify you by email (if, as a user of our Website or
recipient of our marketing communications, you have provided us your email
address) or by means of a notice on our Website prior to the change becoming
effective. If you would like to stay up-to-date on our most current policies and
practices, you should periodically review this Policy.

Personal data pertaining to children

MediaMath’s products and services are not designed to deliver personalized ads
to children, the definition of which varies by jurisdiction, and we do not
knowingly collect personal data from or about children. If we are made aware
that we have received personal data from or about a child, we will use
reasonable efforts to remove that data from our records.

Links, other websites and other third parties

This Policy relates solely to the personal data we collect and process about you
in relation to our Platform, our Website, and other interactions you may have
with MediaMath that are described in this Policy. MediaMath’s Website contains
links to other sites, and the ads delivered by the Platform may run on a variety
of other sites. Clicking on those links, accessing other sites, or enabling
those connections may allow third parties to collect or share data about you.
MediaMath does not control these third-party sites and is not responsible for
the privacy practices of such sites. You should refer to the privacy statements
of such third-party sites to find out how they collect and use your personal
data. Also, as explained below in Section 5, third parties may process personal
data from you when you visit the Website. Such processing is governed by the
privacy statements of such third parties.


2. THE PERSONAL DATA COLLECTED VIA THE PLATFORM

While MediaMath collects certain categories of personal data in the course of
delivering an ad to you via the Platform, we do not intentionally collect
directly identifiable data such as your name, home address, phone number, or any
government identifiers such as your Social Security Number unless you provide
such data in connection with any request that you may choose to make directly to
MediaMath. Instead, MediaMath collects certain personal data related to your
computer or device through the use of cookies and other similar technologies, as
explained below.

We may assign a unique identifier called a MediaMath ID to your browser, your
devices, such as your mobile device, connected television, or over-the-top
television devices (“OTT TV Device“), or other screens you may encounter when we
serve an ad to it or when you use it to access a client’s digital properties.
Digital Properties include websites, emails, apps (“Digital Properties“). The
MediaMath ID enables the Platform to determine within a reasonable level of
confidence that a browser or devices is the same one with which the Platform has
previously interacted. For example, the MediaMath ID allows us to determine that
a browser or device to which we served an ad on Monday is likely to be the same
browser or device for which we observed a purchase on Tuesday. In some cases,
based on data we receive from our clients or partners, we are able to infer
within a reasonable probability that a particular browser or device should be
associated with the same MediaMath ID. Where we are able to associate more than
one browser or device with the same MediaMath ID, we may use this information to
deliver targeted ads across multiple browsers or devices. This is sometimes
referred to as cross-device advertising.

The MediaMath ID can be a cookie ID (a unique ID assigned randomly by MediaMath
to an unrecognized browser), a mobile advertising ID (a unique ID assigned by
the mobile operating system, e.g. Apple ID for Advertising or Android
Advertising ID), or an OTT TV Device Identifier for Advertising (a unique ID
assigned by an OTT TV provider, e.g., Roku ID for Advertising)).

Your MediaMath ID is personal data and is associated with other categories of
personal data that we collect about you. These categories include the following:

 * Bid Request Data and Impression Data: MediaMath receives personal data about
   you when we have the opportunity to show you an ad on Digital Properties and
   collects additional data when we deliver an ad. We refer to this data as Bid
   Request Data and Impression Data. The sources of Bid Request and Impression
   Data are your browser or device and media supply sources, such as publishers
   (i.e. organizations who operate Digital Properties) and exchanges or
   supply-side platforms who display ads on publishers’ Digital Properties. This
   includes data that may be considered personal data in your jurisdiction such
   as your Internet Protocol (“IP”) address, imprecise location (e.g., country,
   region, postal or zip code), browser type (e.g., Chrome or Internet
   Explorer); operating system (e.g., Mac OS or Windows); browser language
   (e.g., English or Spanish); and Internet Service Provider (e.g., Comcast or
   Verizon). It also may include IDs that our partners assign to your browser or
   device, including Google advertising identifiers associated with your browser
   or device and used by MediaMath as part of its syncing processes. See
   Google’s Privacy Policy to learn more about its use of the personal data
   which it receives from partner sites and your ability to control the
   information which Google collects on these sites.
 * Pixel Data and Other Client Data: MediaMath clients may import personal data
   to the Platform regarding your interactions with them when you visit their
   Digital Properties. We may similarly collect personal data when you visit our
   Website. This includes data that may be considered personal data in your
   jurisdiction such as the time you visited the site, the page URL, your IP
   address, your browser type (e.g., Chrome or Internet Explorer), the operating
   system (e.g., Mac OS or Windows), the type of device you used (e.g. laptop or
   desktop), and data regarding your activities on the Digital Properties. For
   example, if you are shopping online for a product, place a product in your
   online shopping cart, or make an online purchase, the client associated with
   the website or app may use the Platform to collect that personal data and
   later show you an ad on a different site or app related to that product.
   MediaMath clients also may use the Platform to collect hashed personal data
   that does not reveal your direct identity, such as hashed email addresses.
   The process of hashing is commonly used in digital advertising to convert
   directly identifiable personal data to pseudonymous personal data. We refer
   to everything described above as Pixel Data. Clients also may import personal
   data that they have obtained outside of the Platform, such as segments that
   our clients create or obtain independently from third-party sources. A
   segment is a grouping of individuals who share one or more attributes (e.g.,
   “car enthusiast”). These individuals are identified by an online identifier
   in these segments but are not identified by name or other personal data that
   directly reveals their identity. Clients also may import personal data that
   they collect or independently obtain offline, such as personal data regarding
   a purchase you made in the client’s store. The client’s offline data is first
   processed by the client or a third party, which removes any directly
   identifiable personal data, appends a MediaMath ID, and transmits the file to
   MediaMath for processing. We refer to this data as Other Client Data.
 * Third-Party Segment Data and Other Third-Party Data: We work with audience
   providers who create and provide us with segments for us and our clients to
   use for advertising purposes. We refer to this as Third-Party Segment Data.
   We also receive personal data from third-party partners that allows them
   and/or us to associate the MediaMath ID with those partners’ identifiers
   (through a process called “cookie syncing”) as well as personal data that
   associates your different devices with each other. Certain third parties may
   provide personal data to us regarding video content that you view on
   television. We refer to this personal data in the Policy as Other Third-Party
   Data.
 * Special or Sensitive Categories of Personal Data: We do not knowingly collect
   any special categories of personal data about individuals in the EEA,
   including: personal data revealing your racial or ethnic origin, political
   opinions, religious or philosophical beliefs, or trade union membership;
   personal data concerning your health, sex life, or sexual orientation; and
   genetic or biometric data. MediaMath also does not knowingly collect any data
   about other sensitive categories such as personal data about children,
   financial account numbers, insurance plan numbers, and criminal convictions
   or offenses.


3. HOW WE COLLECT PERSONAL DATA VIA THE PLATFORM

 

The Platform uses various technologies to collect your personal data.

Personal data we collect from your browser or device

Like most digital marketing platforms, MediaMath uses cookies and other
technologies to recognize browsers and devices and collect the categories of
personal data described above in Section 2 so that we and our clients can infer
your interests, deliver more relevant advertising to you, measure the impact of
that advertising, and better understand your digital media usage patterns.

The types of technologies used via the Platform that enable us to identify a
computer or device, and enable the Platform to function and serve more relevant
ads include:

 * Cookies – Cookies are small text files. MediaMath uses cookies to uniquely
   identify an Internet browser. Certain browsers or browser settings sometimes
   block cookies or prevent them from working effectively.
 * Pixels – Pixels are transparent images, iFrames, JavaScript or mobile SDKs
   that we, our clients, and our partners use to understand how users interact
   with their Digital Properties.

 

Personal data we collect from third parties

As described above, we receive personal data from third parties such as our
clients and partners, including audience data partners, media supply sources,
and exchanges or supply-side platforms. We receive this personal data in a
number of ways, including through server-to-server transfers, a process called
“cookie syncing” and other client and partner calls to MediaMath originating
from the browser. We process all of this personal data in the Platform.


4. HOW THE PLATFORM USES PERSONAL DATA

 

We use the personal data in the Platform to deliver more relevant ads to you on
behalf of our clients. We also use the personal data to improve our Platform and
the products and services that we provide to our clients and partners, as well
as to create new products and services. Below, we have set out a description of
specific ways we use various combinations of your personal data in the Platform.

 

Personal Data Type Purpose/Activity
 * MediaMath ID
 * Bid Request and Impression Data
 * Pixel Data and Other Client Data
 * Third-Party Segment Data and Other Third-Party Data

 * Enabling MediaMath clients to create marketing campaigns;
 * Creating segments;
 * Facilitating MediaMath clients’ creation of segments;
 * Making decisions related to the opportunity to display an ad (e.g., deciding
   which clients’ campaigns are a good match for a bid opportunity and what
   price to bid in each case) and placing the bid;
 * Setting, reading and modifying a MediaMath cookie or reading a mobile
   advertising identifier or OTT TV Device Identifier for Advertising;
 * Collecting information about a browser or device;
 * Facilitating our partners’ collection of personal data, including by placing
   partners’ pixels or tags on our clients’ Digital Properties;
 * Delivering ads based on your inferred interests or activities on Digital
   Properties;
 * Measuring the effectiveness of those ads and attributing your activities to
   our clients’ campaigns;
 * Generating and providing to clients reports and user-level data related to
   their campaigns in the Platform;
 * Automated decision-making and profiling based on personal preferences,
   interests, behavior, or location;
 * Transferring data to a third party where clients have elected to use its
   services or where MediaMath has engaged a subcontractor to provide certain
   functionality or capabilities as a part of the Platform or to improve our
   Platform and the products and services that we provide to our clients and
   partners; and
 * Fraud detection and prevention.

 * MediaMath ID
 * Impression Data
 * Pixel Data
 * Other Third-Party Data

 * Synchronizing MediaMath cookie ID with third-party partners.

 * MediaMath ID
 * Impression Data
 * Third-Party Segment Data and Other Third-Party Data
 * Pixel Data and Other Client Data

 * Associating multiple browsers and devices with each other;
 * Development, maintenance, and commercialization of MediaMath’s cross-device
   graph that associates your different devices with each other;
 * Append audience membership to Client’s first-party data.

 * Pixel Data and Other Client Data
 * Third-Party Segment Data and Other Third-Party Data
 * MediaMath ID

 * Mapping data pixels to third-party segments.

 * MediaMath ID

 * Honoring opt-out requests for users who have opted out.

 * Bid Request Data

 * Enabling hyperlocal targeting of devices within a defined location.

Segments

As described above, a segment is a grouping of users who share one or more
attributes. Where allowed by applicable data protection law and industry
self-regulatory associations:

 * Our clients may use health-related segments about non-sensitive conditions
   such as an inferred interest in health and wellness or cough medicine and
   allergy medications. Click here for a list of the standard health-related
   segments and a sample of custom health segments provided for use by clients
   in MediaMath’s Platform.
 * Our clients may use segments based on political information or interests.
   Click here for a list of the standard political interest segments and a
   sample of custom political segments provided for use by clients in
   MediaMath’s Platform.

While MediaMath does not knowingly create segments that are based upon what we
consider to be sensitive information (for example, we do not create segments of
EEA users based on personal data considered to be sensitive in the EEA, such as
personal data revealing your racial or ethnic origin, political opinions,
religious or philosophical beliefs, or trade union membership, personal data
concerning your health, sex life or sexual orientation, or genetic or biometric
data), our clients may use the Platform to process some sensitive data (but
excluding sensitive categories in the EEA), which may come from our clients’
Digital Properties or our partners. MediaMath may process segments based on
demographic information such as race, gender and income range where such is
information is not considered sensitive. We take steps designed to ensure that
this is done in compliance with applicable laws and self-regulatory guidelines,
including through our contracts and policies with our clients and partners, but
our clients are responsible for this processing, and any queries should be
directed to them.

Automated decision-making and profiling

The Platform uses proprietary algorithms to make decisions about whether or not
to bid on opportunities to serve you ads and, if so, how much to bid. The ads
you see are the result of client campaigns that specify how much to spend and on
what basis to spend combined with the use of our algorithms. The ways in which
we use algorithms to determine bid prices may be considered automated
decision-making in certain jurisdictions. Additionally, these processes, in
combination with client campaigns described below, may constitute profiling in
certain jurisdictions.

As explained above, we assign a MediaMath ID to your browser or device. Using
proprietary technology, we associate data that we collect about you with this
MediaMath ID and create segments using inferred details about certain of your
preferences, behaviors, and demographic information. Many of our clients’
campaigns rely on such segments. For example, if you are browsing a shoe
retailer’s website on your mobile device, we may infer that you are interested
in buying sneakers and associate that mobile device with a sneaker-buyer
segment. If a client subsequently wants to advertise sneakers, the client may
choose to target that segment across your devices. If MediaMath then receives an
opportunity to show you an ad on your computer browser, which has been
associated with your mobile device by our algorithm, MediaMath’s bidding
technology will automatically decide whether to bid and if so what price to bid,
based on the data and algorithms outlined above.

The automated processes that we use do not affect your legal rights (such as
your right to vote, take legal action, or freely associate with others) or your
ability to receive social benefits or obtain citizenship, nor do they have legal
effects on you. Also, we do not knowingly process or make automated decisions
about EEA users based on any data that falls into special categories in the EEA.
As described below, you have the right to object to this automated
decision-making at any time and you may have additional rights described in
Section 11.

Legal basis for processing

Our legal basis under the GDPR for collecting and using the personal data
described above will depend on the personal data concerned and the specific
context in which we process it. However, we will normally collect personal data
from you only where the processing is in our (or a third party’s, such as our
clients’) legitimate interests and not overridden by your rights, such as your
right to opt out. If we collect and use your personal data in reliance on our
legitimate interests (or those of any third party), this interest will normally
be to operate the Platform and serve you ads on behalf of our clients. We may
have other legitimate interests and, if appropriate, we will make clear to you
at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal
basis on which we collect and use your personal data, please contact us using
the contact details provided under the “How to contact us” heading above.

Sale of personal information

For the purposes of the CCPA, MediaMath has sold all of the categories of
personal information collected on the Platform for certain processing purposes
in the past twelve months. If you are a California resident and want to exercise
your right to opt out of the sale of your personal information, please see the
instructions below in the section Opt out of sale for California residents.

Opt-out and choice mechanisms

Opt out of tailored advertising

If you want to limit the data that MediaMath collects about you and want us to
not target ads that are based on your interests to your browsers or devices, you
may opt out from MediaMath tracking and tailored advertising at any time through
one of the ways described below. If you opt out, you will still see ads, but
those ads are less likely to have anything to do with products or services you
care about. With tailored advertising, you receive ads and offers that are more
likely to be useful to you.

Your opt-out is only applicable to the Platform and does not opt you out from
platforms provided by third-party companies. However, you can opt out from both
MediaMath and many third-party companies at once; to do so, please see “Other
ways to opt out of tailored advertising” below. When you opt out, MediaMath will
collect data from your browser, app, or device only as needed to honor your
opt-out and for limited research and development purposes to improve our
browser- and device-recognition technology, which also helps to improve our
ability to honor your opt-out. When you opt out, MediaMath also stops targeting
tailored advertising to the opted-out browser, app, or device.

If you use multiple browsers or devices and wish to limit the data that
MediaMath collects and do not wish to receive MediaMath tailored advertising on
any of them, you must opt out from each browser and device individually.

Opt out of tailored advertising in a browser

You may opt out if you are using a browser by clicking the “Click here to opt
out” link below. Please note that if cookies are not enabled in your browser,
including if third-party cookies are disabled, or if you use certain ad-blocking
tools, our opt-out mechanism may not work properly. Please also note that
deleting your cookies does not opt you out. If you clear your cookies, or if you
use a different browser or device, you will need to renew your opt-out choice.

Opt this browser out of tailored advertising (if using a browser)

Your current opt-out status with MediaMath in this web browser is:



Opt out of tailored advertising in the mobile application environment

You may opt out in mobile app environments using the “AppChoices” mobile
application, where applicable, which you can download to your mobile device from
your App Store or via the DAA AppChoices page here.

Other ways to opt out of tailored advertising

You may learn more about tailored advertising and opt out of tailored
advertising from MediaMath and other online advertising companies that are also
members of applicable self-regulatory organizations by visiting their opt-out
links:

 * NAI (browser) – http://optout.networkadvertising.org/
 * DAA (browser) – http://optout.aboutads.info/
 * DAA Canada (browser) – http://youradchoices.ca/choices
 * European Interactive DAA (browser) – http://www.youronlinechoices.com/
 * DAA AppChoices page (mobile) – http://www.aboutads.info/appchoices

Other ways to limit ad tracking in the mobile and OTT TV device application
environment

You also may limit ad tracking in mobile app environments on your mobile device
as well as on your OTT TV Device. For the most effective and up-to-date methods
for doing so, you should consult instructions provided by those device
manufacturers. The NAI provides additional information regarding opting out on
mobile available here and TV streaming devices available here.

Where MediaMath receives a signal to limit ad tracking, we will collect data
from your device only as needed to honor your choice and for limited research
and development purposes to improve our device-recognition technology, which
also helps to improve our ability to honor your choice. Where MediaMath receives
a signal to limit ad tracking, MediaMath also will not serve tailored
advertising in the apps on your mobile device or OTT TV Device.

 

Opt out of sale for California residents

California residents can find instructions about how to opt out of the sale of
their personal information here.

 

If you have questions about how to opt out or limit ad tracking, please contact
us at privacy@mediamath.com.


5. THE PERSONAL DATA WE COLLECT VIA THE WEBSITE OR OFFLINE

 

If you visit our Website or certain third-party marketing applications used by
MediaMath or if you interact with MediaMath in other ways described below,
MediaMath collects certain personal data from you when you choose to reveal it
to us, and we may also automatically collect certain personal data. Third
parties may collect personal data from you if you use certain features on the
Website. The Website also may reflect certain personal data provided to us
separately when you provide your consent for such display.

Personal data you provide

When you visit the Website, you may choose to provide your personal data to set
up an account, request information such as a demonstration of our products, or
send us questions. You also may choose to provide us with your personal data
through sources other than the Website, including, for example when you register
for or attend an event hosted by MediaMath. The personal data may include your
name, email address, company, title, region, and information about your business
such as industry, size, revenue, and address. You have the ability to provide
additional information at your discretion.

You also may provide us with your personal data on the publicly accessible blogs
on our Website. You should be aware that any information you provide in these
areas may be read, collected, and used by others who access them. To request
removal of your personal data from our blog or community forum, please contact
us at privacy@mediamath.com. In some cases, we may not be able to remove your
personal data, in which case we will let you know if we are unable to do so and
why.

We do not link the personal data described in this section with personal data
that we may have about you in the Platform.

Personal data we collect automatically

As is true of most websites, we gather certain personal data automatically when
content is displayed to you on the Website and we store it in log files. This
includes data that may be considered personal data in your jurisdiction such as
IP address, browser type, Internet Service Provider, referring and exit pages,
operating system, date and time stamp, and/or clickstream data. We do not link
this personal data stored in log files to other information we collect about
you.

We also automatically collect, and allow certain of our partners and
subcontractors to automatically collect, personal data from you when you visit
the Website. This is done using various technologies including cookies and
pixels. Examples of subcontractors include video providers and email service
providers. We classify the data that we collect from you on the Website using
cookies and pixels as Pixel Data, which is described above in Section 3. Our
partners and service providers also may collect personal data, may sync with
additional third parties, and may allow third parties with whom they partner to
set cookies on the Website. Please note, MediaMath does not control these
partners and subcontractors. You should refer to the privacy statements of such
parties to find out what personal data they collect, how they use cookies and
how they interact with other third parties. For further information on the
cookies and pixels we use on the Website, including a list of the partners and
subcontractors described above, and how you can opt out, please see our Cookie
Notice.

Social media features and widgets

The Website includes social media features that allow you to share news, events,
and blog posts from the Website on platforms such as Facebook, Twitter, and
LinkedIn or by email. These social media features are hosted by the third
parties providing them, and your interactions with these features are governed
by the privacy policies of the company providing them, which you should read and
ensure you understand.

Testimonials

We may display testimonials from satisfied clients on the Website in addition to
other endorsements. We will obtain our client’s permission before we place these
testimonials on the Website. If you are a client who wishes to update or delete
your testimonial, please contact us at privacy@mediamath.com.

Legal basis for processing

Our legal basis under the GDPR for collecting and using the personal data
described above in this Section 5 will depend on the personal data concerned and
the specific context in which we collect it. However, we will normally collect
personal data from you only where the processing is in our legitimate interests
and not overridden by your rights, such as your right to opt out, or where we
have your consent to do so. If we collect and use your personal data in reliance
on our legitimate interests, this interest will normally be to operate the
Website, communicate with you, send you marketing communications (where we have
your permission to do so, if such permission is required by applicable law), and
show you ads on Digital Properties. We may have other legitimate interests and,
if appropriate, we will make clear to you at the relevant time what those
legitimate interests are.

In some cases, we also may have a legal obligation to collect personal data from
you. If we ask you to provide personal data to comply with a legal requirement,
we will make this clear at the relevant time and advise you whether the
provision of your personal data is mandatory or not (as well as of the possible
consequences if you do not provide your personal data).

Where we are required by applicable law to obtain your consent, for instance (in
some cases) in order to send you marketing communications, we will do so, and in
such cases the legal basis for our processing of personal data will be your
consent.

If you have questions about or need further information concerning the legal
basis on which we collect and use your personal data, please contact us using
the contact details provided under the “How to contact us” heading above.


6. HOW WE USE PERSONAL DATA COLLECTED VIA OUR WEBSITE

Personal data you provide

When you provide your personal data to MediaMath on the Website or through other
means described in this section, we may use the data for the following business
and commercial purposes:

 * To respond to your inquiry;
 * To understand your business and offer you potential business opportunities;
 * To know or infer your interest in marketing products and services;
 * To enrich certain personal data you provide, for example your IP address or
   company information with information obtained from third parties;
 * To segment (group) you with similar individuals;
 * To provide you with information and offers about MediaMath products and
   services, information resources (e.g. whitepapers, reports and webinars),
   industry news and opinions, and announcements about MediaMath;
 * To inform you about and invite you to events, educational opportunities, or
   training opportunities;
 * To ask you to share MediaMath information, offers, and invitations with other
   people; and;
 * To attribute your responses or actions to specific marketing campaigns,
   activities, and channels.

You may choose to stop receiving marketing communications at any time by
following the unsubscribe instructions included in any marketing communications
we send you or by contacting us via email at privacy@mediamath.com.

Personal data we collect automatically

MediaMath uses information from the Website log files for troubleshooting and
security purposes. We use the Pixel Data that we collect from you on the Website
for the purposes described above in Section 4. Accordingly, each purpose and
activity that applies to our clients in Section 4 could apply to MediaMath. For
example, we may use Pixel Data that we collect from you on the Website to
deliver ads to you when you visit other Digital Properties, and we may collect
additional personal data from you on those Digital Properties, such as Bid
Request Data or Impression Data. We use other data that is collected on the
Website using cookies and pixels to determine how you found out about us, what
your interests are regarding our services, and how to further improve the
functionality of the Website and our service towards you as well as to analyze
trends and administer the Website. For further information on the cookies and
pixels we use on the Website and how you can opt out, please see our Cookie
Notice.


7. DISCLOSURE OF PERSONAL DATA FROM THE PLATFORM AND WEBSITE

 

We disclose your personal data to the following categories of third parties for
the business and commercial purposes set out above in Section 4 and Section 6:

 * We disclose the following categories of personal data to our affiliates in
   connection with our business operations that are based in our regional
   offices in the UK, Spain, France, Germany, Singapore, Brazil, Japan, Mexico
   and Australia:
   * MediaMath ID
   * Pixel Data and Other Client Data
   * Bid Request and Impression Data, and
   * Third-Party Segment Data and Other Third-Party Data
 * We disclose the following categories of personal data with our clients and
   resellers in connection with providing them with our digital advertising
   media and data management services and products:
   * MediaMath ID
   * Pixel Data and Other Client Data
   * Bid Request and Impression Data
   * Third-Party Segment Data and Other Third-Party Data.
 * We also, at our clients’ direction, disclose their data to the third parties
   that they designate.
 * We disclose the following categories of personal data to our audience
   partners in connection with creating custom client segments based on
   client-supplied seed data or other data:
   * MediaMath ID
   * Pixel Data and Other Client Data
   * Third-Party Segments
   * Impression Data
 * We also disclose the following categories of data with a limited number of
   audience partners in connection with audience creation or modeling:
   * Bid Request Data
 * We disclose the following categories of personal data with our cookie sync
   partners in connection with synchronizing MediaMath cookie IDs with
   third-party partners’ IDs:
   * MediaMath IDs
   * Pixel Data
   * Impression Data
   * Other Third-Party Data (specifically third-party IDs)

We work with a number of parties (referred to in this Policy as subcontractors)
to whom we disclose personal data so that they can help us provide the services
requested by our clients. These subcontractors provide the following services:
measurement, viewability, location-based attribution and location-based
targeting providers, dynamic creative optimization, attribution, fraud detection
and prevention, providing mechanisms to honor user choices, infrastructure,
storage, computing delivering content, analyzing supply inventory and reporting.

We disclose personal data to subcontractors who help with the operation of our
Website, including services provided in connection with the Website including
email services, event management, maintenance of our marketing database, web
analytics, recruitment, management of marketing and customer relationship and
social media.

We require third parties and subcontractors to respect the security of your
personal data and to treat it in accordance with applicable laws. We also define
the permissible scope and, where appropriate, restrict the use by third parties
of your personal data. We require our subcontractors to only use the information
that we provide to them in connection with the services they perform for us and
in accordance with our instructions.

We disclose personal data when we consider this to be necessary to establish or
protect the legal rights of MediaMath or its employees, agents and contractors,
as well as the legal rights of its clients or other third parties; to protect
the safety and security of users and visitors to our Website; to protect against
fraud; or to comply with the law or legal process.

We disclose personal data when we are required to or allowed to do so by law
(for example in response to subpoenas, to comply with a binding court order,
legal process, or government requests, including in response to a public
authority to meet national security or law enforcement requirements).

If MediaMath negotiates to or sells all or part of its business or makes a sale
or transfer of assets or is otherwise involved in a merger or business transfer,
we may transfer or assign the personal data to a third party as part of any
proposed or actual transaction.

We also may publish or otherwise make public anonymous, aggregate, or summary
information regarding campaigns run in the Platform on behalf of our clients.
For example, we may publish a report that reflects aggregated statistics
regarding seasonal trends in shopping patterns or geographic differences in
advertising impression opportunities.


8. INTERNATIONAL TRANSFERS

 

The information that we collect from you and about you may be transferred to and
stored in a country other than your country of residence, such as the United
States, which may not offer the same level of protection of personal data as
your country of residence. However, we will take contractual and/or other
measures to ensure your personal data is protected.

For individuals in the EEA, UK and Switzerland

MediaMath has its headquarters in the United States and many of our partners or
vendors are based outside of the EEA, UK and Switzerland. Whenever we transfer
your personal data out of the EEA, UK and Switzerland we ensure that it receives
a similar degree of protection by entering into the Standard Contractual Clauses
approved by the European Commission (and/or the applicable UK and/or Swiss
authority) with our group companies and applicable partners or vendors.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

Notwithstanding the invalidation of the Privacy Shield Frameworks as mechanisms
for the lawful transfer of data out of the EU and Switzerland (as applicable),
MediaMath, Inc., in addition to entering into the Standard Contractual Clauses
referred to above, continues to comply with the EU-U.S. Privacy Shield Framework
and the Swiss–U.S. Privacy Shield Framework as set forth by the U.S. Department
of Commerce regarding the collection, use, and retention of personal data
transferred from the EU, United Kingdom and Switzerland to the United States,
respectively.

MediaMath, Inc. has certified to the Department of Commerce that for all
personal data it receives from the EU, the United Kingdom and Switzerland, it
will adhere to the Privacy Shield Principles of Notice, Choice, Accountability
for Onward Transfers, Security, Data Integrity & Purpose Limitation, Access, and
Recourse, Enforcement and Liability.

If there is any conflict between the terms in this Policy and the Privacy Shield
Principles, the Privacy Shield Principles shall govern. To find out more about
the Privacy Shield, access the Privacy Shield List, and find details of our
certification, please visit: https://www.privacyshield.gov/list.

Under the Privacy Shield, MediaMath, Inc. may remain liable if its subcontrators
process your personal data in a manner inconsistent with the Privacy Shield
Principles, unless we prove that we are not responsible for the event giving
rise to the damage.

Individuals in the EU or Switzerland who believe that their personal data has
not been processed in compliance with the Privacy Shield Principles may raise
their complaint in the following ways:

 1. You can contact MediaMath, Inc. directly using the details in the “How to
    contact us” section above. We will respond to your complaint within 45 days
    of receipt.
 2. We have further committed to refer unresolved privacy complaints under the
    Privacy Shield via the Better Business Bureau (“BBB”), an alternative
    dispute resolution provider located in the United States. If you do not
    receive a timely acknowledgment of your complaint, or if your complaint is
    not satisfactorily addressed by us, please
    https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information
    and to file a complaint directly with the BBB.
 3. Further, your complaint can be made or referred to the U.S. Department of
    Commerce or the Federal Trade Commission for further investigation.
 4. For residual disputes that cannot be resolved by the methods above, you may
    be able to invoke a binding arbitration process under certain conditions. To
    find out more about the Privacy Shield’s binding arbitration scheme, please
    see: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

The Federal Trade Commission has investigation and enforcement authority over
our compliance with the Privacy Shield.


9. DATA SECURITY AND INTEGRITY

 

MediaMath implements appropriate technical and organizational measures to
safeguard personal data in our possession against being accidentally lost, used,
or accessed in an unauthorized way, altered, or disclosed. No transmission of
data over the Internet, however, is guaranteed to be completely secure. It may
be possible for third parties not under the control of MediaMath to intercept or
access transmissions or communications unlawfully. While we strive to protect
your personal data, we cannot ensure or warrant the security of any data you
transmit to us or that we collect about you. We have procedures in place to
address any suspected personal data breach, and if we are required by law, we
will notify you of any such breach.

MediaMath processes information in a way that is compatible with and relevant
for the purpose for which it was collected. To the extent necessary for those
purposes, we take reasonable steps to ensure that any information in our care is
accurate, complete, current, and reliable for its intended use. If you have any
questions about security on the Website or through the Platform, you can contact
us at privacy@mediamath.com.


10. DATA RETENTION

Retention of data collected on the platform

As described above, we process your personal data for different purposes, and
the length of time that we retain your personal data varies depending on the
processing purpose, the category of personal data and certain external factors.

We will retain the MediaMath ID and, where applicable, its association with
other devices for no longer than thirteen months from the last time we
encountered that MediaMath ID on your browser or device.

We will retain all other categories of personal data that we collect or receive
on the Platform, including Bid Request Data and Impression Data, Pixel Data and
Other Client Data, and Third-Party Segment Data and Other Third-Party Data, for
no longer than thirteen months, and we retain much of this data for shorter
periods of time. Furthermore, we may delete personal data in response to a
request from a user under applicable law, when requested to do so by our clients
or when contracts with our clients end. Also, most cookies set via the Platform
expire within thirteen months, while certain cookies that are not used for
tracking are refreshed for as long as such cookies are necessary for our
legitimate business purposes.

Retention of data collected on the Website and for marketing

If you provide us with your personal data on our Website or through other means
described above in Section 5, we will retain your information for as long as it
is necessary for our legitimate business purposes. For example, if you sign up
for an account or request information on the Website, we will retain the data
you provide for as long as we think you may have an interest in receiving
information from us. Similarly, we retain log files for as long as it is
necessary for our legitimate business purposes.

We retain the Pixel Data that we collect as described above in the section
“Retention of data collected on the Platform”.


11. YOUR LEGAL RIGHTS

 

MediaMath acknowledges that in some circumstances, you have certain rights under
data protection laws in relation to your personal data. Depending on where you
are located, these may include the right to access your personal data, correct
certain personal data, erase your personal data, object to certain processing of
your personal data, restrict certain processing of your personal data, receive
personal data in portable format, and not be subject to decisions based solely
on automated processing. To the extent required and permitted by applicable law,
we will provide you access to the personal data we hold about you and also allow
you to correct inaccurate information in certain situations (e.g., if you submit
your email address on the Website), delete your personal data, object to
processing, restrict certain processing of your personal data, port your
personal data or elect not to be subject to decisions based solely on automated
processing.

If you would like to exercise any of these rights, please send your request to
us at privacy@mediamath.com and we will respond to your request in accordance
with applicable laws.

In some circumstances, California residents have the following CCPA rights which
can be exercised as follows:

 

Right to know about your personal information which we collect, use, disclose
and/or sell
 * Email privacy@mediamath.com
 * Call us toll-free at 1-844-966-4636

Right to delete personal information which we have collected from you
 * Email privacy@mediamath.com
 * Call us toll-free at 1-844-966-4636

Right to opt out of the sale of your personal information
 * Email privacy@mediamath.com
 * Follow the instructions above in the section “Opt out of sale for California
   residents”
 * Call us toll-free at 1-844-966-4636

Right not to receive discriminatory treatment for exercise of CCPA rights
MediaMath does not discriminate against you if you choose to exercise your CCPA
rights.

 

In order to process your request, we may need you to provide additional
information to allow us to confirm your identity or the authority of any third
party submitting the request on your behalf. We do this as a security precaution
and to ensure that we do not disclose personal data to the wrong person.


12. HOW TO CONTACT US

 

If you have any questions about this Policy, including any request to exercise
your legal rights, and/or you have a disability which prevents you from
electronically accessing this Policy and require it to be provided in
alternative format, please contact us as follows.

 * If you are located in the United States or any other country outside of the
   EEA or UK:
   * By email to privacy@mediamath.com
   * By post to MediaMath, Inc., Attn: Melinda Clemans, 4 World Trade Center,
     45th Floor, New York, NY 10007.
   * If you are a California resident inquiring about the CCPA, you can also
     call our CCPA Helpline, toll free at 1-844-966-4636.
 * If you are located in the EEA or the UK, you can contact our data protection
   officer who is responsible for overseeing questions in relation to this
   Policy:
   * By email to privacy@mediamath.com
   * By post to MediaMath UK Ltd, Attn: Melinda Clemans, 230 Blackfriars Road,
     London, SE1 8NW

You have the right to lodge any complaints you have regarding our processing of
your personal data with a regulatory authority. We care about your privacy, and
we appreciate the chance to address your concerns before you do so.




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