Ad Platform Privacy Policy

TRUSTe

Effective Date: March 28, 2023

This privacy policy explains how xAd, Inc. dba GroundTruth (“we,” “us,” “our”) and our affiliates and subsidiaries collect, use, and share information via our mobile advertising service and mobile advertising landing pages (“Services”).

Overview of GroundTruth’s Services

GroundTruth is an advertising platform specializing in location powered ads. Our Services combine data, technology, and strategy to help advertisers reach the audiences most likely to be interested in their products or services.

If you visit a website, use a mobile application, or interact with an Internet-connected device of one of our platform members, that property will have its own privacy policy and practices. You will need to refer to the member’s privacy policy for information about their data collection and use practices.

GroundTruth adheres to the Digital Advertising Alliance’s (“DAA”) self-regulatory principles and the Digital Advertising Alliance Canada’s (“DAAC”) self-regulatory principles.

Data Collection & Use

We may collect various types of information from connected devices and web browsers using scripts, cookies, web beacons, software development kits (“SDK”), or other similar techniques. These technologies are used to collect digital actions of users that visit and use websites, applications, and connected devices or interact with ads presented on websites and devices of our platform members. We also receive other data (e.g., demographic information and digital identifiers) from third parties or through analytical techniques that we combine with the data we collect or derive through the Services.

The categories of data we collect or receive may include:

  • Digital identifiers, such as device identifiers and IP addresses;
  • Information about the browser and operating system type and version, device type, and other data from or about a device;
  • Purchase history and transactional data such as records of products or services purchased, obtained, or considered
  • Precise geolocation data;
  • Postal addresses; and
  • Information about users’ web viewing, application usage, and device usage information including what advertisements are interacted with.

We may collect or receive this data from a variety of sources, including over time across different mobile apps, websites, browsers, or Internet-connected devices. We may also receive data related to the location of a device from our platform members and other parties, such as consumer data resellers. We may also receive physical address information from our customers or other third parties, or we may derive address information from other location information we receive or collect from devices.

We may use any of the data we collect and receive for a variety of business purposes including analytics; auditing; research; reporting; attribution; detecting security incidents and illegal, deceptive, or fraudulent activity; service enhancements and other business operations; predicting possible relationships among different browsers and devices; differentiating and/or associating multiple device users as well as associating devices or users with locations such as a household or workplace; frequency capping and other auditing purposes; and in multiple ways to make ads more relevant across various connected devices, browsers, through direct mail, and any other advertising channel, such as by inferring potential interests based on web viewing, application use, location, and device usage activity for advertising purposes.

For instance, we may use location data for proximity or audience advertising. Proximity advertising uses location and other data to present ads based on a device’s current location. Another example would be using location and other data to create “audiences” – groups of Internet-connected devices that are inferred to share similar interests or other characteristics based on the information we collect – to deliver ads that we believe may be more relevant to those audiences through various advertising channels. We consider both proximity and audience advertising to be interest-based advertising as described in this policy. We retain data used for interest-based advertising only as long as we have a legitimate business purpose to retain such data, or as otherwise required by applicable law.

Choice

We use data collected across different devices and from non-affiliated websites, applications, and devices over time as well as other data described in this policy to provide advertising on behalf of our clients that is relevant to a device’s location and/or interests inferred from this data. This form of advertising is known as interest-based advertising. We may also partner with other ad companies to extend our audiences across different browsers, devices, and various other advertising channels for interest-based advertising purposes.

Mobile Device Choice: You may download the DAA’s AppChoices mobile app, or the TRUSTe mobile app, on your iOS or Android device in order to exercise choice regarding the collection of mobile application use activity for interest-based advertising on this device by us and other companies that participate in those choice tools. Links to those applications are below:

Location Data Choice: The DAA’s AppChoices tool can also be used to exercise choice regarding the collection and use of precise location data by GroundTruth for interest-based advertising purposes. iOS and Android users can limit our collection of precise location data from a device by turning location services off through the settings on that device.

Web Browser Choice: If you would like to exercise choice regarding our, and for other third parties that participate in the DAA Choice Page, collection of web viewing data from web browsers for interest-based advertising purposes on this device, click here.

When you make your choices on your browser or device using these choice tools, we will stop collecting and using data from that browser or device for interest-based advertising on it. We will also stop using data collected from that browser or device on other browsers or devices associated with it, and will stop using data collected from those associated browsers, devices, or elsewhere for interest-based advertising on the opted-out browser or device. We will also stop collecting and using data from that browser or device to inform relevant advertising that is sent to you via direct mail.

Note that electing to opt out from GroundTruth services will not stop advertising from appearing on your browser or device. It may make the ads you see less relevant to your interests. In addition, note that if you use a different browser or device, erase cookies from your browser, or reset your platform ad identifier, you may need to renew your opt-out choice. In addition, we may still collect data from browsers or devices for non-interest based advertising purposes such as for analytics and reporting purposes, operations, improving our services and frequency capping.

Data Sharing

We may share the various types of information we collect and infer about devices and users with our affiliates, third party partners and agents for advertisement targeting, audience extension across different browsers, devices and various other advertising channels, to make and create offers, for other marketing and advertising purposes, to provide reporting to advertisers and clients, to improve our systems and products, and for other research and analytical purposes.

We may also share data with contractors and service providers who work on our behalf. We may disclose data in response to subpoenas, court orders, or other legal process, or to establish or exercise our legal rights and obligations or defend against legal claims. We may also transfer data in the event of an acquisition or merger with another company, including at bankruptcy.

Children

Our services are not intended for children under the age of 13, and we do not knowingly collect information from children under the age of 13.

Website Privacy Policy

TRUSTe

Voluntarily Submitted Information on our Websites

This privacy policy applies to our corporate websites and explains how xAd, Inc. dba GroundTruth (“we,” “us,” “our”) and our affiliates and subsidiaries collect, use, and share information on www.groundtruth.com, or other websites we control that link to this policy (collectively “Website”). By using the Website you agree to the terms of this Privacy Policy.

Information Collection & Use:

Personal Information

When you use the Website, you may encounter areas that allow you to voluntarily enter personal information, which includes contact information such as your name, email address, telephone number, and mailing address.

You may provide this information to us when you sign up for our newsletter, request information about products, apply for a job, fill out surveys, or otherwise provide personal information to us.

We may use personal information for, among other things:

  • Internal record keeping and auditing;
  • Communicating with you about site updates and your inquiries, as well as offer products, content, and services that we believe may be of interest to you;
  • Customizing the Website;
  • Verifying customer information; and
  • For purposes disclosed at the time of collection.

If you would prefer not to receive communications from us in the future, please follow the unsubscribe instructions available in each communication.

We may retain your information for as long as necessary to fulfill a legitimate business need, such as to provide you with information or services, comply with our legal obligations, resolve disputes and enforce our agreements.

Usage Information

When you browse our Website we may also collect various types of usage information about your browser or device, including, but not limited to, online identifiers such as your IP address and your mobile device identifier, as well as information about your internet activity such as the web pages visited, links clicked, and your operating system and browser type. We and our partners may automatically record real-time session information generated in the course of your interactions with the Website, such as mouse movements, clicks, page visits, text entered, how long you spent on a page, and other details of your actions on the Website. Such information is used for the purpose of operating, debugging, and improving our Website, analyzing demographic and statistical research about website usage, customizing offers, and to monitor the Website for compliance with our terms of service and the law, to detect security incidents and malicious, deceptive, fraudulent, or illegal activity, as well as other purposes. This usage information may be collected through various technologies, including but not limited to “cookies” when you visit the Website. For more information, please see the “Tracking Technologies” section below.

Information Sharing

We will not sell, rent, license, trade or disclose your contact information collected through our Websites to an unaffiliated third party, except with your permission or for circumstances described in this policy. We may share or disclose personal and usage information in certain circumstances, including sharing with:

  • Service providers that perform a business function for us for purposes like CRM management and infrastructure support;
  • Our subsidiaries and affiliates;
  • Entities, such as government agencies, as required by a court order, subpoena, warrant, or when otherwise required by law;
  • Entities as part of a sale or merger of all or part of our business, including at bankruptcy;
  • Third parties for our direct marketing purposes; and
  • Entities to protect our rights and the rights of third parties.

The Website may contain links to third party websites that we do not control, and to which this privacy policy does not apply. We encourage you to read the privacy policy of every website you visit.

Security

We follow generally accepted standards to help protect the personal information submitted to us, both during transmission and once it is received.

Update Personal Information

If you wish to access, update or request deletion of the personal information you have previously provided to us through this website, such as your email or phone number, you may do so by writing us at requests@groundtruth.com stating that request. We will respond to your request within a reasonable timeframe.

Tracking Technologies

GroundTruth and our partners use cookies, session replay, or similar technologies to analyze trends, administer the Websites, collect information about use of the Websites, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Website or service. To manage Flash cookies, please click here.

We use Google Analytics to better understand how visitors interact with our Websites. This service provides usage information including but not limited to data on where visitors came from, what actions they took on our Websites, and where visitors went when they left our Websites. We use this information to improve your experience when visiting our Websites. Please click here to learn more about this service and how to opt out of data collection by Google Analytics.

Digital Advertising

We may partner with ad networks and other ad serving providers (“Advertising Providers”) who serve ads on behalf of us and others on non-affiliated sites. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your visits to this site and elsewhere on the Internet over time, as well as from various mobile applications you use, across different devices.

You may visit www.aboutads.info to learn more about this type of advertising and how to opt-out of this type of advertising by companies participating in the Digital Advertising Alliance self-regulatory program. Additionally, if you would like to opt-out of this type of advertising in mobile apps, you can visit here and download the opt-out app for your device.

GroundTruth adheres to the Digital Advertising Alliance’s Self-Regulatory Principles. Note that electing to opt out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests. In addition, note that if you use a different browser or erase cookies from your browser, you may need to renew your opt-out choice. You can also opt out of browser-based interest-based advertising by us and other companies that offer choice by clicking here, or if located in the European Union you can click here to make choices with respect to companies integrated in the YourOnlineChoices consumer choice platform.

Children

This Website is not intended for the use of children under the age of 13. We do not knowingly collect personal information from children under the age of 13.

U.S. States Privacy Rights

This section contains disclosures required by the laws in California, Colorado, Connecticut, Utah, and Virginia (“Certain States”). If you are a resident of such states, this section of the Privacy Policy contains disclosures required by law and explains rights that may be available to you. Our use of the terms “sell” and “share” below generally refers to these California definitions. Consumers with disabilities may access this notice by utilizing standard screen readers.

Personal Information We Collect, Process, Disclose, Sell/Share. We collect the categories of personal information identified in the chart below for the specified purposes. As further set forth in the chart below, in the past 12 months, we have disclosed and sold personal information to third parties for business or commercial purposes.

Categories of Personal Information

Categories of sources from which information is collected:

Business purposes for collection, use, and sharing:

Disclosed for business purposes to the following categories of third parties:

Sold to the following categories of third parties:

Personal identifiers (such as first and last name, email address)

Customers (agencies and advertisers);
Ad inventory supply partners (Publishers);
Service providers;
Consumer data resellers; and
Other third party partners

Marketing;
Legal compliance;
Performing services (for us or our service providers) such as account servicing, processing orders
and payments;
and
Other one-time uses.

Service Providers

This information was not sold in the past 12 months to third parties

Online identifiers (such as unique online identifiers)

Consumers;
Customers (agencies and advertisers);
Ad inventory supply partners (Publishers);
Service providers;
Consumer data resellers; and
Other third party partners

Advertising;
Marketing;
Targeted advertising; Data analytics and insights; Measurement;
Attribution;
Reporting and fraud prevention;
Auditing;
Legal compliance;
Detecting and protecting against security incidents, fraud, and illegal activity;
Debugging;
Performing services (for us or our service providers) such as account servicing, processing orders
and payments;
Internal research for technological improvement;
Internal operations;
Activities to develop, maintain and improve our products and services; and
Other one-time uses.

Service Providers

Advertising networks;
Measurement companies;
Publisher partners;
Data analytics providers;
Companies to which we provide our products and services.

Demographic Information  (such as gender)

Consumers;
Ad inventory supply partners (Publishers); and
Consumer data resellers; and
Other third party partners

Advertising services and advertising products; Targeted advertising;
Data analytics and insights;
Measurement;
Attribution;
Reporting and fraud prevention;
Legal compliance;
Detecting and protecting against security incidents, fraud, and illegal activity;
Debugging;
Performing services (for us or our service providers) such as account servicing, processing orders
and payments;
Internal research for technological improvement;
Internal operations;
Activities to develop, maintain and improve our products and services; and
Other one-time uses.

This information is not disclosed to third parties in the past 12 months.

Advertising networks

Commercial or transactions information (such as records of products or services purchased, obtained,
or considered)

Data resellers; and
Other third party partners

Advertising;
Marketing;
Targeted advertising; Data analytics and insights; Measurement;
Attribution;
Reporting and fraud prevention;
Auditing;
Legal compliance;
Detecting and protecting against security incidents, fraud, and illegal activity;
Debugging;
Performing services (for us or our service providers) such as account servicing, processing orders
and payments;
Internal research for technological improvement;
Internal operations;
Activities to develop, maintain and improve our products and services; and
Other one-time uses.

Commercial or transactions information (such as records of products or services purchased, obtained,
or considered)

Data resellers; and
Other third party partners

Internet or other electronic network activity information (such as browsing history, search history,
interactions with a website, email, application, or advertisement)

Consumers;
Consumer data resellers; and
Other third party partners

Advertising services and advertising products; Targeted advertising;
Data analytics and insights;
Measurement;
Attribution;
Reporting and fraud prevention;
Legal compliance;
Detecting and protecting against security incidents, fraud, and illegal activity;
Debugging;
Performing services (for us or our service providers) such as account servicing, processing orders
and payments;
Internal research for technological improvement;
Internal operations;
Activities to develop, maintain and improve our products and services; and
Other one-time uses.

Service Providers

Companies for which we provide advertising services

Geolocation information

Consumers;
Customers (agencies and advertisers);
Ad inventory supply partners (Publishers);
Service providers;
Consumer data resellers; and
Other third party partners

Advertising services and advertising products; Targeted advertising;
Data analytics and insights;
Measurement;
Attribution;
Reporting and fraud prevention;
Legal compliance;
Detecting and protecting against security incidents, fraud, and illegal activity;
Debugging;
Performing services (for us or our service providers) such as account servicing, processing orders
and payments;
Internal research for technological improvement;
Internal operations;
Activities to develop, maintain and improve our products and services; and
Other one-time uses.

Service Providers;
Analytics providers

Companies for which we provide advertising services

Inferences drawn from the above information about your predicted characteristics and preferences

Service providers;
Other third party partners

Advertising services and advertising products; Targeted advertising;
Data analytics and insights;
Measurement;
Attribution;
Reporting and fraud prevention;
Legal compliance;
Detecting and protecting against security incidents, fraud, and illegal activity;
Debugging;
Performing services (for us or our service providers) such as account servicing, processing orders
and payments;
Internal research for technological improvement;
Internal operations;
Activities to develop, maintain and improve our products and services; and
Other one-time uses.

Service Providers

Advertising/marketing companies; Advertising networks; and Companies for which we provide advertising
services

Other information about you that is linked to the personal information above

Consumers;
Customers (agencies and advertisers);
Ad inventory supply partners (Publishers);
Consumer data resellers; and
Other third party partners

Advertising services and advertising products; Targeted advertising;
Data analytics and insights; Measurement;
Attribution;
Reporting and fraud prevention;
Legal compliance;
Detecting and protecting against security incidents, fraud, and illegal activity;
Debugging;
Performing services (for us or our service providers) such as account servicing, processing orders
and payments;
Internal research for technological improvement;
Internal operations;
Activities to develop, maintain and improve our products and services; and
Other one-time uses.

This information is not disclosed to third parties in the past 12 months.

Advertising networks.

Employee and job applicant data, which may include the categories of personal information listed
above that are collected during the job application process and while individuals are GroundTruth
employees

Consumers; service providers; and other third party partners

Processing your application.
Using your information in connection with your employment roles and responsibilities. This includes,
for example:

  • Providing you with services and tools to use in connection with your employment, such as email
    service and information technologies;
  • Responding to your requests;
  • Maintaining compliance with our policies and procedures;
  • Paying you and administering your employment benefits, including those provided to other
    individuals like family members; and
  • Responding to emergencies or safety concerns, such as by maintaining and using your emergency
    contact information.

Other business purposes, which include:

  • Auditing related to our interactions with you;
  • Legal compliance;
  • Detecting and protecting against security incidents, fraud, and illegal activity;
  • Debugging;
  • Performing services (for us or our service providers) such as account servicing, processing
    orders and payments, and analytics;

Internal research for technological improvement;

  • Internal operations;
  • Activities to maintain and improve our business; and
  • Other one-time uses.

Service providers

This information was not sold in the past 12 months to third parties

Information Retention. We will retain each category of personal information we collect in accordance with applicable laws and as reasonably necessary for our processing purposes set out under this Privacy Policy.

Rights Regarding Personal Information. Residents of Certain States have certain rights with respect to the personal information collected by businesses. You may exercise the following rights regarding your personal information, subject to certain exceptions and limitations contained in the relevant state law:

  • The right to confirm whether we process personal information about you.
  • The right to correct inaccuracies in the personal information we have collected about you.
  • The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information;
  • The right to request that we delete the personal information we have collected from you or maintain about you.
  • The right to opt out of (i) the sharing of personal information for targeted advertising or (ii) the sale of personal information. Please note that if you opt out of certain types of sales, we may be unable to provide you with the services that rely on such sales. Additionally, we do not knowingly sell or share personal data of individuals under 16.
  • Depending on your state, the right to receive a portable and readily usable copy of the personal information we have collected about you, to the extent feasible.
  • Depending on your state, the right to limit our processing of certain “sensitive” personal information (or to withdraw consent for such processing if you previously gave it).
  • The right not to receive discriminatory treatment for the exercise of these privacy rights.

To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:

We do not use or disclose sensitive personal information for purposes other than as permitted under the CCPA.

We may require additional information from you to verify your identity before responding to your request. That verification process can be found here. You may designate an authorized agent to make a request on your behalf. To do so you will need to provide the agent with signed written permission to act on your behalf. We do not knowingly sell the personal information of minors under 16 years of age.

For Colorado, Connecticut, or Virginia residents, if you have submitted a request that you feel we have not reasonably fulfilled, you may contact us to appeal our decision by sending an email to privacyrightsappeals@groundtruth.com

In the previous calendar year, GroundTruth:

  • Received 0 requests to know
  • Received 0 request to delete
  • Received 33,509 request to opt out of data sale, complied in whole or in part with 33,509 of them, and denied 0 of them.

The median number of days within which GroundTruth substantively responded to California consumers’ requests to know, requests to delete, and requests to opt out in the previous calendar year is 1 day.

Privacy Policy Changes

We may update this privacy policy to reflect changes to our information practices. If we make any material changes with respect to our practices relating to your personal information, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

If you have questions or complaints regarding our privacy policy or practices, please contact us at:

Global Headquarters
One World Trade
60th Floor
New York, NY 10007
privacy@groundtruth.com

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at www.feedback-form.truste.com/watchdog/request.

Privacy Policy Last Updated:
March 28, 2023