Effective date: January 1, 2011
Last update: August 15, 2019
Privacy Practices for the Website
The Website is used for providing business information to prospective clients and business partners. It also serves as a marketing vehicle for Division-D. Division-D is committed to respecting your privacy and conducting business matters that follow all policies as required by law.
Collection and Use of “PII” (Personally Identifiable Information) on the Website
Personally identifiable information is only collected when you choose to provide it to Division-D, such as in an email or by completing a form on the Website. The Website does contain a contact page where you can contact Division-D personnel and request additional information. This PII may include: name, company name, address, telephone number or email address. This information is only used by Division-D to contact you in response to your inquiry, conduct business activities with you, provide customer service and provide new products and services to existing and prospective customers. While Division-D may use the information it collects to notify you of necessary changes to the Website, new services/offerings and unique opportunities, you can contact Division-D at any time if you do not wish to receive these notices by emailing Division-D at firstname.lastname@example.org.
Collection and Use of “Non-PII” (Non-Personally Identifiable Information)
Division-D also collects Non-Personally Identifiable Information (“Non-PII”) from visitors to this Website. Non-PII is information that cannot by itself be used to identify a particular person or entity, and may include your IP host address, pages viewed, browser type, Internet browsing and usage habits, Internet Service Provider, domain name, the time/date of your visit to this Website, the referring URL and your computer’s operating system.
This Website uses Google Analytics to help analyze how users use the Website. The tool uses “cookies,” which are text files placed on your computer, to collect standard Internet log information and visitor behavior information in an anonymous form. The information generated by the cookie about your use of the Website (including IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the Website and to compile statistical reports on Website activity for Division-D.
Cookies and Other Tracking Technologies
Privacy Practices for the Network
Division-D operates a virtual advertising network (the “Network”) where we direct 3rd party technology platforms (our “Partners”) to help advertisers (our “Clients”) find the right digital audience and to help website and mobile application publishers (our “Publishers”) do a more effective job monetizing their content. Division-D does not physically store any data via our Network. Rather, we purchase media on behalf of our Clients and engage our Partners to serve the ads and provide additional services pursuant to ensuring the media we buy for Clients from our Publishers. We adhere to the Digital Advertising Alliance Code to the extent that it is applicable to our business.
Collection of Information via the Network
Division-D doesn’t physically store information directly via the Network. Rather, information is collected and processed by our Partners pursuant to their privacy policies. We encourage you to read our Partners’ privacy policies. Generally, these partners collect Non-PII including but not limited to browser type, operating system, Internet Service Provider, IP address, and basic ad serving information such as the time and date an ad is served, the name of the mobile app or URLs from the web page visited. Some Partners work with us and our Clients to enable our Clients to bring their offline data into our systems for use by our technology.
Cookies and Tracking Technologies
Division-D provides you with choices regarding how your data is processed. You can request the PII that Division-D has collected about you, correct factual inaccuracies in information, remove personal information and/or update your personal information by contacting email@example.com.
While Division-D doesn’t directly process data via the Network, many of our Partners provide choices regarding how information is collected or used on the Network. Each of these opt-out mechanisms are designed to enable you to exercise choice as is applicable for each Partner:
• LKQD Platform - https://ad.lkqd.net/optout/optout.html
• SpringServe - https://springserve.com/opt-out/
In general, in order for any of these tools to work on your computer, your browser must be set to accept third party cookies. If you buy a new computer, change web browsers or delete this cookie, you will need to perform the opt-out task again.
You may also visit the Digital Advertising Alliance’s (DAA) website and use the opt-out procedure, which can be used to opt-out from the use of data for interest based advertising purposes from digital advertising companies, including many of our Partners. To access this service, please visit the DAA at: https://www.aboutads.info/choices/.
The NAI also provides a mechanism to opt out of its member networks here: https://www.networkadvertising.org/managing/opt_out.asp and the European Digital Advertising Alliance opt-out page may be found at https://youronlinechoices.com/.
If you are looking to exercise choice regarding your mobile device, please visit the NAI’s Mobile Choice information page at https://www.networkadvertising.org/mobile-choice/ and follow their instructions.
Onward Transfer of Information
We do not share PII collected via the Website with anyone outside of Division-D, unless specifically stated otherwise. Division-D does not sell, rent or lease such PII collected on the Website to non-affiliated third parties without your consent. We don’t generally share PII provided from Clients, Publishers or Partners other than with our agents and service providers who are bound by confidentiality provisions. In the context of an onward transfer, Division-D is responsible for the processing of personal data it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Division-D shall remain liable under the Principles if its agent processes such information in a manner inconsistent with the Privacy Shield Principles, unless Division-D proves that it is not responsible for the event giving rise to the damage.
Division-D may share information for the following purposes: (i) to enable third party service providers to assist or facilitate in the services Division-D provides; (ii) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information Division-D receives, whether or not a response is required by applicable law, and to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Access, or as otherwise required by law; (iii) for law enforcement or national security purposes including sharing data of EU and Swiss individuals in response to lawful requests from public authorities to meet national security and law enforcement requirements; (iv) to enforce an agreement or to protect Division-D’s rights; with any parent, affiliated or successor entity; (v) in connection with any asset sale, transfer, divestiture, bankruptcy or liquidation; (vi) in connection with strategic alliances, partnerships or other business arrangements to permit the offering of products or services Division-D believes may be of interest to you or where Division-D has determined that the information will be used in a responsible manner by the third party; or (vii) as permitted under any agreement with you. Division-D may also share aggregated data with others.
While our Partners may provide Division-D, our Publishers and our advertising Clients with reports pertaining to advertising campaigns, neither Division-D, our Publishers nor our Clients have access to IP addresses, cookie IDs or other forms of pseudonymous data via the Network, although Publishers and Clients may obtain this data independent from the Network. To the extent that our partners may transfer data across international borders, they are required by law to have an appropriate data transfer mechanism such as membership in the Privacy Shield program.
Division-D is respectful and keenly aware of the privacy rights of children. Division-D’s products and services are not intended for persons under 18 years of age and the Website is not directed to children. Division-D does not knowingly solicit or collect any PII from children under the age of 18, nor knowingly markets Division-D products and services to children under this age. If you are a parent and are aware that your child has provided Division-D with PII without your knowledge or consent, please contact us immediately at firstname.lastname@example.org.
Data Subject Access Rights
You can request the PII that Division-D has collected about you, correct factual inaccuracies in information, remove personal information and/or update your personal information by contacting email@example.com. Some of the Non-PII collected on behalf of the Network is considered personal data under EU Data protection laws. While Division-D doesn’t place cookies nor process any data directly on the Network, interested persons may contact our Partners to see what type of access rights they offer.
Division-D uses appropriate measures to ensure the security of all information, including the use of passwords, firewalls, encryption and remote servers, and routinely evaluate our practices to identify security threats or opportunities for the improvement of our services. No transmission of information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. You acknowledge and agree to assume this risk when communicating with us.
European Economic Area
The General Data Privacy Regulation (“GDPR”) affords additional data protection rights to EU data subjects. For example, with respect to EU data subjects, the definition of personal data includes pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID. EU Data subjects have the right to complain to EU Supervisory Authorities and the right to access, port, correct and delete certain personal data processed by Division-D (e.g., via the Website) and those Partners that serve ads on our behalf to EU data subjects via the Network. You may access those rights with respect to Division-D by scrolling up and reading the section entitled “Data Subject Access Rights” or by sending us an email at firstname.lastname@example.org.
While Division-D does not physically store personal data in the context of our Network, we do have Clients located in the EU and we do place media buys on behalf of Clients which may collect data from data subjects located in the EU. Our Clients and Publishers direct us to process data under their general instructions but we may direct our technology Partners to adjust advertising campaigns where we feel appropriate. We rely on the consent of the individual to process personal data in some instances (for example, when the user inputs personal data onto a web form of our Website). On other occasions, Division-D may process personal data when needed to fulfill a contract with a Client or partner or where required to do so by law.
We may also process data when it is in our or our Clients’ legitimate interests to do this and when these interests are not overridden by the individual’s data protection rights (which may vary based on an individual’s jurisdiction). Certain Publishers, Clients and Partners choose not to operate in the EU and/or collect data from EU data subjects – and each has a process to ensure they are not collecting personal data from the EU on the Network.
In compliance with the Privacy Shield Principles, Division-D commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact email@example.com.
We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you. If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
If you have any questions or concerns about your privacy in connection with this policy, please send us a thorough description to firstname.lastname@example.org and we will try to resolve it. You may also contact us by mail at:
Attn: Privacy Officer
602 Fay Street
Columbia, MO 65201