AU Ratings Privacy Policy

1. Overview

Adelaide Metrics Inc. (“us”, “our”, or “we”) wants you to be familiar with how we collect, use and disclose information from and about you. This Privacy Policy explains how we and any other digital properties that display authorized links to this policy (“us”, “our”, or “we”) use information when you interact with Adelaide’s attention measurement tracking technology, which is used to create our attention metrics product, AU Ratings (“AU Ratings” and/or “Technology Services”). When we handle personal information, we typically act as a service provider and/or data processor on behalf of our customers. However, there are limited circumstances in which we will collect and process certain personal information directly from individuals as further addressed in this Privacy Policy. If you are a California resident, please see the California Consumer Privacy Act Notice in Section 9 below. If you are a European Data Subject, please see Section 12 below about European Data Subjects.

For our privacy practices surrounding our website and corporate operations, please visit our website privacy policy here: https://www.adelaidemetrics.com/privacy

2. How Do We Collect Personal Information

From devices you use when you interact with us or our customers online. This includes information collected through our Technology Services and automatically.      

From third parties. This includes information collected from third parties, such as certain platform/CTV measurement partners.

3. The Types of Personal Information We May Collect From You

Depending on how you interact with our Technology Services, we may collect the following information:

• Activity Information, such as information we collect when you access and interact with our Technology Services and/or our customers’ or partners’ services, including device type, and IP address.
• Location Information, collected through our Technology Services, such as country, city, designated market area, and zip code.
• Inferences, such as inferences drawn from any of the personal information identified and discussed in this Privacy Policy.

4. How We Use Your Personal Information

We may use your information for the following reasons, depending on your relationship with us:

• To provide, support, and develop our products and services, including to troubleshoot; and conduct data analysis and testing. We may also aggregate, anonymize, and/or deidentify personal information we collect and use it for any purpose, including product development and improvement activities.
• To understand how individuals interact with the media that our Technology Services measure and analyze.
• To maintain the integrity of our Technology Services.
• To debug our Technology Services.
• To comply with legal requirements and/or to investigate or address claims or disputes relating to your exposure to our Technology Services. This would include the use of your information to comply with our legal and regulatory obligations, to defend ourselves in litigation and investigations, and to prosecute litigations.
• To conduct internal business purposes, including for data analysis, and enhancing our services.

5. How We Disclose Personal Information

We may disclose some or all of the personal information collected from or about you with any of the following entities and for any of the following purposes:

• Government, regulatory, or law enforcement agencies. We reserve the right to disclose your information to respond to valid information requests from government authorities and judicial requests, to investigate potential fraud, or where otherwise required by law. We may disclose your personal information where we believe the disclosure is necessary or appropriate to comply with regulatory or legal requirements, or to protect the safety, rights, or property of ourselves and others and to exercise, establish, or defend our legal rights.
• In connection with a merger, acquisition, or business transfer. If we sell all or a part of our business, are part of a merger, consolidation, restructuring, and/or sale of assets or other corporate change, your information may be transferred as part of that transaction.
• Aggregate Data. We may disclose your personal information in an aggregated or non-identifying form or otherwise in a form that cannot reasonably be used to identify you.

6. Children’s Privacy

Our Technology Services reach a general audience as determined by our clients, and do not knowingly target or collect personal information from children under 18 years of age.‍

7. Third Party Websites and Content

We measure advertising media running on websites and other third party content that are not owned or operated by us. The websites and third party content which we measure may have separate privacy notices or policies. We are not responsible for the privacy practices of these third party websites and content.  If you provide any personal information through a third party site, your interaction and personal information will be collected by and controlled by the privacy policy of that third party website and content. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this Privacy Policy.‍

8. Information Security

We use commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in its possession against loss, theft, unauthorized use, disclosure, or modification. However, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the internet. We cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to us, you do so at your own risk.     ‍

9. California Consumer Privacy Act Notice

This section provides information for California residents. Under the California Consumer Privacy Act (“CCPA”), and for purposes of this Section, “Personal Information” generally means information that identifies, relates to, or describes a resident in California. As noted above, when we handle Personal Information belonging to California residents, we typically act as a Service Provider under the CCPA on behalf of our customers. However, there are limited circumstances in which we will collect and process certain Personal Information directly from California households. We do not reidentify Personal Information that has been deidentified. Under the CCPA, and for purposes of this Section, “Personal Information” generally means information that identifies, relates to, or describes a California resident. Personal Information does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been deidentified or aggregated; or other information covered by certain sector-specific privacy laws, as consistent with applicable law.  Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy.

‍a. Categories of Personal Information Collected and/or Disclosed

‍The categories of Personal Information that we collected and disclosed are below, along with the purposes for processing, and categories of third parties to whom each category of Personal Information was disclosed. Our Technology Services do not sell/share personal information as defined by the CCPA, including for children under 16 years of age. Additionally, depending on how you interact with our Services, we may not have processed Personal Information about you for each (or any) of these purposes. We have provided detailed descriptions below on the data collection, use, and disclosure practices.

Please note that we may process Personal Information in each of the above categories in order to protect our and others’ rights, and/or to complete a merger or sale of assets or other corporate transaction.

Sensitive Personal Information.  We do not process “sensitive” Personal Information.

Data Retention.  We will retain Personal Information from or about you as reasonably necessary and proportionate to achieve the purpose(s) for which the Personal Information was collected or processed as outlined in this Section unless a longer retention period is required or allowed by law.

Purposes

We may use this Personal Information for the following purposes, including commercial purposes:

• to operate, manage, and maintain our business;
• to provide our Technology Services;
• to accomplish our business purposes and objectives;
• to develop, improve, repair, and maintain our Technology Services;
• to conduct analytics;
• to take quality assurance measures;
• to detect and prevent fraud;
• to conduct audits and other internal functions;
• to comply with the law, legal process, and internal policies;
• to maintain records; and
• to exercise and defend legal claims.

Depending on your interactions with us, we may not have used Personal Information collected about that household for each or any of these purposes.

‍Sources of Personal Information

In general, we only collect Personal Information that is reasonably necessary for and proportional to the purposes for which we process it. We collect this Personal Information directly from California households themselves through their devices. All sources of Personal Information collected are noted in the “How Do We Collect Personal Information” and “The Types of Personal Information We May Collect From You” sections above.

Your Privacy Rights Under California Law

California residents have certain rights with respect to their Personal Information.

Adelaide Technology Services collect information only on the household level. Under the CCPA, the obligations imposed on businesses regarding the right to access, deletion, and correction do not currently apply to household data. Additionally, Adelaide Technology Services do not sell or share Personal Information as defined by the CCPA. If you are a California resident, however, and would like to exercise certain rights with respect to your use of our website, please visit our website’s privacy policy.

Non-Discrimination: You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.‍

10. International Data Transfers

We are based in the United States. Any information you provide to us through exposure to the Technology Services may be stored and processed, transferred between, and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside.  We may need to send your personal information overseas as part of our normal business operations.  Provided the data protection laws of these other countries differ from those in the United States, please be assured that we take reasonable steps to ensure that your privacy is protected.

11. Updates to the Policy

We may update this policy from time to time. To the extent permitted by law, any changes to our Privacy Policy will be posted to the website and will become effective upon posting. Any changes will be effective only after the effective date of the change and will not affect any dispute arising prior to the effective date of the change.‍

12. European Data Subjects

Adelaide’s AU Ratings do not process personal data as defined by the General Data Protection Regulation (GDPR) or similar European laws (such as the UK GDPR). Similarly, as characterized by the ePrivacy Directive and similar European laws, AU Ratings do not use cookies or similar technologies on devices, or gain access to information already stored on your device.‍

13. Contact Us

We welcome all requests, suggestions and questions concerning our limited use of your Personal Information. All such communication should be directed to privacy@adelaidemetrics.com or you can send correspondence to us at the following address:

Adelaide Metrics Inc.
Attn: Data Privacy Officer
228 Park Ave S, PMB 29029
New York, New York 10003-1502 US

‍