This Privacy Policy explains how Real Audiences LLC (“Real Audiences”, “we”, “us” or “our”) collects, uses and discloses information in connection with the Real Audiences hosted, on-demand, web-based real-time bidding platform (the “Hosted Service”) and the websites we operate (collectively, the “Website”).
It is derived from, and should be read together with, the Real Audiences Advertiser Agreement. By using the Hosted Service, you agree to Real Audiences’ collection, use and disclosure of personally identifiable information in accordance with this Privacy Policy.
Capitalized terms used but not defined here have the meaning given to them in the Real Audiences Advertiser Agreement.
1. Information we collect
- User Data. Any data that Real Audiences collects during the delivery of Ads or the performance of its obligations under the Advertiser Agreement, including End User device information, End User session-based browsing behavior, number of impressions, http header information, and any other data that an Advertiser elects to provide to Real Audiences.
- User Volunteered Data. Personally identifiable information of End Users collected by an Advertiser or a Third Party Advertiser via an Ad. Where an Advertiser enables this collection, it is done solely on behalf of that Advertiser (and not Real Audiences), and such data is the property and Confidential Information of the Advertiser or its Third Party Advertiser, subject to their posted privacy policies.
- Account and identity information. Information provided to open and operate an Account, place Orders and make payments — such as contact information, payment details, and information used to validate identity. Real Audiences may ask for further information, require confirmation of ownership of the email address provided, order a credit report, or verify information against third-party databases or other sources.
- Confidential Information. Information and data made available through the Hosted Service (including publisher information, publisher website statistics and inventory prices), Advertiser Content, and nonpublic business, financial, product and technical information exchanged between the parties.
2. Tracking technologies and measurement
- Pixels, scripts and tags. The Real Audiences Code includes pixels and scripts (for conversion and click-through tracking), ad tags and impression counting, and APIs for programmatic media buying and reporting.
- Measurement. Real Audiences determines in its sole discretion how to measure impressions, inquiries, conversions, clicks, offers, installations and other actions taken by third parties in connection with Ads, and all payments are based on those measurements. Any third-party tracking tool, script, SDK or code used by an Advertiser or other third party does not bear on Real Audiences’ measurement, and Real Audiences has no liability for malfunctions or discrepancies in such third-party data.
3. How we use information
- Providing the Hosted Service. To match Ads with Inventory through real-time bidding, deliver and route Ads, provide reports of advertising requests, impressions and related data, and bill for Orders.
- Internal business purposes. Real Audiences may use User Data for its internal business purposes, so long as such use complies with all applicable privacy policies, laws, rules, regulations and industry self-regulatory regimes relating to the collection, use and disclosure of such information, and provided it obtains any consents, authorizations and clearances from End Users that may be required.
- Identity and credit verification. To validate identity and assess creditworthiness, Real Audiences may perform credit checks with, and obtain information about an Advertiser from, credit reporting agencies, banks and other similar sources.
- Marketing. Either party may include the name and logo of the other in customer or vendor lists.
4. How we disclose information
- As required by law. Real Audiences may disclose information as required by law or legal process, or pursuant to the order or requirement of a court, administrative agency or other governmental body (with reasonable notice to the other party where permitted so it can contest the order).
- Aggregated and de-identified data. Real Audiences may use and disclose information when it is aggregated with similar information relating to other Real Audiences customers or End Users and when it does not specifically identify the Advertiser or End User.
- Service providers and advisers. Real Audiences may disclose Confidential Information to its employees, subcontractors and advisers who need to know it for the purposes of the Advertiser Agreement, each subject to written use and disclosure restrictions at least as protective as those in the Agreement, and on a confidential basis to legal or financial advisors and to current or prospective investors or acquirers.
- Corporate transactions. Real Audiences may assign its rights and obligations, and transfer related information, in connection with a merger, consolidation, reorganization, change of control or sale of all or substantially all of its related assets.
5. Data security
- Safeguards. Real Audiences will take commercially reasonable administrative, physical and technical measures to safeguard the security of Advertiser Content, and will treat such information in accordance with this Privacy Policy. Real Audiences warrants that the Hosted Service will not knowingly contain or transmit computer viruses or other harmful or malicious code.
- Account security. Advertiser is solely responsible for the security of its Account(s), including its password(s), and for the activities of any person accessing the Hosted Service using an Account, whether authorized or not.
- No guarantee. No method of transmission or storage is completely secure, and availability of the Hosted Service is not guaranteed.
6. Confidentiality
- Confidential Information. Each party protects the other party’s Confidential Information using all reasonable efforts — no less than the efforts it uses for its own proprietary information of similar nature and importance — and uses it only as necessary to exercise its rights or perform its obligations under the Advertiser Agreement.
- Exclusions. Confidential Information does not include information that is or becomes generally known to the public without breach, was known to the receiving party before disclosure without breach, is independently developed without breach, or is received from a third party without breach.
7. Advertiser and End User responsibilities
- Advertiser obligations. Advertiser must comply with all applicable privacy policies of the publishers of the Inventory, is solely responsible for all aspects of dealing with End Users and Third Party Advertisers, and must correctly install and use Real Audiences-provided conversion pixels in the manner specified.
- Disclosure to End Users. If an Advertiser enables the collection of any User Volunteered Data via Ads, it must expressly disclose to the individual End User that such collection is solely on behalf of the Advertiser and not Real Audiences, and must obtain any consents, authorizations and clearances from End Users that may be required.
8. Changes to this Privacy Policy
- Updates. Real Audiences may change this Privacy Policy on a going-forward basis at any time. Where a change materially modifies your rights or obligations, Real Audiences will make reasonable efforts to notify you — for example through a pop-up or banner within the platform, by email to an address used to register the Account, or through similar mechanisms. We encourage you to review this page periodically.
9. Contact
- Notices. Notices to Real Audiences may be sent in writing by email to legal@realaudiences.com. Questions about this Privacy Policy or Real Audiences’ data practices can be directed to the same address.
This Privacy Policy summarizes the privacy-related provisions of the Real Audiences Advertiser Agreement. Where there is any conflict, the Advertiser Agreement, as it may be updated from time to time, governs.
