DATONICS TECHNOLOGY PRIVACY POLICY

Last Updated:  Februar 2nd, 2024

Datonics (“we”, “us”, “our”) is a New York-based advertising technology company that provides a service to website publishers and other advertising companies to enable such other companies to provide consumers (“Users”) with relevant ads on their computers and mobile devices.

So that we may help you to understand how our technology works, and to allow you to exercise your privacy preferences, we offer this Technology Privacy Policy. For information about the information collected and used from this website, https://www.datonics.com/, and not our services, please see our website privacy policy.

Datonics is a member in good standing of the Network Advertising Initiative (“NAI”). Datonics is considered a “data broker” under certain state privacy laws.

Users located in California and certain other states with comprehensive consumer privacy laws have specific rights regarding their personal information.  Please see the CALIFORNIA PRIVACY RIGHTS and OTHER STATE PRIVACY RIGHTS sections below.

For more information about how users with disabilities can access this Technology Privacy Policy in an alternative format, please contact us at privacy@datonics.com.

What types of information does Datonics collect?

In order to increase the relevance of online advertisements, our technology collects or we license from third parties “personal information”, which is information that directly or indirectly identifies, relates to, describes, or can be associated with a specific person. The precise definition of personal information (sometimes called personal data) may vary depending on your place or residence, but we take the same general approach to protecting your privacy, subject to any additional measures that may be required by applicable laws. Datonics typically collects personal information when a User visits a website where our technology is used or enters a word or phrase into a search engine or conducts a search for a product or service where our technology is used. Datonics also collects data provided by select data partners, including demographic information (e.g., area code, city, gender, age), life stage data, and business-to-business data. This data may have been originally collected either online or offline. Datonics also collects information about users’ mobile devices, including the advertising identifiers assigned to their devices (on iOS devices, the IDFA, and on Android devices, the Advertising Identifier) from its data partners, and may associate those identifiers with data that it collects directly and other devices it has associated with you.

Datonics stores, uses, and may share both raw search terms and websites visited as well as segment categories inferred from such raw data to help deliver relevant online advertisements. For example, if a User searches for a “digital camera” on a partner web site of Datonics, Datonics will store and use the term “digital camera” in its raw form and to inform the segment categories associated with the user (e.g., “electronics”).

Datonics’ technology does NOT intentionally collect or store any data that can be used to directly identify a User such as name, address, telephone number, social security number or unhashed e-mail. We do not attempt to identify Users using the information we collect, and we forbid our partners from using the data we share with them to attempt to identify a User’s real-life identity. We do collect, store, and share personal information that has been hashed so that it does not identify a User. To the extent data has been deidentified or it otherwise cannot reasonably be related back to a specific person, such data is not considered personal information, and is not subject to this Technology Privacy Policy.

Datonics does create some data segments that might be considered ‘sensitive’ by applicable law or industry practices for the purpose of helping clients to tailor ads, such as segments regarding ethnicity or political views. Where applicable law requires that such data be collected with the consent of individuals, we contractually require our data partners to do so.

Information about our data collection during the prior 12 months is described below.

How is the information collected through Datonics technology used?

This information we collect is used to provide advertisements about goods and services that may be of interest to you on the websites and mobile apps you visit on the device from which we collect data and on other browsers and apps that we have associated with you. These relevant advertisements, sometimes called “targeted advertising,” “interest-based advertising,” or “cross-context behavioral advertising,” are delivered by Datonics’ clients based on information provided by Datonics to them. The information may also be used by third parties to whom we sell or transfer the information for purposes of their products and services, such as research, fraud detection, financial services and other lines of business.

We may use your information to match it with other public and private data sources in order to enhance our records, such as appending additional information to your profile, or the records of our clients and business partners, such as providing them with your profile information to append to their existing records about you.

Does Datonics use Cookies?

Yes, Datonics' technology uses cookies. A cookie is a small text file that a browser stores on a user’s computer for record-keeping purposes and future recognition of that user’s web browser by the server that placed the cookie. The Datonics tracking cookie contains a unique value (a series of letters, numbers and characters) and may contain other information as well. The unique value can be used by Datonics, other websites and third parties receiving this unique value to identify your browser. Additional identifiers used by Datonics’ technology include hashed email addresses and mobile device advertising IDs, specifically Android Advertising ID (AAID) and iOS ID For Advertising (IDFA)

How do I know if Datonics collects data on a website I visit?

We require our partner websites to inform Users about their privacy and information collection practices, including whether or not the website partners with third parties like Datonics to collect and use data for advertising purposes, and a way to opt out from the use of such data for targeted advertising purposes by Datonics. Datonics is a member of the Network Advertising Initiative (“NAI”) and follows the NAI’s Code of Conduct. We do not respond to or honor “do not track” (a/k/a DNT) signals or similar mechanisms transmitted by web browsers. However, if you are a resident of California, Virginia, Colorado, Connecticut or another jurisdiction with rights under applicable laws that apply to Datonics, we treat Global Privacy Control signals as a means of opting out of the sale or sharing of personal information, or of opting out of the processing of personal information for targeted advertising, as applicable. Please see the sections titled California Privacy Rights and Other State Privacy Rights below for more information.

To whom is the information you collect disclosed?

Datonics discloses the information collected by our technology on a limited basis, including in the following instances:

·       We share the information we collect with our advertising partners so they may deliver relevant online advertisements to users.

·       We may append our data to the data of our clients in order to enrich their data sets. For example, we may provide attributes and behavioral data to our clients so that they can associate it with their email marketing database and enhance the data they already have about you.

·       We may grant our partner websites and advertising partners access to reports that aggregate information about their web site or mobile application visitors. The information in these reports does not identify anyone personally.

·       We may also disclose to third parties the information we collect through our technology when we have a good faith belief that it is necessary to do so in response to legal process, to protect and defend Datonics’ rights or property, to prevent fraud or in cases of imminent danger.

·       We may share your personal information and other information with third parties in the event of a merger, acquisition or sale of all or a part of Datonics’ assets, or as part of bankruptcy, liquidation, or similar proceeding, in which the assets transferred may include information about the users of our technology. 

Does Datonics sell or share my personal information?

Datonics may sell or share your personal information to third parties, subject to your right to opt-out from your personal information being sold or shared. For more information about your right to opt-out, please see the sections titled California Privacy Rights and Other State Privacy Rights below.

In the preceding twelve (12) months, Datonics has sold the categories of personal information in the chart set forth above to our clients.

How long do you retain the information you collect?

We generally store demographic information (e.g., area code, city, gender, age) obtained from our data partners, as well as search terms and segment categories, for up to five years, or as necessary to comply with our legal obligations. After five years, this information is discarded pursuant to our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. In each case, even if we delete some or all of your information, we may continue to retain and use anonymous or aggregate data, or any other data that constitutes non-personal information. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties

What are your security procedures?

The security of the information collected through Datonics’ technology is important to us. Information collected by the Datonics system is stored in databases that are maintained in a secure data center in the United States. Both physical and Internet access are strictly protected and limited. Access is granted only to those with authorization. Stored personal information is encrypted. No method of transmission over the Internet or of electronic storage is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect the information we collect, we cannot guarantee its absolute security.

How can I opt-out from interest-based advertising by Datonics?

If you would like to opt out from receiving ads that are made more relevant to your interests by Datonics, you may do so by visiting the Network Advertising Initiative’s Opt-Out page and selecting Datonics. You may also opt out of interest-based advertising by other members of the Network Advertising Initiative on this page.

You can learn more about interest-based advertising and opt-out of targeted advertising from certain providers with whom we work by visiting the DAA’s consumer choice page. The opt-out process through the DAA relies upon the placement of an opt-out cookie on your device. If you choose to opt out, we will place a Datonics opt-out cookie on your browser and we will no longer allow the information we collect to be used for interest-based advertising purposes on the browser where you opt out. However, we are at the mercy of browser providers, such as Google Chrome, that may limit the amount of time a cookie can be active on your device and/or block our cookies altogether. If you delete cookies, use another browser or a different device, you need to renew your opt-out choice. Our opt-out process requires your browser to accept third-party cookies. Please make sure your browser allows third party cookies before utilizing this opt-out. For more information about first party and third party cookies, please visit http://www.allaboutcookies.org.

In addition, your mobile device gives you the option to opt out of the use of information about your mobile app usage collected by our data partners for purposes of showing ads that are more likely to be of interest to you. For iOS devices, you may opt out of such collection by turning on the “Limit Ad Tracking” flag in the Advertising subsection of the Privacy section of your Settings. For Android devices, select the “Opt-out of Interest-Based Ads” or “Opt out of Ads Personalization” in the Ads section of the Google Settings App. For more information on how to configure the settings on these and other devices, please see https://www.networkadvertising.org/mobile-choice/.

Please note that each opt out is specific to the browser or device where it is exercised, and you will need to repeat these processes on every browser or device where you wish to opt out.

Hashed emails: We may use your hashed email address as an online identifier. When an email is hashed, your personally identifiable information is removed so that we can no longer identify you directly from the hash. For example: the hashed version of the email address john.doe@gmail.com become 375320dd9ae7ed408002f3768e16cb5f28c861062fd50dff9a3bff62e9dce4ef. You may opt-out of the use of hashed email addresses as an identifier by certain providers by entering your email address on the Network Advertising Initiative’s consumer opt-out page at https://optout.networkadvertising.org/optout/email. Datonics is integrated with this service.

Smart TVs:  Third parties to whom we provide data may append additional data to our data to make it more effective.  Thereafter, consumers may exercise any rights through such third parties.  For example, we may provide data to smart tv advertisers.  You can learn how to exercise choices on connected TVs by reviewing the Network Advertising Initiative’s page on tv streaming devices at https://www.networkadvertising.org/internet-connected-tv-choices/.

We use non-personally identifying information to facilitate cross device association. We or our third party vendors analyze device activity data using a mathematical tool known as a “probabilistic algorithm” to determine if you have interacted with content across multiple devices and to match such devices. In connection with this analysis, we may rely on non-personally identifiable information (including demographic, geographic and interest-based data) from third parties such as data vendors, pursuant to their own privacy policies or we may use the non-personally identifiable information we collect in conjunction with such third party data.  Based on this data, we may then enable the display targeted advertisements across devices that we believe are associated and may provide other services to our advertisers such as tools, analyses, data and insights to see how their website or mobile applications are used and to further enable the display of targeted advertisements to you, including across your devices. Our business partners may also provide us with deterministic data about you that may be used to supplement our probabilistic data. Based on this data, we and/or our clients may then display targeted advertisements across devices that we believe are associated and may provide other services to our advertisers such as tools, analyses, data and insights to see how their website or mobile applications are used and to further enable cross-device targeting and analysis. In order to restrict our use of certain cross-device data, you may opt out by following the instructions above. Once you have opted out on one device (“Opted-Out Device”), we will not use any new data from the Opted-Out Device to identify you on another device for interest-based advertising purposes, and we will not use data from another device for interest-based advertising purposes on the Opted-Out Device.

Your California privacy rights

If you reside in California, under the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020, you have specific rights regarding your personal information. This section describes such rights that you have and explains how to exercise those rights. For the purposes of this section, personal information does not include: (i) information that is lawfully made available from federal, state or local government records; (ii) de-identified or aggregated data; or (iii) information excluded from the scope of the CCPA. To be clear, these rights are granted only to the extent that you are a California consumer and we are acting as a “business” under the CCPA with respect to your personal information. The rights in this section are not intended to grant you additional rights, but only your rights under the CCPA.

Right to Know About Personal Information Collected, Disclosed or Sold. You have the right to request that Datonics disclose certain information to you about our collection, use, disclosure or sale of your personal information. Once we receive and confirm your verifiable consumer request (see Exercising Your CCPA Rights), and subject to certain limitations that we describe below, we will disclose such information to you. You have the right to request any or all of the following:

·       The categories of personal information we collected about you.

·       The categories of sources from which the personal information is collected.

·       Our business or commercial purpose for collecting or selling that personal information.

·       The categories of third parties with whom we share that personal information.

·       The specific pieces of personal information we collected about you  

Right to Request Deletion. You have the right to request that Datonics delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Your CCPA Rights), we will delete (and direct any service providers to delete) your personal information from our records. However, we may retain personal information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under CCPA, such as detecting security incidents and protecting as illegal activity.  

Right to Data Portability. You have the right to request a copy of personal information we have collected and maintained about you in the past 12 months. The CCPA allows you to request your information from us up to twice during a 12-month period. We will provide our response in a readily usable (and usually electronic) format.

Right to Correct. You have the right to request the correction of any personal information we maintain about you.

Exercising Your CCPA Rights.

To exercise the rights described above, please submit a request on our Your Privacy Choices page or call 1-800-569-8617.

Only you, or a proper agent authorized to act on your behalf (an “authorized agent”), may make the requests set forth above. We will require the authorized agent to provide a signed writing from you designating them as your authorized agent and we will need to verify both the identity of the authorized agent and your identity. You may also make a request on behalf of your minor child.

Requests should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The method used to verify your identity will vary depending on the nature of the request. Generally speaking, verification will be performed by matching the identifying information provided by you to the personal information that we already have.

We will respond to consumer requests within 45 days from when you contacted us. If you have a complex request, the CCPA allows us up to 90 days to respond. If we require extra time to respond, we will still contact you within 45 days from when you contacted us and inform you of the reason and extension period in writing.

We are not obligated to provide the information set forth above under “Right to Know About Personal Information Collected, Disclosed or Sold” more than twice in a 12-month period.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales and Sharing Opt-Out and Opt-In Rights. You have the right to direct us to not sell or share your personal information at any time (the "right to opt-out"). To exercise your right to opt-out, please visit our Your Privacy Choices page. We will also treat Global Privacy Control browser signals as valid opt-out requests. We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 and less than 16 years of age, or the parent or guardian of a consumer less than 13 years of age.

Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights, including, but not limited to, by:

·       Denying you goods or services.

·       Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

·       Providing you a different level or quality of goods or services.

·       Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Privacy Requests Stats

During 2023, we processed consumer requests in California as follows:

Requests to delete personal information: 1

Requests to know or access what personal information the data broker was collecting: 1

Requests to know what personal information the data broker was selling or sharing and to whom: 1

Requests to opt out of sale or sharing of personal information: 2

Requests to limit the data broker’s use and disclosure of sensitive personal information: 0

The median and the mean number of days within which we substantively responded to the above requests in the previous calendar year: 7 mean, 7.75 average

Data Broker

Datonics is registered as a data broker where required by applicable law, including under Texas law. To conduct business in Texas, a data broker must register with the Texas Secretary of State (Texas SOS). Information about data broker registrants is available on the Texas SOS website.

Other State Privacy Rights

Laws in Virginia, Nevada, Colorado, Connecticut and similar state laws provide consumers and residents of such states, as applicable, with specific rights regarding their personal information. To the extent that you are a resident of a state with similar privacy laws, this section describes your rights and explains how you may exercise these rights.

The categories of personal information we process, our purposes for processing your personal information, the categories of personal information that we share with third parties, and the categories of third parties with whom we share it are set forth in the chart above.

Rights to Your Information

In addition to the rights set forth in our privacy policy, we provide you with the following rights:

• Right to know. You have the right to know whether we process your personal information and to access such personal information.

• Right to data portability. You may have the right to obtain a copy of your personal information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hindrance, where the processing is carried out by automated means. You may request such personal information up to twice annually, subject to certain exceptions.

• Right to delete. You have the right to delete personal information that you have provided by or that we have obtained about you. Please note that we may deny such request if the requested deletion falls under an exception as set forth in an applicable law. Additionally, if you request deletion of your personal information and we have obtained such information from a third-party source, we may retain such data by keeping a record of the deletion request and the minimum data necessary to ensure that your personal information remains deleted from our records and that such retained data is not used for any other purpose, or we may opt you out of the processing of such personal information for any purpose except for those allowed under applicable laws.

• Right to opt out. You have the right to opt out of the processing of the personal information for purposes of: (i) targeted advertising; (ii) the sale of personal information; or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. As of the latest date of the Privacy Policy:

• We process personal information for the purposes of targeted advertising;

• We sell your personal information in exchange for monetary consideration; and

• We do not engage in profiling decision based on your personal information that produce legal or similarly significant effects concerning you, but our clients may do so.

• Right to correct. You may have the right to correct inaccuracies in your personal information.

• Right to nondiscrimination. You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights. Unless permitted by applicable law, we will not:

• Deny you goods or services;

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

• Provide you a different level or quality of goods or services; or

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

HOW TO EXERCISE YOUR RIGHTS; VERIFYING YOUR IDENTITY

To exercise any of your privacy rights described above, you may visit our Your Privacy Choices page or call 1-800-569-8617.

After submitting a request, we will take steps to verify your identity in order for us to properly respond and/or confirm that your request is not fraudulent. We may contact you for additional information as reasonably necessary to authenticate your request, but if we are ultimately unable to authenticate your request using reasonably commercial efforts, then we may not be able to comply with it.

Only you may make a verifiable request related to your personal information. If you are making a request as the parent or legal guardian of a known child regarding the processing of that child’s personal information, we may ask you to submit reliable proof of your identity.

Response Time; Your Right to Appeal

We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, the law may allow us up to 90 days to respond. We will contact you within 45 days from when you contacted us to inform you of the need for additional time and the reason for such extension. We may charge you a reasonable fee to cover administrative costs if your requests are manifestly unfounded, excessive, or repetitive.

If we decline to take action on a request that you have submitted, we will inform you of our reasons for doing so, and if you have applicable rights in your jurisdiction, provide instructions for how to appeal the decision. In that case, you will have the right to appeal within a reasonable period of time after you have received our decision. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your right to appeal, we will provide you with a method for contacting the applicable authorities to submit a complaint.

How can I learn more about Datonics’ Privacy Practices?

You may contact Datonics with any questions or concerns you may have at:

Datonics LLC
37-18 Northern Blvd, Suite 404
New York, NY 11101
Tel: (646) 867-0647
E-mail: privacy@datonics.com

UNITED STATES OF AMERICA: Our servers are maintained in the United States of America.  By using the website, you freely and specifically give us your consent to export your personal information to the USA.  You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA.

Privacy Policy Updates: If we decide to change this Technology Privacy Policy, we will post those changes to this Technology Privacy Policy and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right, at our discretion, to change, modify, add, or remove portions from this Technology Privacy Policy at any time by posting the modified policy on this page, provided that any such modifications will only be applied prospectively. Your continued use of the Datonics technology after the effective date of the revised policy will constitute your consent to those changes. However, we will not, without your consent, use your personal information in a manner materially different from what was stated at the time your personal information was collected. We encourage you to periodically review the Website for the latest information on our privacy practices.