DIANOMI PRIVACY NOTICE
Effective date of this Privacy Policy:
If you would like to go directly to Dianomi’s opt-out status options, please click here.
If you would like to learn more about Dianomi’s region-specific processing of Information, you can go directly to the applicable notices for individuals in the UK and/or the European Economic Area (“EEA”) and in California by clicking here.
Introduction
Welcome to Dianomi’s privacy notice.
Dianomi is dedicated to providing Internet users the highest level of transparency and control over the use of their data in online advertising. We adhere to the Interactive Advertising Bureau’s (IAB) and the Digital Advertising Alliance (DAA) Self-Regulatory Principles for Online Behavioural Advertising.
When you visit www.dianomi.com, and any Dianomi website displaying this privacy notice, or use or interact with any of our services or are a visitor to one of our Advertiser’s or Publisher’s websites and digital properties who interacts with our services (collectively the “Sites”), we may collect information from or about you or your device, which may include personal information or personal data as defined by applicable privacy laws (“Personal Information” or “Personal Data“) (collectively, the “Information”), and this Information will be handled as described in this privacy notice.
Dianomi respects your privacy and is committed to protecting your Information. This privacy notice will inform you about how we collect, process, use, disclose and look after your Information that we may obtain when you visit our Sites and when we provide our advertising services for digital publishers and advertisers (collectively the “Services”) to you (regardless of where you visit from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR INFORMATION COLLECTED
- HOW WE USE YOUR INFORMATION
- TRACKING AND RETARGETING
- COOKIE POLICY
- DISCLOSURES OF YOUR INFORMATION
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- CHANGES TO THE PRIVACY NOTICE
- ADDITIONAL REGIONAL PRIVACY DISCLOSURES
Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Dianomi collects and processes, clients and users Information through your use of the Sites and Services, including any data you may provide through our Sites when you sign up to our newsletter or request information about other products and services from Dianomi. It also describes how in the course of providing our Services to our advertising clients we may collect and use your Information for analytical purposes and in order to deliver personalised advertisements for products or content you might be interested in.
The Sites are not intended for children under the age of sixteen (16) and we do not knowingly collect data relating to children. However, if children who are under sixteen (16) provide information to us, their parents or legal guardian can request us to delete this information from our records by sending us an email at [email protected].
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Information about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Dianomi PLC's registered address is 6th Floor, 60 Gracechurch Street, London, United Kingdom, EC3V 0HR , and details of the different legal entities in the Dianomi entities (“the Dianomi Group”) can be found here. This privacy notice is issued on behalf of the Dianomi Group so when we mention "Dianomi", "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the Dianomi Group responsible for processing your data. Dianomi PLC is the controller and responsible for the Sites.
Details of Dianomi PLC’s Data Protection officer are:
Clientside Law Limited
20-21 Jockey's Fields,
London WC1R 4BW
Email: [email protected]
Details of Dianomi PLC’s EU Representative are:
HYAZINTH Consulting for Tech uG (haftungsbeschränkt),
Lennéstraße 1, 10785 Berlin, Germany
Email: [email protected]
If you have any questions about this privacy notice, including any requests to exercise your legal rights (including an opt-out mentioned in this privacy notice), please contact us at: [email protected]
Changes to the privacy notice and the duty to inform you of changes
This version was last updated on and previous versions can be obtained by contacting us at: [email protected]
Third-party links
The Sites and our Services may include links to third-party websites, plug-ins and applications. Any access to, use or clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for the information security nor privacy practices of such third-party websites. When you leave our Sites or Services, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Information about you (as a user, advertiser or publisher) which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Technical Data includes internet protocol (IP) address, your login data, cookie identifiers, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Sites and our Services.
Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our websites or Services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Information but is not considered Information in law as this data doesnot directly or indirectly reveal your identity. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific website. However, if we combine or connect Aggregated Data with your Information so that it can directly or indirectly identify you, we treat the combined data as Information which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide Information
Where we need to collect Information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your Information collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise or clicking on ads. This includes Information you provide when you:
- Apply for our products or services as an advertiser or publisher
- Create an account on our Sites
- Subscribe to our service or publications
- Visit a web page with our ad units
- Click on a link in our ad units
- Request marketing to be sent to you
- Enter a competition, promotion or survey
- Give us some feedback.
Automated technologies or interactions. As you interact with our Sites or Services, we may automatically collect Technical Data about your equipment, browsing actions and patterns and we may deliver advertisements to you based on this behaviour. This data can also be used for analytic purposes. We collect this Information by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other Sites employing our cookies and similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive Information (including analytics data, demographic data, IP addresses) about you when you visit our sites via third parties that collect information on our behalf through your use of the Sites or via our third party customers’ websites and digital properties who interact with our Services or via our data partners and other public sources.
How we use your Information
Most commonly, we may use your Information in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with our publisher and advertiser clients and others.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- To provide and manage our Sites and Services.
- For analytical and insight purposes.
- To register you as a new customer, advertiser, publisher.
- To process and deliver your order campaigns including:
- Manage payments, fees and charges
- Collect and recover money owed to us
- To manage our relationship with you which will include notifying you about changes to our terms or privacy notice.
- To enable you to partake in a prize draw, competition or complete a survey.
- To administer and protect our business and our Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
- To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
- To use data analytics to improve our Sites, products/Services, marketing, customer relationships and experiences.
- To make suggestions and recommendations to you about goods or services that may be of interest to you.
- To check the reputation of your IP Address (both then and later) for security and to detect robots and fraudulent traffic.
- We need to use your IP address so we can geotarget our ads
- We may disclose user Information to other unaffiliated third parties, specifically with our data partners, so that we can connect you with relevant content by allowing our advertisers to target specific audience segments.
- We may use your Information to tailor the content and information that we may send or display to you; to retarget content to you through our Services and elsewhere; and to otherwise personalize your experiences while using our Services.
- We may use your Information to improve your experience across multiple browsers and devices (such as smartphones, tablets, or other viewing devices) by providing better targeted ad campaigns to you. For instance, should we recognize you on a web browser, we may want to provide you with similar or personalized content on mobile apps, as well. To do this, we may identify you across devices, or we may sync cookies and identifiers with our data partners and Publishers that do this, to help our Publishers enhance their own data and data segments, or to help them target the right audience.
- Offering our Customers data segments that help target content and advertisements for topics, products, and services that may interest you. A data segment is a grouping of users who share one or more attributes (e.g., sports enthusiasts). We offer a number of data segments, both proprietary and from our data partners, to our Customers so that they may better target users who are more likely to be interested in their content and advertisements. Dianomi does not knowingly create segments that are based upon what we consider to be sensitive information (for example, Personal Data revealing your racial or ethnic origin or your religious affiliations, or Personal Data concerning your sensitive health information, sex life or sexual orientation, or genetic or biometric data).
- For audit purposes
- To comply with applicable legal obligations, including requests from law enforcement or other governmental entities.
Tracking and retargeting
Dianomi PLC participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Dianomi PLC's identification number within the framework is 885.
Marketing / Targeting
We strive to provide you with choices regarding certain Information uses, particularly around marketing and advertising. We have established the following Information control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). In most cases we will show you recommendations based on the context of the page and not on your Information profile.
You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered your details in one of our form.
Third-party marketing
Dianomi may also use third parties to serve ads (see list of data partners for this purpose). These third parties and our Advertisers and Publishers may collect information about your visits to our Sites and other websites, your IP address, your ISP, the browser you use to visit our Sites (but not information such as your name, address, email address or telephone number). They do this using their own cookies, clear gifs, pixels or other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Sites and the other sites tracked by these third parties. This notice does not apply to, and we are not responsible for, cookies or clear gifs in third party ads, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology.
User Choices and Opting Out
Dianomi supports initiatives to offer our users greater transparency and control over the uses of their Information. Therefore, we offer the following options for controlling the interest-based content and ads you receive.
Opting out - Tracking
If you have:
Opted Out: you have opted out of tracking (behavioural targeting), Dianomi will no longer serve you with personalized content recommendations based on your Internet history. Please note that an opt out will not prevent you from seeing Dianomi’s content recommendations. Rather, the opt out will prevent Dianomi from using your information to tailor these recommendations to your interests. You will continue to receive recommendations that are selected based on the particular website that you are viewing (i.e. contextually based ads). By opting out you give us permission to clear all the personalisation cookies that we previously stored regarding your account and to set a new cookie that tells us that we should no longer track you. If you clear all cookies from your browser after you opt out, you will also be clearing the cookie that tells us that you have opted out, so you will need to re-enrol in our opt-out.
Not Opted Out: in some cases Dianomi will serve you personalized recommendations (behavioural targeting) based on your history, however Dianomi serves mostly contextual recommendations.
Tracking mechanisms operate at the device and browser level, so if you would like to opt-out across all devices, you will need to do so on each device and browser individually.
If you are in the United States you can also opt-out of targeted ads from Dianomi and other advertising companies by visiting the DAA consumer choice page at www.aboutads.info/choices
Note that opting out from one or more companies listed on the DAA consumer choice pages will not prevent you from seeing those companies’ advertisements. The opt out will prevent these companies from using your Information to display targeted or personalised ads or content to you. You may still receive ads that are served based on the content of website that you are viewing, for example, ads based on the context of the website rather than on your personal information.
If your browsers are configured to reject cookies by default when you visit the DAA consumer choice page, your opt out may not be effective because your browser will not accept the opt-out cookies.
Cookie Policy
To enhance your online experience, we use "cookies." Cookies are small text files placed by the Sites in your computer's browser to make a user’s experience more efficient. Cookies, by themselves, do not tell us your e-mail address or other personal information. However, once you choose to furnish the Sites with information (such as signing up to receive one of the offers made by our third party advertising partners), this information may be linked to the data stored in the cookie. We use cookies to understand Internet usage, enhance the performance of the Sites, activate special web features and security mechanisms. In addition, we may use cookies to target advertisements to you for products and services that may interest you, offer you products, programs or services which may be part of client retargeting campaigns. The information that we collect via cookies may include, for example, information about your operating system, the web pages accessed within the websites of our Advertisers and Publisher’s, the website that led you to our Advertiser’s or Publisher’s websites, the dates and times you accessed our Customers’ websites or platforms, event information (e.g. irregular system crashes), and general location information (i.e. city).
You always have the option of setting your browser to warn you when a cookie is being accessed on your computer, to delete cookies that are currently on your computer or to decline cookies altogether. However, to take full advantage of the Sites and its features, your browser will need to accept cookies.
Web beacons (also known as clear gifs) are small, invisible graphic images that may be used on the Sites and in e-mails to collect certain information about your use of and activity with the Sites and emails. If we combine cookies or clear gifs with or link them to any of the personally identifying information, we would treat this Information in the same way we treat other Information.
To understand your interests and deliver advertisements that are tailored to your interests, we may work with service providers, data partners or other third parties that use their own cookies, web beacons, and other technologies to collect Information about your online activities, either on our Sites and/or other websites across the Internet. This may include advertisers and their service providers that may collect Information when you view or interact with one of their advertisements and may collect information regarding your activities on our Sites and your online activities over time and across different websites. Dianomi works to place our advertisements where we think they will be most interesting and relevant to the recipient. We may use pixel tags to track conversions or to create a custom audience for our advertiser Customers to target on our network (i.e. retargeting).
Dianomi uses different types of cookies which are listed in the below table. Some cookies are placed by third parties. We ask our Publishers to obtain consent on our behalf, where required by applicable data protection laws, so that we may use cookies and other automated means of data collection on their digital properties. We use any Information collected via third-party cookies on our Sites to remember your information so that you do not need to re-enter it upon your next visit, to monitor how many visitors we have and understand how they engage with different web pages on our Sites, and to improve and manage our Sites. We may use third parties to track or analyse your activity on the Sites for these purposes, or to deliver you tailored advertisements.
Change of purpose
We will only use your Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process your Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your Information
We may share data or aggregated data with affiliates, subsidiaries, or our third party data partners for the purpose of delivering our Services. We may disclose your Information to our customers where relevant to the Services we provide. For example, we may provide third parties with information about the viewing and click-through patterns of the advertisements and/or content they publish and may provide advertisers with information about conversion rates for analytics purposes.
We may disclose your Information to vendors, service providers, agents, contractors, sub-processors or others who perform functions (e.g., maintenance, data analysis, customer relationship management, email marketing, surveys, credit card processing, data hosting, fraud detection) on our behalf.
We may disclose your Information to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Information in the same way as set out in this privacy notice.
Payment Information: When you make a purchase on our Service (including via telephone, email or online), you will provide your payment information to our third party payments processor, currently Stripe Payments Europe Ltd. Our payments processor is responsible for processing payments in connection with your use of our Services and for any Personal Information that it collects from you. Please read their terms and conditions and Privacy and Cookies Policies as well as those of your credit card issuer. We are not responsible for any errors by the payment processor. To find out more about how Stripe Payments Europe Ltd stores and uses your Personal Information, please read their Privacy and Cookies Policies
We require all third parties to respect the security of your Information and to treat it in accordance with the law.
We may transfer your Information outside the country in which it is collected, including to a country that may not offer the same level of protection for Information as the country in which you reside. Rest assured however, that Dianomi has contractual safeguards to ensure your Information is processed in a way that offers an adequate level of protection when it is shared between or among the Dianomi Group or with third parties outside the country in which your Information was collected, used or disclosed. If you would like to learn more about EEA Data Transfers, specifically, see Section 12.1 below.
Data security
We have put in place appropriate security measures to prevent your Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
We retain your Information for the period necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required or allowed by law.
Your legal rights
You have the right to make a complaint at any time to the relevant data protection authority about data protection issues.
We would, however, appreciate the chance to deal with your concerns before you approach your local authority so please contact us in the first instance. You have the right to request that Dianomi provide you with access to the Information we hold about you, correct your Information, delete your Information, and cease or restrict processing of your Information. Please contact us at: [email protected] for any such requests.
Changes to This Privacy Policy
This Privacy Notice is current as of the Effective Date set above at the beginning of this Privacy Notice.
We may change this Privacy Notice from time to time, but we do not have a means of advising of an update by way of notice.
The last material changes to this Notice are in the version dated which added wording relating to changes to some US state privacy laws and which added details of our credit card provider. You should check back here periodically to see if the Privacy Notice has been updated as we will always show the date of the latest modification of the Privacy Notice at the top of the page so you can tell when it was last revised.
Additional Regional Privacy Disclosures
12.1 Individuals within the UK and European Economic Area (EEA)
Data Controller
If you reside in the UK or the EEA, Dianomi PLC will be the controller of your Personal Data provided to, collected by or for, or processed by Dianomi in connection with our Services.
Legal Basis for Processing Personal DataIf you are a customer, Site visitor, or user from the UK or the EEA, our legal basis for collecting and using the Personal Data described above (also referred to in this Section 12.1 as “UK or the EEA Data”) will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only (i) where we have your consent to do so, (ii) where we need the Personal Data to perform a contract with you, or (iii) where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.
If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us at: [email protected]
Your Rights to Your Information
You have the right to request that Dianomi (i) provide you with access to the Personal Data we hold about you, (ii) correct your Personal Data, (iii) Export your Personal Data, (iv) delete your Personal Data, and (v) cease or restrict processing of your Personal Data. If you are a user and would like to understand what Personal Data and behavioural information Dianomi holds about you, specifically, and how you can exercise any of your rights with respect to your Personal Data, please contact us at: [email protected]. You may also submit a data subject access request by emailing us at [email protected] so that Dianomi may respond with the relevant information. You have the right to complain to a data protection authority about our collection and use of your Personal Data. To learn more, please contact your local data protection authority. However, if you have any questions about our collection and use of your Personal Data, please first contact us at: [email protected].
UK and or EEA Data Transfers
We share your personal data within the Dianomi Group. This will involve transferring your data outside the UK and/or European Economic Area (EEA) and Dianomi has in place an Inter Group Data Transfer Agreement across its international entities, which is based on the UK and/or the European Commission’s approved Standard Contractual Clauses, which are contractual privacy and security commitments between companies that transfer personal data. We may also share your personal data with our external data partners who may be based outside of the UK and/or the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the UK and/or the EEA, and such transfers will rely on adequacy determinations and/or be based on the European Commission’s approved Standard Contractual Clauses.
12.2. Individuals in the United States
Residents of certain U.S. states may have the ability to exercise additional rights and choices regarding their personal data. We will take reasonable steps to accommodate your request but may need to verify your identity before doing so. If you are a resident of Colorado, Connecticut, Utah, or Virginia, please see additional information below. If you are a California resident, please see Section 12.2.1. Individuals in the State of California below.
We set forth above the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared. Residents of Virginia, Colorado, Connecticut, and Utah have certain privacy rights with respect to this data, as described below. If you are a Consumer residing in one these states (as defined in each state’s respective law) and would like to exercise your applicable rights, please use email us at [email protected] .
In your request, please provide enough information to allow us to verify you are the person about whom we collected personal information. You must also describe your request with enough detail so that we can understand, evaluate and respond to it. We can’t respond to your request if we can’t verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity.
12.2.1 Individuals in the State of California
Effective data of this California Privacy Notice is
This notice supplements Dianomi PLC’s (“Dianomi“) Privacy Policy and applies only to California consumers. This California Privacy Notice sets forth the disclosures and rights for California consumers regarding their Personal Information, as required by the California Consumer Privacy Act (“CCPA“). Terms (including defined capitalized terms) used in this California Privacy Notice have the same meanings given in the CCPA and the regulations of the Attorney General implementing the CCPA, unless otherwise defined.
INFORMATION DIANOMI COLLECTS
In order to provide our Services, we obtain information about you through the means discussed below. We may combine the information that we collect through the Services with information that we collect automatically or receive from other sources. In addition to the below, we may collect and/or use additional types of information, and will do so after providing notice and obtaining your consent to the extent such notice and consent is required by the CCPA.
| Category of Personal Information Collected | Categories of Sources from which the Information was Collected | Business or Commercial Purpose(s) for which Information is Collected |
|---|---|---|
| Identifiers This category includes information such as name, contact information, and online or device identifiers. |
We may collect this type of information from:
|
We may use this type of information to:
|
| Any categories of personal information described in subdivision (e) of Section 1798.80 This category includes information such as name, contact information, financial information and online or device identifiers. |
We may collect this type of information from:
|
We may use this type of information to:
|
| Characteristics of protected classifications under California or federal law This category includes information such as age, sex (including gender), and marital status. |
We may collect this type of information from:
|
We may use this type of information to:
|
| Internet or other electronic network activity information This category includes information such as details about the hardware and software you use to visit the Service, areas of the Service you visit, and login information. |
We may collect this type of information from:
|
We may use this type of information to:
|
| Commercial information This category includes, for example, information about products and services you have purchased, obtained, or considered. |
We may collect this type of information from:
|
We may use this type of information to:
|
|
Geolocation data This is the location of the device you use to access our clients’ websites, mobile applications, or other services.
|
We may collect this type of information from:
|
We may use this type of information to:
|
|
Inferences drawn from any of the information identified above to create a profile about a consumer These inferences may relate to your perceived interests, preferences, characteristics, or behavior.
|
We may collect this type of information from:
|
We may use this type of information to:
|
|
Professional or employment-related information This includes business names and job titles.
|
We may collect this type of information from:
|
We may use this type of information to:
|
INFORMATION DIANOMI DISCLOSES
We will share the information collected from and about you for the various business purposes described above, both with service providers and with third parties including our clients. The table below shows how and with whom we may share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months. Additional, more general disclosure practices are also described below the table. In addition to the following, we may share the Information with any other party with your prior consent.
| Category of Personal Information | Third Parties to Whom We May Disclose Personal Information | Whether We Sold This Information in the Last 12 Months |
|---|---|---|
| Identifiers This category includes information such as name, contact information, and online or device identifiers. |
We may disclose this type of information to:
|
Yes |
| Any categories of personal information described in subdivision (e) of Section 1798.80 This category includes information such as name, contact information, financial information and online or device identifiers. |
We may disclose this type of information to:
|
Yes |
| Characteristics of protected classifications under California or federal law This category includes information such as age, sex (including gender), and marital status. |
We may disclose this type of information to:
|
Yes |
| Internet or other electronic network activity information This category includes information such as details about the hardware and software you use to visit the Service, areas of the Service you visit, and login information. |
We may disclose this type of information to:
|
Yes |
| Commercial information This category includes, for example, information about products and services you have purchased, obtained, or considered. |
We may disclose this type of information to:
|
Yes |
|
Geolocation data This is the location of the device you use to access our clients’ websites, mobile applications, or other services.
|
We may disclose this type of information to:
|
Yes |
|
Inferences drawn from any of the information identified above to create a profile about a consumer These inferences may relate to your perceived interests, preferences, characteristics, or behavior.
|
We may disclose this type of information to:
|
Yes |
|
Professional or employment-related information This includes business names and job titles.
|
We may disclose this type of information to:
|
Yes |
We also may share any of the personal information we collect as follows:
Disclosure for Legal Purposes: We may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, the Privacy Policy, this California Privacy Notice, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our clients, our agents and affiliates, and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.
Disclosure in Event of a Corporate Transaction: We may share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.
Disclosure to Service Providers: We may share any personal information we collect with our service providers, which may include (without limitation) providers involved in: technical or customer support; operations; web or data hosting; billing; accounting; security and fraud prevention; marketing; data management, validation, enhancement or hygiene; or otherwise assisting us to provide, develop, maintain and improve our Services.
Aggregate and De-identified Information: We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device. (“Aggregate and De-Identified Information”). We may use Aggregate and De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, in our discretion.
YOUR RIGHTS
Exercising Your California Access, Deletion, and Opt-out Rights
California residents have the right to request: (1) that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the specific pieces of Personal Information we have collected about you in the prior 12 months (“Right to Know”); (2) that we delete the Personal Information we collect about you (“Right to Delete”); (3) that we correct inaccurate information we hold about you (“Right to Correct”); (4) ; or to opt-out from the “sale” of Personal Information or sharing of Personal Information to a third party for cross-context behavioral advertising (i.e. targeted advertising) (“Right to Opt-Out of Sale/Sharing”), all subject to exceptions set forth in the CCPA. More information on each of these rights is below. Dianomi does not process sensitive personal information and therefore does not process requests to limit the use and disclosure of sensitive personal information.
Agents
If you are an agent submitting a request on a user’s behalf, please send an email to [email protected] with a declaration signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request, and needs to be clear about the permission granted. Alternatively, you may submit a copy of a power of attorney under California Probate Code sections 4000-4465. In either case, please also indicate in your email the nature of your request. The consumer’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfil your request. We may also ask the consumer to directly confirm with us that they provided you permission to submit a request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer’s behalf, we may deny the request.
How to Make a Request to Know, Request to Delete, Request to Correct, or Request to Limit Use of Sensitive Information
If you are a California resident and would like to request information about the Personal Information we have collected about you in the prior 12 months,to request that we delete your information, request that we correct inaccurate information, or request that we limit use of sensitive information please contact us at [email protected].
Verifying Requests
Please provide your first and last name, email address, mailing address, and telephone number, which we will use to verify your request. We may ask for additional information as needed to fully verify you or your request.
If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.
Other Important Information:
In order to have us provide specific pieces of information, we will require a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.
To ensure that we do not delete your personal information in response to a fraudulent request, once you submit the request, we will follow up to confirm that you want your information to be deleted.
In order to have us correct information we hold about you, we will require a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.
Right to Opt-out of the Sale or Sharing of Personal Information
California residents may opt out of the “sale” (as that term is defined under CCPA) or sharing of their personal information. If you would like to opt out of disclosures of your information for purposes that are considered a “sale” or sharing under California law, you may do so clicking the button below:
Please note that the above opt-out mechanism uses a cookie that enables us to identify your choice, if your browser is configured to reject cookies or delete them, then your choice will not be present next time you engage with our Services. Please ensure you enable cookies in your browser for such purposes and action the above choice in all the devices and browsers you wish not to be tracked on.
Users Younger than 16
Dianomi’s services are not intended for children under the age of sixteen (16) and we do not knowingly sell data related to children. However, if children who are under sixteen (16) provide personal information to us, their parents or legal guardian can request us to delete this information from our records by following the instructions in How to Make a Request to Know or Request to Delete above.
Right to Information about Financial Incentives
California law also gives residents the right to request that we provide you with information about the financial incentives that we offer to you. We offer no such incentives.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
California consumers have the right to not receive discriminatory treatment for exercising CCPA rights. We will not discriminate against you for exercising your CCPA rights.
CONTACT FOR MORE INFORMATION
You can contact us for more information: