PRIVACY POLICY

Introduction

  1. This is Centro Media LLC’s (“Centro”) privacy policy, and applies to our websites, services that we provide to you through our website or technology platform, and ads we display to you on other websites. It is effective as of January 20th, 2017 (“Effective Date“).
  2. This policy is incorporated into, and subject to, Centro’s Terms of Service.
  3. By using Centro’s site, or any product or service offered, you acknowledge that you have read, and agree to, this policy.

What is in this document?

This document provides information about our website and our digital advertising technology platforms (“Centro DSP”, “Centro Brand Exchange”) which enables our clients to buy digital advertising, and then describes our policies about data collection and use. It also provides information on the type of data we collect and utilize when serving ads to individuals.

CONSUMER OPT-OUT CHOICES

Centro supports empowering you to make informed decisions about the type of advertisements that are delivered to you online, and, as such, we are providing you the opportunity to opt out of the tailored ads delivered to you by Centro based on your interests, previous visits to other sites, and information stored in your web browser or mobile device.

If you select this option, you will still see just as many ads, but they will no longer be personalized based on the information Centro has collected, (i.e. the ads will likely be less relevant to you and your interests) and any information we have collected thus far will be dissociated from your device, thereby preventing its use.

Feel free to opt out here if you so desire:

Centro DSP

  1. For desktop and mobile web, click here. You can also opt out by clicking the AdChoices icon located in the top-right corner of any behaviorally targeted ad served by Centro.
  2. For mobile app:
    1. You can install the TrustE privacy app to opt-out of ads from Centro DSP. Both Android and iOS are available.
    2. Alternatively, manually opt-out:
      1. Find your phone’s Android Advertising Identifer (for Android devices.) or Apple Identifier for Advertising (for iOS devices).
        1. On Android 6, open the Settings app and select “Google”. Select “Ads”. Choose “Opt out of Ads Personalization”, and make a note of your advertising ID. In earlier versions of Android, this is found in a separate Google Settings app instead.
        2. On iOS, open the Settings App and select “Privacy”. Select “Advertising”, and enable “Limit Ad Tracking”. On iOS 10 and above, this will set your Identifier for Advertising to “0”, and no further action is needed, as this prevents its use. On iOS 9 and below, for additional confidence, you may wish to download an app such as My TUNE Device to determine your Identifier for Advertising and enter it in the box below.
      2. Enter it here:

It should also be noted that Centro is committed to industry self-regulation, and as such, is a member in good standing with the Interactive Advertising Bureau, (“IAB”) and is a participant in the Digital Advertising Alliance (“DAA”) following the Self-Regulatory Principles for Online Advertising, including its “AdChoices” program.

CENTRO DSP PRIVACY PRACTICES

What is Centro DSP?

Centro DSP provides tools for advertisers, or media buyers, to purchase digital ad space on website and mobile sites and applications. To accomplish these goals, advertisers and media buyers use Centro DSP to engage in a variety of techniques, including interest-based advertising, real-time (programmatic) advertising, contextual, and location-based advertising. Centro DSP also provides buyers other tools, like the ability to measure how effective their ads were, designed to make the buying of ad space seamless.

What information does Centro DSP collect?

Centro DSP is designed to use certain types of data. It includes data generated through Centro DSP as well as data clients receive from other sources and then use on Centro DSP, or that they buy through Centro DSP. This may include non-personally identifiable information about Internet users’ browsers and devices, such as:

  • the type of browser and its settings,
  • information about the device’s operating system,
  • cookie information,
  • information about other identifiers assigned to the device, and
  • the IP address from which the device accesses a client’s website or mobile application
  • Information about whether an Internet user has visited a Centro client’s website, based on web beacons placed on the site by our customer
  • information about the geographic location of the device when it accesses a website or mobile application
  • inferences or information about users’ interests that are created, acquired, bought, sold, or used by our clients

How does Centro DSP collect this information?

Centro DSP uses cookies, beacons, mobile SDKs, tags and other technology to collect data associated with particular devices or web browsers. Customers then use this data within Centro DSP to enhance and refine digital ad campaigns.

How does Centro DSP use the information that it collects?

We use the information we collect to serve targeted ads to individuals.

More specifically, the platform enables our users to use this information to:

  • Determine what ad to show an individual, and to serve that ad (including behaviorally targeted ads) to that individual
  • Customize ads to particular types of audiences;
  • Customize ads to the type of web page an individual is viewing;
  • Perform analysis of how effective the ads served are;
  • Learn more about their own customers;
  • Limit the number of times an individual sees an ad;
  • Detect fraud; and
  • Troubleshoot platform or campaign issues.

How long is the information stored and kept?

Centro DSP stores cookie-based user profiles are stored for up to 60 days since the last update to the user profile. Mobile advertising ID-based user profiles are stored for up to 180 days since the last update to the user profile.

Does Centro DSP use web beacons (aka clear GIFs or web bugs)?

Yes. “Web beacons” are small images (generally a single transparent pixel) with a unique identifier, served to you as part of a web page or other document. Web beacons may be used in parts of our Services for purposes such as site traffic reporting, unique visitor counts, advertising auditing and reporting, and personalization. For more information on web beacons, see http://www.allaboutcookies.org/faqs/beacons.html

CENTRO DSP ADVERTISERS

How does Centro use the information provided by Centro DSP advertisers?

We use any information provided by Centro DSP users for the following service-related purposes:

  • To provide, operate, manage, maintain and enhance the platform. We internally perform statistical and other analysis on information we collect (including usage data, device data, referral data, and information from page tags) to analyze and measure user behavior and trends, to understand how people use our services, and to monitor, troubleshoot and improve our Services.
  • To assist the enforcement of our Terms of Service.
  • To prevent potentially illegal activities.
  • To screen for undesirable or abusive activity.
  • To contact you about your service or account. We occasionally send you communications of a transactional nature (e.g. service-related announcements, billing-related matters, changes to our services or policies, welcome emails when you first register, etc). You can’t opt out of these communications, since they are necessary in order for us to effectively provide our services to you.
  • To contact you for marketing purposes. We will only do this if you have given us your express permission to contact you for this purpose.
  • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  • To create new services, features or content. We may use any information you provide us (e.g. via email or through our ticketing system) to create and provide new services, features or content. When we do this, we will not personally identify you, unless we first receive your permission.

As a Centro DSP user, will Centro share my information?

  1. Aggregate Information (non-personally identifiable) – We share aggregate information about our users for marketing purposes. We also share aggregate information with third party providers, in order to provide the Services (as noted above). We do not link aggregate user data with personally identifiable information.
  2. Personally identifiable information – We share personally identifiable information (PII) with certain third parties, in order to provide you with the Services. For example, if you fund your platform account with a credit card, we use a credit card processing company to bill you for the Services, and share PII with them in order to do so. They do not retain, share, store or use PII for any other purpose. In certain instances, we may share PII with our suppliers (data and inventory exchanges). Finally, we share PII with our parent company and subsidiaries, for record-keeping purposes, billing purposes, and for general business purposes.
  3. To provide the Services – Centro may provide customer platform data to partners and service providers for the purpose of operating, managing, maintaining, or enhancing Centro’s Services, including for the safety and security of the platform and the online industry, or as required by law. Centro does not share the information collected on the platform with other third parties, unless legally required.

Legal Disclaimer: We reserve the right to disclose your PII as required by law, and when we believe that disclosure is necessary to protect our rights and/or to comply with any applicable judicial proceeding, court order, or legal process.

As a Centro DSP user, what communications can I expect from Centro?

  1. Special Offers and Updates – We will occasionally send you information on products, services, special deals, and promotions (if you opt-in on our registration page). If you no longer wish to receive this type of communication, you can opt-out through the link in the email communication.
  2. Surveys or Contests – From time to time, we may provide you the opportunity to participate in contests or surveys on our site. If you participate, we may request certain personally identifiable information from you. Participation in these surveys or contests is completely voluntary, and you therefore have a choice whether or not to disclose this information. We use this information to notify contest winners and award prizes, and to process and analyze survey results. We use a third party service provider to conduct these surveys or contests; that company is prohibited from using our users’ personally identifiable information for any other purpose.
  3. Service-related Announcements – We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is undergoing temporary maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
  4. Customer Service – Based upon the personally identifiable information you provide us, we will send you a welcoming email to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will communicate with you through our ticketing system, via email, and by phone.

If you no longer wish to receive our promotional communications, you may unsubscribe by following the instructions included in each communication.

Through our partners, we use web beacons in our HTML-based emails to let us know which emails recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

Supplementation of Information: In order to provide certain services to you, we may supplement the personal information you submit to us with information from third party sources, including in respect of credit worthiness and verification of any information provided.

CENTRO.NET WEBSITE VISITORS

What information does the Centro website collect, and how do it use it?

We collect usage data about you whenever you interact with our website. This may include which of our pages you visit, what you click on, when you performed those actions, and so on. Additionally, like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses. We collect data from the device and application you use to access our services, such as your IP address and browser type. We may also infer your geographic location based on your IP address. If you arrive at our website from an external source (such as a link on another website or in an email), we record information about the source that referred you to us. We use third party tracking services that employ cookies and page tags (also known as web beacons) to collect aggregated and anonymized data about visitors to our websites. This data includes usage and user statistics, but not personally identifiable information.

Does Centro.net use cookies?

Yes. “Cookies” are pieces of information (actually, alphanumeric identifiers) generated by web servers, and stored on your web browser for future access. Cookies cannot view or retrieve data from other cookies, nor can they capture files or data stored on your computer. We do not link the information that we store in cookies to any PII that you submit while on our site. We use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your web browser’s “help” file. We set a persistent cookie to store your passwords, so you don’t have to enter it more than once. Persistent cookies also enable us to track and target the interests of our users to enhance the experience on our site. If you reject cookies, you may still use our site, but your ability to use some areas of our site will be limited. For more information on cookies, see: http://www.allaboutcookies.org/faqs/cookie-file.html

GENERAL PRIVACY INFORMATION

How do I access my personally identifiable information (PII)?

You have the right to access, update, and correct inaccuracies in your PII in our custody and control, subject to certain exceptions prescribed by law. You may request access, updating and corrections of inaccuracies in the personal information we have in our custody or control by emailing us at privacy@centro.net. We may request certain personal information for the purposes of verifying your identity when requesting access to or correction of your personal information records. If your personally identifiable information changes, or if you no longer desire our Service, you may correct, update, delete or deactivate it by emailing us at privacy@centro.net.

Is my PII secure?

Yes, the portions of our website (and our other Services) that handle sensitive confidential information are secure. We are committed to maintaining the security of your information and have measures in place to protect against the loss, misuse, and alteration of the information under our control. We employ industry-standard techniques to protect our systems from intrusion by unauthorized individuals. Our data center utilizes state-of-the-art physical security measures to prevent unauthorized access to the facility. In addition, all information is stored in a secure location behind firewalls and other sophisticated security systems with limited (need-to-know) administrative access. All provider employees who have access to, or are associated with, the processing of personal information are contractually obligated to respect the confidentiality of your information and abide by the privacy standards we have established. Please be aware that no security measures are perfect or impenetrable. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Will my PII be transferred?

In the event that Centro (or its parent or subsidiary companies) goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You will be notified via prominent notice on our site for 30 days of any such change in ownership or control of your personal information.

Does the Centro privacy policy apply to other sites?

This site contains links to other sites that are not owned or controlled by Centro. We are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site, and to read the privacy statements of each and every site that collects personally identifiable information. This privacy statement applies only to information collected by Centro.

What if Centro changes this privacy policy?

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we decide to change our privacy policy, we will post the updated version, together with an updated Effective Date, on this page. We encourage you to check this page periodically for any changes.

Contact Us

If you have any questions or suggestions regarding our privacy policy, please contact us:

Centro Media LLC
11 E Madison St., 6th Floor
Chicago, IL
60602
United States