Product and Services Privacy Policy

More information about our partners with whom we share your data can be seen here.

Do not sell my Personal Infomation.

zeotap GmbH (“Zeotap,” “us,” “we,” or “our”) is a Customer Intelligence Platform (CIP) that helps companies better understand their customers and predict behaviours, to invest in more meaningful experiences. Our services either solely use Zeotap’s proprietary technology or use its proprietary technology in combination with customer data received from third parties (“User Data”), including but not limited to, customer data unification, identity resolution, data onboarding, data matching, data enrichment (including CRM enrichment), insights (e.g. for out-of-home advertising), audience verification, analytics/modelling (including in data clean rooms), data targeting in mobile advertising, and transfer of data into activation systems (including marketing ecosystem partners) (“Services”). Please note that, as mentioned above, in general, our Services are comprised of two types: (i) software products (“Software Products”), as part of which we are using solely Zeotap’s proprietary technology to process and arrange the customer data shared by our Clients (as defined below), and (ii) data products (“Data Products”), as part of which we would use User Data either alone or in combination with the customer data shared by our Clients (as defined below). You can learn more about our Products and Services on our website.

Our partners (“Data Partners”) are mobile network operators, mobile application providers, media, technology platform providers, owners of media properties (“Publishers”), brands, agencies and others that have access to certain User Data that they wish to monetize by using our services.

Our clients (“Clients”) are businesses, including brands and agencies (“Advertisers”), Publishers, and other companies that send targeted advertising to mobile consumers. By using our Services, our Clients can address a particular audience and tailor advertisements to the likely interests and preferences of such audience.

We work to ensure that our Services respect users’ privacy rights. To accomplish this goal, we adhere to privacy-by-design and privacy-by-default principles throughout the process of designing, building, and delivering our Services.

By law, we are required to provide you with information regarding:

  • how and on what legal basis we use and disclose your personal data;
  • how we take care of your privacy rights specific to your personal data;
  • how you can reach us in case you have any concerns regarding this privacy policy (“Policy”) or the way we are handling your personal data.

The terms of this Policy apply to all User Data to the extent it contains your personal data as defined in the applicable laws and regulations.

This Policy does not apply to personal data collected by our website zeotap.com. To access our website privacy policy, click here.

This Policy also does not apply to information collected by our Data Partners, Clients or other third parties who may provide personal data to us, as their personal data handling practices are covered by their own privacy policies.

This Policy may change from time to time, so please check back periodically to ensure that you are aware of any changes in our processing of your personal data.

Data categories we receive and use

As part of the Data Products, we receive the following categories of User Data from our Data Partners:

  • mobile advertising device IDs such as Apple’s Identifier For Advertisers (IDFA) and Google Android Advertising ID (“Ad IDs”);
  • cookie IDs;
  • hashed email addresses and hashed telephone numbers;
  • demographic information like age, gender, city/region, income, language and mobile contract data such as prepaid/postpaid (“Demographic Data”);
  • mobile app usage data about apps installed/accessed on a user’s device and app events and browsing data such as browsing URLs (Uniform Resource Locators) (“App Usage and Browsing Data”);
  • purchase data, such as interest in and intent to purchase certain products or services;
  • geolocation data.

We do not receive any ‘special categories of personal data’ (i.e., information about your race, ethnicity, religious or philosophical beliefs, sexual orientation, sex life, political opinions, health, trade union membership, or genetic/biometric data) or, knowingly, any personal information about children under the age of 16.

Our Data Partners may collect data directly from users (both online and offline) or receive data from third parties.

We request that our Data Partners provide users with all required information about the use of their personal data and allow users to exercise their rights according to applicable laws and regulations.

We may also use cookies, pixels and similar tools to collect users’ Ad IDs or cookie IDs ourselves. These tools also automatically collect and send us information such as referral URLs, user agent string, and IP addresses. This information is a normal part of the log file information that is routinely exchanged as part of communication between operating systems.

When we obtain different User Data pertaining to the same device from multiple Data Partners, we aggregate such User Data and store it against the same Ad ID (advertising identifier, associated with a device) or Cookie ID (a string of characters that websites and servers associate with the browser on which the cookie is stored). Zeotap also maintains a separate ID inventory, which connects the User Data into a common ID (“zeoID”) and is an internal pseudonymous identifier.

We enhance User Data to create de-identified data segments and aggregate such segments into segment lists or Ad ID / Cookie ID lists based on our Clients’ preferences. We then share such lists with our Clients to enable them to effectively target the relevant users.

We do not process information that directly identifies a particular individual such as an unencrypted name, address or government-issued ID number. However, whether or not User Data we receive are considered personal or personally identifiable data depends on, among other factors, the definition that applies in a user’s physical location. For example, in some locations, a user’s IP address may be deemed to be personal data, while in others it is not.

We do not interact directly with users or their devices, unless a user sends us a deletion request, as described below under “YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA (INCLUDING OPT-OUT OPTIONS)”

Please note that as part of our Software Products we may receive various additional categories of User Data from our Clients (including directly identifiable data).

Below we describe the User Data categories in more detail.

A. Online identifiers

Advertising IDs

Ad IDs are user-resettable, unique, anonymized identifiers for advertising. Ad IDs identify a specific device and are implemented both on IDFA and Google Android Advertising ID.

We obtain Ad IDs associated with de-identified User Data from our Data Partners. Ad IDs are then used by our Clients to identify advertising requests and to deliver relevant advertisements. We may also use Ad IDs to establish a relationship between different User Data attributes pertaining to the same user. For example, if we obtain User Data that indicates a certain user is between 25 and 30 years old, and later learn from another Data Partner that the user of the same device is interested in a healthy lifestyle, we combine this information against the same Ad IDs or cookie ID.

Cookie IDs

An HTTP cookie (also called web cookie, Internet cookie, browser cookie or simply a cookie) is a small piece of data sent from a website and is stored in the user’s web browser while the user is browsing.

We set third party cookies on behalf of Publishers who provide space for the display of advertising within websites. We may use cookies to establish a relationship between devices or data pertaining to the same user. If we already have information about a device’s user, we may link the information stored in cookies to the device’s Ad ID. We call this activity of linking information “mapping.” We use this information to facilitate the delivery of our Clients’ targeted Ads.

B. Browsing data

Logfile information

In the course of the mapping activity described in the above paragraph, we receive such information as referral URLs, user agent string, and IP addresses.

When you come to the website where Zeotap cookies are set, the log file we automatically receive includes the referral URL, which is the address of the website that you came from. We do not use and discard referral URLs within a reasonable time in compliance with our data retention period.

We use IP addresses to derive information such as country and carrier. Afterwards, we discard IP addresses within a reasonable time in compliance with our data retention period.

We use user agent string information contained in the log file to determine your device operating system and device model. Afterwards, we discard user agent string within a reasonable time in compliance with our data retention period.

C. Offline identifiers

Hashed email addresses and hashed phone numbers

Some Data Partners or Clients may provide their offline data, such as hashed email addresses and hashed phone numbers. We require that such data are hashed using secure hashing algorithms prior to sharing with Zeotap.

We use hashed emails or hashed phone numbers to establish a relationship between offline and online user profiles pertaining to a certain user and enrich the profiles pertaining to those online users. For example, our Client would like to run an advertising campaign on mobile devices targeting users whose hashed email addresses and/or hashed phone numbers the Client already has. However, without respective Ad IDs, the Client cannot target the desired audience. By comparing hashed email addresses and hashed phone numbers provided by the Client with the User Data we have from our Data Partners, we can match hashed email addresses or hashed phone numbers to Ad IDs corresponding to the same user. As a result, we have a list of Ad IDs corresponding to the list of users the Client would like to target. Additionally, we can also enrich those lists with additional profile data, such as the ones described below.

Hashed emails would also serve as a basis for the creation of ID+, our tokenized individual pseudonymous identifier and specific to a user. You can learn more about ID+ here.

D. Profile data

Demographic data

We may obtain demographic User Data from our Data Partners, such as:

  • user demographics (e.g., age or age range and gender);
  • general geographic area of the user address and zip code;
  • predicted or actual income tier;
  • other demographic information that was received or collected by our Data Partners.

Zeotap uses this information to create demographic segments about users, for example, users who are “males, 30 to 34, living in Brooklyn.” We connect segments with Ad IDs so that our Clients can reach their target audiences on mobile devices.

App usage data

We may obtain App Usage and Browsing Data from our Data Partners, such as:

  • apps installed/accessed on a user’s device;
  • app events such as purchases or sign-ins;
  • browsing data such as URLs.

URLs are web addresses, a specific character string that constitutes a reference to a resource. Most web browsers display the URL of a web page above the page in an address bar.

We transform App Usage and Browsing Data into aggregated segments based on interests or purchase intent (such as Sports Enthusiast, Health & Fitness Buffs) which are of interest to our Clients.

Purchase data

We may obtain purchase data from our Data Partners, such as:

  • items you have bought in stores;
  • items you have bought online;
  • items you have put in a shopping basket online.

E. Geolocation data

We may receive data from Data Partners about the physical location of a specific device, including latitude-longitude coordinates obtained through GPS tools, Wi-Fi or cell tower triangulation techniques.

The location data we receive from Data Partners may be generalized, non-precise location data, or we may render the location data non-precise, in order to provide generalized location data to our Clients. Our Clients may use inferences from this information to send localized Ads or targeted Ads. We do not process precise location EU and UK data.

Legal basis for processing personal data

Our Services enable our Clients to among other things tailor advertising you see on your internet browser or mobile device to your interests and preferences. As a result, the number of ads that are not relevant or of interest to you will be reduced. To achieve this goal, we need to process your personal data and such processing operations are covered by your consent, which especially enables our Clients to use customized audience segments to improve and enhance their marketing activities and marketing reach.

Under Data Products, our Data Partners who provide User Data to us collect users consent to process their personal data and share it with us according to their respective privacy policies. The consent collected by our Data Partners complies with the applicable laws requirements and enables Zeotap and its Clients processing activities. Any processing of your personal data by Zeotap is subject to your rights of choice and control as explained below.

For example, for the purpose of enabling to share User Data with Oracle and its customers and partners to use such data for the purpose of personalization and linkage in order to market products and services to you (please refer to Oracle’s privacy policy), we rely on your consent. Your consent is obtained on behalf of Oracle and its customers and partners by our third party data providers.

Some Data Partners may share offline User Data with us on the basis of legitimate interest. We would use such offline User Data only for the purposes of creating and maintaining our identity graph, which we use for identity matching and authentication. The offline User Data (namely, hashed emails or hashed phone numbers) serve as a basis for the creation of ID+, our tokenized individual pseudonymous identifier and specific to a user. You can learn more about ID+ here.

Under Software Products, our Clients are acting as data controllers and are responsible for ensuring that an appropriate legal basis is in place.

Please note that under Data Products, in case we combine our Client data with User Data, our Clients and us act as joint data controllers. With respect to the joint process, we and our Clients jointly determine the purposes and means of processing of User Data. In an agreement on joint controllership pursuant to Article 26 GDPR, we and our Clients have determined how the respective tasks and responsibilities in the processing of personal data are structured and who fulfils which data protection obligations. In particular, it was determined how an appropriate level of security and your rights as a data subject can be ensured, how the information duties under the applicable laws can be fulfilled jointly and how potential data protection incidents can be monitored. This also includes ensuring that reporting and notification obligations are fulfilled.

With whom we share user data

We share User Data with the following categories of third parties for the following purposes:

  • Advertisers – we share Online Identifiers, Browsing Data, Offline Identifiers, Profile Data and Geolocation for the purposes of targeting, analytics, measurement;
  • Publishers and other companies that send targeted advertising to mobile consumers – we share Online Identifiers, Profile Data and Geolocation for the purposes of targeting, analytics, measurement, audience insights;
  • Third party data platforms such as Demand Side Platforms (DSPs), Data Management Platforms (DMPs), advertising marketplaces, ad networks etc. (“Data Platform”) – we share Online Identifiers and Profile Data, for the purposes of data activation, targeting, analytics, measurement;
  • Admeasurement companies– we share Online Identifiers, Browsing Data, Offline Identifiers, Profile Data and Geolocation for the purposes of analytics, measurement;
  • Our hosting provider Google Ireland Limited (“Hosting Providers”) – we share Online Identifiers, Browsing Data, Offline Identifiers, Profile Data and Geolocation for the purposes of storage;
  • Our affiliates – we share Online Identifiers, Browsing Data, Offline Identifiers, Profile Data and Geolocation for the purposes of providing technical support and helping Zeotap operationally perform the Services.

The Advertisers we work with operate in the following businesses: Arts & Entertainment, Automotive, Health & Fitness, Food & Drink, Hobbies & Interests, Home & Garden, News, Finance & Insurance, Science, Pets, Sports, Style & Fashion, Technology & Computing, Tourism & Travel, Real Estate, Shopping.

Publishers we work with include: MediaMond S.p.A., SPEED ITALY Ltd., Triboo Media S.r.l., Sport Network S.r.l., Tg adv S.r.l, CIAO PEOPLE S.r.l., NetAddiction S.r.l., Edizioni Piemme S.p.A., Teads Italia S.r.l., Viralize S.r.l., AtomikAd S.r.l., AdKaora S.r.l., WebAds S.r.l., Instal S.r.l., Smartclip Italia S.r.l., MovingUp S.r.l., ZETA Gestion de Medios, Publipress Media S.L., Zinet Media Global S.L., Diario de Prensa Digital S.L., Posterscope Iberia S.A.U., YOC Spain SLU, WebAds Interactive SL, Hi Media España Publicidad Online, SL (ADUX), Web Financial Group S.A., VLN Servicios Publicitarios Integrales S.L. (Sunmedia), Prisa Brand Solutions, S.L., Blue Media Comunicacion, S.L., Tappcelerator Media SL, RichAudience International SL, Smartclip Hispania SL, Hola SL, Vidoomy Media, SL, Axel Springer España, Teads S.A., mCanvas Advertising Pvt. Ltd., Quint Ltd., Cricketnmore Game Pvt. Ltd., Monsoon Software Consulting Pvt. Ltd., Profit Guru Pvt. Ltd., Matrix Publicities and Media India Pvt Ltd. (Xaxis), Httpool Digital Pvt Ltd, Jagran Prakashan Limited, Inmobi Ltd., Maiden Marketing PTE Ltd. (d.b.a. POKKT), Saavn Media Pvt. Ltd., Lotame Solutions, Inc., Eterno Infotech Pvt. Ltd.

Data Platforms we work with include: adsquare GmbH, Xandr Inc., Inmobi Ltd., Maiden Marketing PTE Ltd. (d.b.a. POKKT), Amobee Inc., Widespace AB, Google Ireland Ltd., The Trade Desk Inc., Adform A/S, Adobe Systems Inc., TAPTAP Networks S.L., Videology Media Technologies B.V., Teads Italia S.r.l., Teads S.A. (global), Smartclip Italia S.r.l., Dentsu Aegis Network Italia SPA, LiveRamp Inc., TabMo SAS (Hawk), Pocket Math Pte Ltd, Bidstalk Technologies Pte Ltd, Mediasmart Mobile S.L., AppLift GmbH, salesforce.com EMEA Limited, Oath EMEA Limited, Facebook, Inc., Narrative I/O Inc., Adex GmbH, Smart Adserver, Lotame Solutions, Inc., Ventes Avenue Pvt Ltd, Neustar Inc., Group M Media India Pvt. Ltd. (mPlatform), MediaMath, Inc., A.MOB SAS, Oracle, Amazon Europe Core SARL, Twitter International Company, Snap Group Limited, Taboola.com Ltd, Weborama SA, FreeWheel Media Inc, PubMatic Inc, Index Exchange Inc, Platform161 BV, Dynamic Yield GmbH, Permutive Limited.

Admeasurement companies we work with include Nielsen Company (US) LLC.

We will also disclose your User Data in response to valid legal processes, for example, in response to a court order, a subpoena or other legal request for information, and/or to comply with applicable legal and regulatory reporting requirements. We also may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or to verify or enforce compliance with the policies governing our products and/or services and with applicable laws, or as otherwise required or permitted by law or consistent with legal requirements. We are required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In addition, we may transfer your information to an entity or individual that acquires, buys, or merges with us, or our affiliates. In these cases, we will require the acquiring company to carry on the material terms of this Policy, including the requests for account deletion.

When we transfer user data internationally

When we share User Data with the recipients described above, such sharing may constitute a transfer outside of your home location. By law, we are required to ensure that the level of protection guaranteed for your personal data by the European and UK laws is not undermined by such transfer. We enter the EU Standard Contractual Clauses with respective User Data recipients, which you can access upon request. Please note that User Data is stored in the following locations: Belgium, South Carolina (US) and Mumbai (India).

How we protect personal data

We have implemented appropriate technical and organizational safeguards to protect any personal data we receive from theft, loss, and unauthorized access. We follow generally accepted standards to protect personal User Data throughout the entire use cycle starting from the initial transfer until deletion. In addition, we limit internal access to your personal data to our employees, agents, contractors, and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority of a breach where we are legally required to do so.

Your rights with respect to your personal data (including opt-out options)

Your personal data belongs to you. You have the following rights with respect to your personal data:

  • right to request confirmation as to whether or not we process any of your data, and, where that is the case, right of access to your data;
  • right to request rectification of inaccurate personal data;
  • right to request the erasure of your personal data;
  • right to restrict processing of your personal data if certain conditions are met, e.g., if you believe the personal data we hold about you is not accurate;
  • right to object to us processing your personal data;
  • withdraw your consent with effect for the future;
  • right to data portability, which only applies, however, if you provided us with your personal data directly.

How to exercise your rights

To opt-out from the processing or exercise your other rights with respect to your personal data, you can directly contact your mobile operator or another Data Partner with whom you shared your personal data (please refer to their respective privacy policy). It is the responsibility of the respective Data Partner to ensure that your request is fully honoured.

Additionally, you can contact us directly. The data we store is encrypted and stored against either (i) an Ad ID or (ii) a Cookie ID. This means that we need your Ad ID and/or Cookie ID in order to find all your data that are present in our system.

Alternatively, we can check whether the data attribute that you sent us in your request (e.g. a telephone number or e-mail address) is stored in our system in a hashed format, however, if the hashed telephone number or hashed e-mail address is not stored in our system, and you did not provide us with your Ad ID and/or Cookie ID, we will not be able to find other related data that might still be stored in our system.

Therefore, in order to be able to process and respond to your request properly and fully, we provide you with the following different channels to exercise your rights:

  1. You can ask for access and/or deletion of your data stored against a Cookie ID, through our website portal
  2. You can ask for access and/or deletion of your data stored against an Ad ID, through our proprietary mobile App (“Data Protection Rights App”) that can be downloaded via Google Play and/or the Apple Store
  3. You can also submit your requests by completing this form

Apart from all the above rights, you can also lodge a complaint with a supervisory authority if you believe we or our Data Partners infringed upon your rights.

If you are a California resident, please also visit the Section “DO NOT SELL MY PERSONAL INFORMATION LINK”.

Moreover, you can always use the following mechanism to opt-out from targeted advertising:

  • you may select  “Limit Ad Tracking” on iOS or “Opt-out of interest-based ads” on Google Android. In this case, we will keep your User Data until you request us to delete it, but we will not use it for targeted advertising purposes, and activity on your mobile device will be effectively invisible to us. You may reset the Ad ID by selecting the option “Reset Advertising Identifier” on Apple iOS or “Reset Advertising ID” on Google Android. This will delete your current Ad ID from your device and replace it with a new Ad ID. As a result, we will not receive any Bid Requests containing the old Ad ID anymore. After a certain amount of time, we will delete the old Ad IDs and related User Data. However, we may receive access to your new Ad ID and match it with other User Data we might receive from our Data Partners over time.
  • you can clear or block our cookies in the settings of your mobile browser. In this case, we will keep your data, but we will not be able to use it to target your device when you are browsing mobile websites. However, regardless of the deletion of cookies, your device can still be targeted when you are using apps on the basis of your Ad ID.
  • you may also visit the webpage http://youradchoices.com/appchoices and/or download the mobile AppChoices app. For more information about targeted advertising and opt-out options, you may visit for example the webpage of Network Advertising Initiative’s at http://www.networkadvertising.org/choices and/or Your Online Choices at www.youronlinechoices.com/uk.

Please also note that using the above options does not mean you will block mobile advertising, but it means that the ads you receive will not be personalized for you.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioural advertising services) that you do not wish such operators to track certain online activities, over time and across different websites. We do not honour “Do Not Track” signals.

Information on data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.

We retain data until the occurrence of the following events:

  • request from a Data Partner to delete certain User Data; or
  • the user submits his Ad ID to us for deletion of associated data; or
  • expiration of the Zeotap defined retention period with a deletion of unused profiles after 3 months.

Please note that our cookies have the following storage durations:

  • zc: Cookie dropped against .zeotap.com domain. Purpose: User identification. Expiry: 365 days
  • zsc:  Cookie dropped against .zeotap.com domain. Purpose: Frequency capping for cookie syncing. Expiry: 1-day
  • zi:  Cookie dropped against site domain as first-party cookie. Purpose: User Identification. Expiry: 365 days
  • idp:  Cookie dropped against site domain as first-party cookie. Purpose: User Identification. Expiry: 365 days

zuc: Cookie dropped against .zeotap.com domain to store the consent value. Purpose: User Identification. Expiry: 365 days

Your California Privacy Rights

California does not track disclosures

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioural advertising services) that you do not wish such operators to track certain online activities, over time and across different websites. We do not honour “Do Not Track” signals.

California Consumer Privacy Act (“CCPA”) compliance

The categories of Personal Information (as defined under CCPA) that we have processed (including according to CCPA definition “selling”) over the past 12 months and the usage purposes are the following:

Data categories we receive and use

A. Identifiers

Advertising IDs

Ad IDs are user-resettable, unique, anonymized identifiers for advertising. Ad IDs identify a specific device and are implemented both on Apple iOS (IDFA) and Google Android Advertising ID.

We obtain Ad IDs associated with de-identified User Data from our Data Partners. Ad IDs are then used by our Clients to identify advertising requests and to deliver relevant advertisements. We may also use Ad IDs to establish a relationship between different User Data attributes pertaining to the same user. For example, if we obtain User Data that indicates a certain user is between 25 and 30 years old, and later learn from another Data Partner that the user of the same device is interested in a healthy lifestyle, we combine this information against the same Ad IDs or cookie.

Cookie IDs

An HTTP cookie (also called web cookie, Internet cookie, browser cookie or simply a cookie) is a small piece of data sent from a website and is stored in the user’s web browser while the user is browsing.

We set third party cookies on behalf of Publishers who provide space for the display of advertising within websites. We may use cookies to establish a relationship between devices or data pertaining to the same user. If we already have information about a device’s user, we may link the information stored in cookies to the device’s Ad ID. We call this activity of linking information “mapping.” We use this information to facilitate the delivery of our Clients’ targeted Ads.

B. Internet or other electronic network activity information

Logfile information

In the course of the mapping activity described in the above paragraph, we receive such information as referral URLs, user agent string, and IP addresses.

When you come to the website where Zeotap cookies are set, the log file we automatically receive includes the referral URL, which is the address of the website that you came from. We do not use and discard referral URLs within a reasonable time in compliance with our data retention period.

We use IP addresses to derive information such as country and carrier. Afterwards, we discard IP addresses within a reasonable time in compliance with our data retention period.

We use user agent string information contained in the log file to determine your device operating system and device model. Afterwards, we discard user agent string within a reasonable time in compliance with our data retention period.

App usage and browsing interest data

We may obtain App Usage and Browsing Data from our Data Partners, such as:

  • apps installed/accessed on a user’s device;
  • app events such as purchases or sign-ups;
  • browsing data such as URLs (Uniform Resource Locators).

URLs are web addresses, a specific character string that constitutes a reference to a resource. Most web browsers display the URL of a web page above the page in an address bar. We transform App Usage and Browsing Data into aggregated segments based on interests or purchase intent (such as Sports Enthusiast, Health & Fitness Buffs) which are of interest for our Clients.

C. Customer records information

Hashed email addresses and hashed phone numbers

Some Data Partners or Clients may provide their offline data such as hashed email addresses and hashed phone numbers. We require that such data are hashed using secure hashing algorithms prior to sharing with Zeotap.

We use hashed emails or hashed phone numbers to establish a relationship between offline and online user profiles pertaining to a certain user and enrich the profiles pertaining to those online users. For example, our Client would like to run an advertising campaign on mobile devices targeting users whose hashed email addresses and/or hashed phone numbers the Client already has. However, without respective Ad IDs, the Client cannot target the desired audience. By comparing hashed email addresses and hashed phone numbers provided by the Client with the User Data we have from our Data Partners, we can match hashed email addresses or hashed phone numbers to Ad IDs corresponding to the same user. As a result, we have a list of Ad IDs corresponding to the list of users the Client would like to target. Additionally, we can also enrich those lists with additional profile data, such as the ones described below.

Hashed emails would also serve as a basis for the creation of ID+, our tokenized individual pseudonymous identifier and specific to a user. You can learn more about ID+ here.

Demographic data

We may obtain demographic User Data from our Data Partners, such as:

  • user demographics (e.g., age or age range and gender);
  • general geographic area of the user address and zip code;
  • predicted or actual income tier;
  • other demographic information that was received or collected by our Data Partners.

Zeotap uses this information to create demographic segments about users, for example, users who are “males, 30 to 34, living in Brooklyn.” We connect segments with Ad IDs so that our Clients can reach their target audiences on mobile devices.

D. Commercial information

Purchase data

We may obtain purchase data from our Data Partners, such as:

  • items you have bought in stores;
  • items you have bought online;
  • items you have put in a shopping basket online.

E. Geolocation data

We may receive data from Data Partners about the physical location of a specific device, including latitude-longitude coordinates obtained through GPS tools, Wi-Fi or cell tower triangulation techniques.

The location data we receive from Data Partners may be generalized, non-precise location data, or we may render the location data non-precise, in order to provide generalized location data to our Clients. Our Clients may use inferences from this information to send localized Ads or targeted Ads. We do not process precise location data.

With whom we share your personal data

The list of Businesses/Service Providers with whom we share Personal Information is the following:

We share User Data with the following categories of third parties:

  • brands and agencies (“Advertisers”);
  • owners of media properties (“Publishers”) and other companies that send targeted advertising to mobile consumers;
  • third party data platforms such as Demand Side Platforms (DSPs), Data Management Platforms (DMPs), advertising marketplaces, ad networks etc. (“Data Platform”);
  • admeasurement companies;
  • our hosting provider Amazon Web Services and GCP (Google Cloud Platform) (“Hosting Providers”);
  • our affiliates.

We share the following Personal Information categories for the following purposes:

  • Advertisers – we share Identifiers, Internet or Other Electronic Network Activity Information, Customer Records Information, Commercial Information and Geolocation for the following purposes: targeting, analytics, measurement;
  • Publishers – we share Identifiers and Commercial Information for the following purposes: targeting, analytics, measurement, audience insights;
  • Data Platforms – we share Identifiers and Commercial Information, for the following purposes: data activation, targeting, analytics, measurement;
  • Admeasurement companies – we share Identifiers, Internet or Other Electronic Network Activity Information, Customer Records Information, Commercial Information and Geolocation for the following purposes: analytics, measurement;
  • Hosting Providers – we share Identifiers, Internet or Other Electronic Network Activity Information, Customer Records Information, Commercial Information and Geolocation for the following purposes: storage;
  • Affiliates – we share Identifiers, Internet or Other Electronic Network Activity Information, Customer Records Information, Commercial Information and Geolocation for the following purposes: technical support and help Zeotap operationally perform the services.

We have disclosed the following categories of personal information about consumers for valuable consideration in the preceding 12 months:

  • identifiers
  • internet or other electronic network activity information
  • customer records information
  • commercial information
  • geolocation

We have disclosed the following categories of personal information about consumers for a business purpose in the preceding 12 months:

  • identifiers
  • internet or other electronic network activity information
  • customer records information
  • commercial information
  • geolocation

Data partners

The sources (“Data Partners”) of Personal Information are mobile network operators, mobile application providers, media, and technology platform providers, brands, agencies and others that have access to certain customer information (“User Data”) that they wish to monetize by using our Services.

Non-discrimination

The sources (“Data Partners”) of Personal Information are mobile network operators, mobile application providers, media, and technology platform providers, brands, agencies and others that have access to certain customer information (“User Data”) that they wish to monetize by using our Services.

Your rights and choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights:

You have the right to request that Zeotap discloses certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (in the ways described below), we will disclose to you:

  • the categories of Personal Information we collect about you.
  • the categories of sources for the Personal Information we have collected about you.
  • 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 (also called a data portability request).
  • if we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
    • sales, identifying the Personal Information categories that each category of recipient purchased; and
    • disclosure for a business purpose, identifying the Personal Information categories that each category of the recipient.

Deletion request rights

You have the right to request that Zeotap deletes any of your Personal Information that we processed. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers and recipients to delete) your Personal Information from our records, unless an exception applies and according to the section “Information Retention” above.

How to exercise your rights – access, data portability and deletion rights

The data we store is encrypted and stored against either (i) an Ad ID or (ii) a Cookie ID. This means that we need your Ad ID and/or Cookie ID in order to find all your data that are present in our system.

Alternatively, we can check whether the data attribute that you sent us in your request (e.g. a telephone number or e-mail address) is stored in our system in a hashed format, however, if the hashed telephone number or hashed e-mail address is not stored in our system, and you did not provide us with your Ad ID and/or Cookie ID, we will not be able to find other related data that might still be stored in our system.

Therefore, in order to be able to process and respond to your request properly and fully, we provide you with the following different ways to exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • calling our toll-free number +1 (888) 914-9661 and when prompted enter our unique Zeotap code: 629984. Once your request has been received, we will process this as soon as possible.
  • completing this form.

We will delete all Personal Information associated with the submitted data attributes. This will delete all related Personal Information and prevent any future collection and use of Personal Information associated with the submitted data attributes (for example, the Ad ID). If we did not have your Ad ID, but had some other Personal Information such as cookies, hashed email addresses or hashed phone numbers, we will keep these Personal Information unless our Data Partner informs us that these have to be deleted. Similarly, if we have your other Ad IDs and/or Cookie IDs, we will keep them together with associated data unless you file an opt-out request including other Ad IDs and/or Cookie IDs.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative;
  • describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

When we receive one or more of the above requests from you or a person registered with the California Secretary of State that you authorize to act on your behalf (“Authorized Agents”).

We will verify your identity by asking for your Ad ID or Cookie ID and/or, depending on the method you used to submit your request, we may ask for an additional email confirming that the request is coming from you. We will verify your agent’s identity, and that your agent has been authorized to make a request on your behalf by providing us with a signed written authorization or a copy of a power of attorney. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Do not sell my personal information link

You may also exercise your right to opt-out of sale by clicking the following link:

DO NOT SELL MY PERSONAL INFORMATION

Contact

If you have any questions or suggestions about this Policy and our privacy practices, please contact us here or through the below channels:

By email: [email protected]

By post to Zeotap: zeotap GmbH, Privacy Team, Warschauer Platz 11-13, 10245 Berlin, Germany

By post to our UK representative: zeotap UK Limited, 16 Great Queen Street, Covent Garden, London WC2B 5AH, United Kingdom

By post to our external DPO: ePrivacy GmbH, Prof. Dr. Christoph Bauer, Große Bleichen 21, 20354 Hamburg, Germany

This Policy was last modified in August 2021.