Please read this Privacy Policy carefully to understand how Playwire LLC, its subsidiary and affiliate corporations, successors, and assigns (collectively, “Playwire”) uses and protects the information you provide.
This “Privacy Policy” applies to www.playwire.com, the Playwire Platform (see below), and any other websites owned or operated by Playwire or that may be subsequently added, variations or successors to this website (the “Playwire Sites”), any Playwire computer software downloadable or otherwise available from the Playwire Sites (“Software”), Playwire’s services, including but not limited to, the Playwire digital advertising technology, advertising management services, mobile applications, Revenue Intelligence™, RAMP™, Trendi™, Kids Club®, and all other Playwire platforms and networks (collectively referred to as the “Services, Platforms and Networks”)
This Privacy Policy applies to all Users of the Playwire Sites, Software, the Services, Platforms and Networks. If you are interested in finding out more information regarding our GDPR compliance, click here.
Last Updated: Mar 16, 2023
By use of the Services, Platforms and Networks, Playwire may collect two (2) types of information about Users: Personal and Non-Personal. In addition, Playwire works with advertisers, ad agencies, third-party traffic measurement services and other service providers (collectively “Third Parties”) to serve advertisements on publishers using the Playwire Services, Platforms and Networks. Third Parties may set and access their own tracking technologies on your device including but not limited to cookies, web beacons, device identifiers and other information as described below.
https://www.youronlinechoices.com/uk/your-ad-choices
https://youradchoices.com/appchoices
https://allaboutcookies.org/how-to-manage-cookies
LiveRamp:
When you use Playwire Publisher Websites and enter your email address on their websites (either to log in, or to sign up for a newsletter, or similar), we may share with LiveRamp and its group companies information that we collect from you, such as your email (in hashed, pseudonymous form), IP address, or information about your browser or operating system, with any of the following, acting as “joint controllers” (as applicable and defined in the GDPR).
LiveRamp uses this information to create an online identification code that we may store in our first-party cookie for our use in online, in-app, and cross-channel advertising. This may be shared with advertising companies to enable interest-based and targeted advertising. LiveRamp uses this information to create an online identification code for the purpose of recognising you on your devices. This code does not contain any of your directly identifiable personal data and will not be used by LiveRamp to re-identify you.
Detailed information on LiveRamp’s data processing activities is available in LiveRamp’s privacy policy https://liveramp.com/privacy/. You have the right to withdraw your consent or opt-out to the processing of your personal data at any time https://liveramp.com/opt_out/.
Trade Desk UID:
https://transparentadvertising.org/
https://adssettings.google.com/authenticated
https://tools.google.com/dlpage/gaoptout
Mobile device system software such as Apple iOS or Google Play Services provide mechanisms that allow users to opt out of the use of information about their usage of mobile apps to deliver targeted ads to their mobile device. For more information, or to opt out using these mechanisms, consult your device settings (“Opt out of Personalized Ads” on Android devices and “Limit Ad Tracking” on iOS devices). When Playwire’s technology encounters “Limit Ad Tracking” signals they are respected. Devices vary in where they include the setting to adjust.
We use, and allow third parties as set forth herein to use, the information we collect for the following purposes:
Upon request, Playwire shall allow Users to update or correct Personal Information previously submitted, but only to the extent such activities will not compromise privacy or security interests. Additionally, upon request, Playwire shall delete Personal Information from the database where such information is stored; however, it may be impossible to entirely delete a User’s entry without some residual information being retained due to the manner in which data backups are maintained. Requests to delete Personal Information shall be submitted to legal@playwire.com.
If you reside or are located in certain jurisdictions, you may have rights and protections regarding the collection, processing, sharing, and use of your data under a particular jurisdiction’s law. This may mean that you may have the right to:
A. Persons Covered. If you are located in the European Economic Area (EEA), the General Data Protection Regulation (GDPR) applies to our processing of personal data. If you are located in the United Kingdom, then the Data Protection Act 2018 applies to our processing of personal data. These laws each grant those located respectively in the EEA and the UK a set of clear privacy rights and imposes responsibilities on Playwire as we process the personal data of data subjects located in those places. This section is designed to provide more information on how Playwire adheres to the GDPR and the Data Protection Act 2018 and your rights as a data subject located in the UK or the EEA.
B. Definition of Personal Data. Both the GDPR and UK Data Protection Act define personal data broadly. As such, where Usage Data and/or Profile Information relates to an individual in the EEA or UK we treat it as personal data. This includes: a) data collected via visits to Playwire.com; b) data collected from customers, Publishers and business partners; and c) data collected from employees and prospective employees.
C. Special Categories of Personal Data. Playwire does not collect nor process any special categories of personal data with respect to UK or EEA data subjects, and we do not create Profile Information of audience segments of such consumers based on special categories of personal data (i.e. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health, or data concerning a natural person’s sex life or sexual orientation).
D. Legal Basis for Processing. Both the UK Data Protection Act and GDPR requires entities seeking to process personal data to have a valid legal basis for doing so. The legal basis utilized by Playwire includes: a) consent; b) legitimate interest (i.e., where we believe that our need to process the data and/or the value we deliver by processing such data is not outweighed by the rights of the data subject); c) where necessary for the performance of a contract; and d) where processing is necessary to comply with our legal obligations. We will endeavor to outline our legal basis for the most common types of processing conducted by Playwire.
I. Cookie and Similar Tracking Technologies – We endeavor to obtain consent for our placement of cookies, pixels and similar tracking technologies as required under the ePrivacy Directive as implemented throughout the EEA. As Playwire does not have direct relationships with Internet users in many cases, we ask Publishers and other partners to obtain a consent on our behalf as described below. Where we directly place cookies (e.g., via Playwire.com) we directly obtain the consent from data subjects we’ve identified as being from the EEA or other place where consent is required.
II. Usage Data and Profile Information – While we obtain a consent for our placement of cookies as described above, Playwire processes Usage Data and Profile Information under our legitimate interest. For purposes of clarity, where this data is utilized for analytics, targeted advertising, measurement or reporting, we also process it via legitimate interest. To offer additional transparency, we endeavor to mention some of these use cases in the consents obtained for cookies and pixels.
III. Website Data – We collect personal data via Playwire.com. Where that data is provided to Playwire (e.g., via completing an online form), we consider it either Account Data and/or data collected pursuant to a Business Relationship which are described below. Where we place cookies via the website, we use consent. Where data is collected automatically (e.g., log files containing IP addresses), we process such data via our legitimate interest and in order to maintain the website and help us to a better job of personalizing the website to the interests of visitors.
IV. Account Data and Business Relationships – We require some Publishers to setup an Account with Playwire. Similarly, we maintain accounts containing personal data with most of the vendors who provide services to Playwire, our customers, our employees and our business partners. If you are an employee of one of those entities, Playwire may have your personal data including your name, your work email or your work telephone number. For data subjects located in the EEA or UK, we process this data under the legal basis of contractual necessity. In other words, we need to process this data in order to honor the terms of the contract between Playwire and the Publisher, customer, vendor, etc. This includes maintaining an account and login credentials, billing and payment purposes, communicating with the other party, and fulfilling requests. Where we are seeking to market additional products and services to these entities, we will do so via legitimate interest unless applicable law dictates that we use consent (e.g., for email marketing).
V. General Purposes – There are a number of instances where Playwire processes personal data which are distinct from the descriptions provided above. For example:
A. Legal and Regulatory Compliance – Like most companies, Playwire will process data in order to comply with law, cooperate with requests from competent legal authorities such as the police, and to pay taxes. The legal basis for this type of processing is necessary for Playwire to meet our legal and regulatory obligations.
B. Enforcement of Legal Obligations – To enforce our terms and conditions, protect of our intellectual property and/or the rights of third parties, Playwire processes personal data in these instances via our legitimate interest. This may include obtaining advice and conducting legal proceedings.
C. Sell and Promote Our Business – Playwire may choose to conduct, evaluate and/or promote the sale of our business via our legitimate interest.
D. Aggregated Data – Where we aggregate data and remove digital identifiers (e.g., cookie IDs), we may use this data for internal research, marketing, and statistical analysis purposes.
E. UK and EU Data Subject Rights. Where the GDPR or UK Data Protection Act applies, such data subjects have certain rights, including: a) The right to be informed about the types of data being processed and the legal basis for processing; b) the right to access and see the data being processed; c) the right of rectification, to make corrections to data subject to processing; d) the right to erase data; e) the right to restrict processing of data; f) the right of data portability; g) the right to object to the processing of data and f) the right not to be subject to automated decision-making. Some of these rights apply only in certain circumstances and depend on the legal basis relied upon to process the data. As an example, the right to object applies to processing which is carried out because it is necessary for our legitimate interests and only if we cannot demonstrate compelling legitimate grounds which outweigh your rights, interests and freedoms. The same right does not apply to processing which is necessary for us to comply with our legal obligations or to perform a contract with you. Given that both the UK Data Protection Act and the GDPR defines personal data broadly, these rights may extend to the personal data we place into cookies or similar tracking technologies.
Where processing is based on your consent, in accordance with the GDPR and UK Data Protection Act (as applicable), you may withdraw that consent at any time, although any processing previously carried out will still be legal. In order to exercise your data subjects’ rights or if you have any questions about these rights, you can write to us at gdpr@playwire.com . We will endeavor to respond to any requests to exercise your rights within one month from when they are made, although this period may be extended in some cases in which case we will inform you before the expiration of the one month period.
You also have the right to submit complaints to the supervisory authority in your jurisdiction. A list of supervisory authorities in the EEA can be found here: https://edpb.europa.eu/about-edpb/board/members_en.
F. Cross-border transfers of EU or UK Personal Data. We generally process data in the United States. When we share data, we provide data to companies globally. In each case, we have safeguards in place which allow those transfers to happen in a way that ensures data is handled in accordance with the applicable law.
When we transfer personal data outside the EEA or UK, unless the recipient or location to which the data is transferred has been approved by the appropriate authorities as providing an adequate level of protection for personal data, we put in place measures to ensure that the transfer complies with the applicable data protection law and that the personal data which is transferred is appropriately safeguarded.
G. Data Protection Officer. Playwire has appointed a data protection officer to supervise our personal data processing-related activities, and to respond to requests as required. Our Data Protection Officer can be contacted as follows: gdpr@playwire.com
1. Overview of California Consumer Privacy Laws
This California Privacy Policy applies only to California consumers (“you” or collectively as “consumers”) and supplements the Playwire Privacy Policy (collectively, “we,” “us,” or “our”). The California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”), collectively referred to as “California Consumer Privacy Laws”, provide California consumers with specific rights regarding their personal information. This California Privacy Policy describes a California consumer’s privacy rights under the California Consumer Privacy Laws, explains how you may exercise your privacy rights, and provides an overview on the types of personal information we collect.
2. California Consumer Privacy Laws provide you with the following rights:
3. Information We May Keep. California Consumer Privacy Laws allow us to keep your personal information that we need to provide you with goods and services, ensure the security and integrity of your personal information, fix any errors, exercise free speech, use your information lawfully for our internal purposes, and to comply with the law.
4. Contact. California Consumer Privacy Laws allow you to exercise your privacy rights and request your information from us, at no cost. We will provide our response in a readily usable format, which is usually electronic. If you would like to exercise any of your privacy rights, please contact us through any of the following:
by writing to:
Playwire, LLC
Attn: Privacy
4855 Technology Way
Suite 500
Boca Raton, Florida 33431
by email: legal@playwire.com
5. Verification of Your Identity. To protect your privacy, we will ask you to verify your identity. We will ask you to confirm your name, email address, phone number and other information so that we can reasonably confirm your identity. We will not share any information until we can reasonably confirm your identity.
6. Our Response Time to Your Privacy Request
7. Authorized Agent. California Consumer Privacy Laws allow you to ask someone else to exercise your privacy rights for you. This person is your “Authorized Agent.” Before we will share anything with your Authorized Agent, you will need to provide your written permission or other proof, such as a valid Power of Attorney. Please contact us if you would like us to know who your Authorized Agent is. Once we have your written permission, we will also ask your Authorized Agent to verify their identity with us directly. We will not share any of your information with your Authorized Agent unless we have both your written permission and have verified the identity of your authorized agent.
8. Information Collection and Use- Sources of Information. Please refer back to https://www.playwire.com/privacy-policy. To help consumers make informed privacy decisions, the California Consumer Privacy Laws create and define categories of personal information. Some types of personal information may apply to multiple categories. We collect the categories of personal information described in Table 1 below. Depending on your level of interaction with us, we may not have collected your personal information from all of the categories.
Categories of Personal Information | Specific Types of Personal Information | Categories of Sources of Collection |
Identifiers | A. Identifiers such as name and email that you choose to provide to us when you email us, complete an online form or register for our products or services. B. IP Address that your devices uses to connect to the internet | A. Directly from you, the user B. From your device when accessing our website or one of our publisher Websites/Apps that utilize our technology or services |
Internet or other electronic network activity | Browser and Device Information, User Agent,IP Address, Mobile Device Identifiers such as IDFA or AAID/GAID, custom or external unique Identifiers, search history and information on interaction with our publisher websites, their content and advertisements | Through our Publisher Websites/Apps that use our technology or services when you access those Websites/Apps |
Location | Regional location of the users device | Through the IP address of your device, collected through our publisher Websites/Apps that utilize our technology as you access them |
Inferences | Inferences drawn from the above mentioned categories to create an advertising profile reflecting perceived interests and behavior of a user | Through our Publisher Websites/Apps that use our technology or services when you access those Websites/Apps |
9. Business Purposes Of The Personal Information We Collect And Sell. Table 2 is a list of the categories of personal information we disclosed about consumers for a business purpose in the preceding 12 months.
Categories of Personal Information | Business or Commercial Purpose |
Identifiers such as name and email that you choose to provide to us when you email us, complete an online form or register for our products or services. | A. Providing Customer Service, maintaining and servicing your account and communicating with you. B. Auditing customer interactions C. Advertising and marketing company news and products to you D. Maintaining and ensuring quality of services, improve users experience |
IP Address that your devices uses to connect to the internet or other electronic network activity, Location Data, Inferences | A. Providing data services which analyze how users interact with content and advertisements on website/apps B. Analytics and research activities to improve our products and services C. Detecting security incidents, illegal or fraudulent activities D. Debugging and troubleshooting purposes to improve service, fix errors and maintain usability of services |
10. Categories Of Personal Information We Sell Or Disclose For A Business Purpose
Table 3 below describes the categories of personal information we sell or disclose for business purposes. These are also the categories of information we sold in the past 12 months. The sources for each category of personal information we collect, the business or commercial purposes for which we use each category of personal information, and the third parties with whom we may share your personal information with.
Categories of Personal Information | Categories of Third Parties to Whom the information is disclosed or sold |
IP Address that your devices uses to connect to the internet, Internet or other electronic network activity, Location Data, Inferences | A. Providing Customer Service, maintaining and servicing your account and communicating with you. B. Auditing customer interactions C. Maintaining and ensuring quality of services, improve users experience D. Marketing company news and products to you E. Advertising Services F. Maintaining and ensuring quality of services, improve users experience |
Playwire collects the personal information described above for a variety of business and commercial purposes.
For Ad Services, we use the personal information collected to provide our services; serve ads; provide information and reports to Media Buyers; prevent End Users from seeing the same ad too many times; customize and personalize ads; analyze ad performance; deliver Internet-based and location-based advertising; detect and prevent fraud and protect the security of our Ad Services; provide, manage and improve our Ad Services and develop new services; calculate usage levels of our Ad Services, help diagnose server problems and administer our Ad Services; and as we believe to be necessary or appropriate, such as to comply with legal requirements.
For Playwire properties, we use the personal information collected to send marketing and promotional communications; send administrative information; engage in and process transactions; post testimonials; provide interest-based advertising and engage in analytics on your activity on the Playwire Properties and other websites over time; manage accounts and provide customer support or other services; improve the content and quality of Playwire’s Properties and Ad Services; for legal purposes; and for our business purposes, such as to evaluate and improve our products, services, marketing, and client relationships.
Categories of Third Parties to Whom We May Disclose or Sell Personal Information
We may disclose any of the personal information we collect for our business purposes, or sell the personal information, to the following categories of third parties:
Playwire continually strives to implement new technologies and processes to better protect you, your privacy and your use of the Playwire Sites. As a result, changes to this Privacy Policy may be made by Playwire from time to time. If we make changes, we will post them here and update the date above. If we make material changes to this Policy, we may take additional measures to notify you and, if necessary, gain your prior consent. In no event will these changes result in the degradation of any of the security measures designed to protect you from unauthorized disclosure, as such measures are described in this Privacy Policy.