US Privacy Notice
This US Privacy Notice (the “Notice”) supplements OpenWeb Privacy Policy (available here: the “Privacy Policy” or “Policy”) and addresses specific disclosure requirements under US Privacy Laws.[1]
Most of the statements, rights and obligations under this part are common to all US Privacy Laws and apply to you only to the extent determined in the applicable law according to your residency.
Any capitalized terms throughout this Notice (such as Personal Information, Publishers, Advertisers, Websites, End Users, etc.) shall have the same meaning as defined in the Privacy Policy.
TABLE OF CONTENTS
- Collection, Disclosure and Sharing of Personal Information
- Your Rights Under US Privacy Laws
- Direct Marketing Requests
- Updates to This Notice
- Collection, Disclosure and Sharing of Personal Information
In the preceding 12 months, we have collected the following Personal Information:
| Categories of Personal Information | Data Types |
| Identifiers | For example, name, surname, email, phone number, username, password, social media accounts, and profile picture |
| Personal information categories listed in the California Customer Records statute | For example, name, address, telephone number, profile picture, employment (only from business partners) |
| Internet or other similar network activity | Your interactions with the Services, for example, likes, preferences, information included in your comments, and other interactions within our Services, including with other users on our Services. Additional Information also includes IP addresses, unique device identifiers, device and operating system, browser version, pages visited, advertisements viewed or clicked on, your geographic location, log data and other information derived from your interaction with our Services. |
| Geolocation data | IP address and your geographic location |
| Professional or employment-related information | From our business partners: title or profession, employer, etc. |
| Inferences drawn from other personal information | End user: Profile reflecting the preferences and interactions with our Services on Publisher assets (such as, age, gender, income level and interests) |
Sources of Information
In the preceding 12 months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:
- Directly, through your activity on our Services: For example, from forms you complete on our Websites, interactions (such as comments) on our Platform.
- Indirectly from you: We track your activities across the internet, for example, when you view or interact with certain content, web page or ad, or when we collect your usage data automatically from measurement tools such as those implemented on our Publishers’ properties.
- From third-parties: For example, from Publishers, Advertisers, service providers who assist us in performing the Services for our customers, internet service providers, data analytics providers, social networks, and data brokers.
We do not “Sell” but we may “Share” Personal Information about you, as these terms are defined under US Privacy Laws.
In the preceding twelve (12) months we may have shared and disclosed your Personal Information, as described below:
| Category of Recipient | Type of Data | Disclosed or Shared |
| Advertisers | Unique identifiers, IP address, user activity data (interaction with Ads) | Shared |
| Publishers | All types of Personal Information | Shared and Disclosed |
| Service Providers | All types of Personal Information | Disclosed |
| Any Acquirer of Our Business Entities within OpenWeb Group | All types of Personal Information | Disclosed |
| Legal and Regulator Entities | Subject to law enforcement or a competent authority request. |
When we disclose Personal Information, we ensure that the recipient only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the Personal Information they receive, and to use it for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulation (such service providers may use other Non-Personal Data for their own benefit).
Purposes for Collection, Use, & Sharing
In addition to the practices detailed in Sections 1 and 2 of the Privacy Policy, as applicable, we also use and disclose the Personal Information we collect for the following commercial and business purposes:
- Auditing related to our interactions with you;
- Legal compliance;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and necessary prosecution;
- Debugging;
- Performing services (for us or our service provider);
- Internal research for technological improvement;
- Internal operations;
- Activities to maintain and improve our services; and
- Other one-time or short-term uses.
- Your Rights Under US Privacy Laws
Where applicable, you may have the following rights under US Privacy Laws in relation to Personal Information we have collected about you, to the extent required by the US Privacy Laws and subject to verification and any applicable exceptions. These rights are:
Right to Know/Access: You have the right to request that we disclose certain information to you about our collection and use of certain personal information about you as described below:
- The specific pieces of Personal Information collected;
- The categories of Personal Information collected;
- The categories of sources from whom the Personal Information is collected;
- The purpose for collecting or sharing the Personal Information; and
- The categories of third parties with whom we have shared the Personal Information.
Right to Delete: You have the right to request that we delete the personal information.
Correct Inaccurate Data: The right to correct inaccurate Personal Information that we maintain about you.
Opt-Out of Sharing for Cross-Contextual Behavioral Advertising: You have the right to opt-out of the “sharing” of your Personal Information for “cross-contextual behavioral advertising” (all as defined under the CCPA), often referred to as “interest-based advertising” or “targeted advertising”.
Data Portability: You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format.
Right to Non-Discrimination: You have the right to be free from unlawful discrimination by us for exercising any of the rights above.
If you would like to exercise your rights mentioned in the section, please contact us at: privacy@openweb.com. To fulfill your request, we will need to verify your identity and validity of your request.
For users of the Platform, OpenWeb provides the ability to exercise the rights for access and deletion via the ‘User Privacy’ section available on our Platform.
Please note that in some cases, you will also be required to submit your request directly to the relevant Publisher.
Please be aware that only you, or someone legally authorized to act on your behalf, may make a request related to personal information collected about you. To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf.
In some jurisdictions, you have the right to appeal a rejection to your request. The appeal request shall be submitted to privacy@openweb.com, or using the contact details specified in the “Contact Us” section in the Privacy Policy.
- Direct Marketing Requests
California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at privacy@openweb.com.
- Updates to This Notice
We may modify this Notice from time to time in which case we will update the “Last Updated” date at the top of this Notice, and will notify you and take other steps as required by applicable law. The updated US Privacy Notice will be effective as of the time of posting, or such later date as may be specified in the updated Notice.