Barometric® Privacy Policy

This Privacy Policy describes, in Plain English, the steps taken by Barometric to safeguard the privacy rights of users of the Barometric Hosted Service, as well as visitors to the Web site barometric.com, including how Barometric accesses or otherwise engages with different types of data. As a leading provider of digital (mobile and desktop) advertising attribution services, our mission is to provide advertisers and their agencies with information related to the value derived from their digital advertising investments. We do this by observing user activity on participating publisher websites (including activity with digital ads on such properties) and then analyzing such information and in some cases supplementing it with available third party data. In our pursuit of these business objectives we adhere to the fundamental principles of transparency, user control and data security. Barometric, a separate division of AdTheorent, Inc., is a member of the Internet Advertising Bureau and adheres to the IAB/DAA’s Self-Regulatory Principles for Online Behavioral Advertising, including the unique principles applicable to the mobile environment. Barometric is an attribution and measurement solution and does not engage in the business of digital advertisement targeting.

Privacy Policy is subject to change from time to time, in which case we will post an updated version on the Privacy section of our Web site. Changes to this Privacy Policy will take effect 30-days after the updated Privacy Policy is posted to our Web site’s privacy page, located at www.barometric.com/privacy.

I. Information Collected By The Barometric Hosted Service

Information & Data We Collect

The advertisers and publishers with whom we work insert a small bit of computer code on their websites or within their digital ads. This code directs a user’s web browser to contact Barometric’s servers, record non-personal information conveyed by the user’s browser, including but not limited to browser type, Internet service provider, IP address, a cookie containing a unique ID number, the website or ad you have visited or accessed, and whether (and/or to what extent) you responded to an ad.

We Do Not Collect Personally Identifiable Information or Sensitive Consumer Information

The Barometric Service and related technologies do not collect Personally Identifiable Information (“PII) or Sensitive Consumer Information (“SCI”) about individual Users for any purpose. For purposes of this Privacy Policy, (i) PII means any information that could be used to identify the User, such as the User’s name, Social Security Number, phone number (fixed or mobile), email address, credit card information, or any other data that could be used to personally identify the User; and (ii) SCI means sensitive information about a User such as financial account numbers, insurance plan numbers, or information about medical conditions. For purposes of this Privacy Policy PII and SCI are referred to collectively as PII. To the extent any of our Partners (as defined below) gather PII, we do not aggregate such information in a manner that could be used to identify any User. For example, in some instances we cross-reference non-PII information with a “hashed” version (i.e., a coded version) of a corresponding physical address or email address. We do this to provide more transparency to advertisers regarding the users who engaged with their ads, and although we maintain statistical and aggregate information about such users, we do not create profiles of specific users for any purpose.

How We Use Non-PII Data

We analyze the effectiveness of digital (mobile and desktop) advertisements on behalf of our advertiser and agency clients. We accomplish this by corresponding individual ad engagement data (i.e., ad clicks, video completions, rich media engagement, or any other advertiser KPI) with relevant non-PII characteristics about the User and the publication that the User has visited, such as the time of day, content on the site or app, latitude/longitude of the User, carrier network, type of mobile device/mobile browser, IP address, as well as other data provided through our Partners. In other words, although we may identify a User based on certain demographic or non personally identifiable information about the User (e.g., New York user, with iPhone 5 between the ages of 35 and 50), we do not know – nor do we seek to know — who that user is, or any information that would allow us to identify who the User is.

Currently we obtain certain device IDs (Android Advertising ID, Apple IDFA) in some cases to verify a User election, such as a User-requested app install request. In those cases we obtain the device ID not to track the User, but rather to substantiate for our advertiser clients whether the User installed the app.

Barometric does not currently use or seek to obtain information about a User’s browsing history (i.e, web sites visited) or Web-based purchasing history. In addition, we will not use a User’s current GPS geographic location to target an ad unless we or one of our data or inventory Partners have previously obtained permission to do so. Because we do not have a nexus with a User before the User generates a specific bid request, we rely on inventory partners to adhere to contractual requirements and applicable regulatory and self-regulatory guidelines, including any requirements related to obtaining User consent to access the User’s geographic location.

If we intend to obtain or use this information in the future we will update our Privacy Policy accordingly, as described above, to clearly delineate a User’s rights; provided, however, that any User is free to Opt Out of any such future practice or use of User-specific behavioral, geocoding or interest-based targeted advertising by clicking here: http://trkn.us/opt-out/.

We work with a broad network of publishers, carriers, networks and advertisers (“Partners”). Our Partners may have certain rights to the data we collect on their behalf, and data that they license to us, and each of our Partners maintains its own privacy policy. We may share aggregated data, or non-personal data with third parties.

How We Safeguard the Security of Aggregate User Data

Data collected by the Barometric Service is only retained in an aggregated or anonymized form after 180 days, so that information about an individual User cannot be retrieved. For example, impression level data (“click data”) is not tied back to any specific user. All the data we hold is protected by multiple layers of physical, electronic and administrative safeguards, to secure it against accidental, unauthorized or unlawful access, use, modification, disclosure, loss or destruction.

From time-to-time we may share the aggregated, non-individualized, data we hold with Publishers and Networks for reporting and accounting purposes, as well as other unaffiliated third parties for various purposes such as statistical or educational analysis. In these cases we work with organizations we believe to have appropriate safeguards in place to protect data at the levels we require. In situations where we are obligated by law, we may also disclose information in order to investigate, prevent or take action regarding suspected or actual prohibited activities, included but not limited to, fraud and situations involving potential threats to the physical safety of any person.

How We Meet Our Obligations Under Laws, Regulations and Standards Intended to Safeguard Children

Our clients are corporate organizations and businesses and our services are not directed at or developed for persons under the age of 13.

We also take various steps to ensure compliance with the federal Children’s Online Privacy Protection Act (COPPA) as well as voluntary industry frameworks such as the Children’s Advertising Review Unit (CARU), administered by the Council of Better Business Bureau’s, Inc., including the following:

Otherwise, we do not collect or use information intended to identify the age of a given User. If we do, unexpectedly, obtain information that a given User is under age 13 we will delete such information.

Opting Out & Clearing Advertising IDs

If you do not want Barometric to collect data related to your engagement with our Advertisers’ digital ads, you may take the following steps:

II. Information Collected By The Barometric Corporate Website (Barometric.com)

Our corporate Web site located at barometric.com permits Site visitors to solicit services or ask a question, which includes the Site visitor providing his or her name and email address. If you chose to provide us with PII, we may use this for general marketing purposes and to notify you about information about our products and services. If we do collect PII, we will not share or sell such information to any third party.

III. Contact Us for Further Information

If you have any questions about this Policy or our privacy practices, please email us at legal@adtheorent.com.

This Privacy Policy was last updated in November, 2016.