Rhythmone’s Compliance with the California Consumer Privacy Act
What is the CCPA?
The California Consumer Privacy Act (CCPA) was passed by California legislature on June 28, 2018 and is scheduled to go into effect on January 1, 2020. It creates new consumer rights relating to the access to, deletion of, and sharing of personal information that is collected by businesses.
At Tremor International Ltd. and its group of companies, including RhythmOne, LLC and Tremor Video, Inc. (collectively, “Tremor International Companies”), our view is that privacy and security are of the utmost importance to building a respectful, brand safe and transparent digital advertising marketplace for publishers, brands, agencies and consumers. We believe the CCPA will help our industry continue to foster greater trust in digital advertising, supported by a more transparent and controlled marketplace for the benefit of businesses and consumers. We are prepared to support our clients and partners through their CCPA compliance journey.
Information About Your CCPA Rights
a. The right to access and disclosure
You may have the right to request, twice during a twelve-month period, the following information about the personal information we have collected about you during the past 12 months:
- the categories and specific pieces of personal information we have collected about you;
- the categories of sources from which we collected the personal information;
- the business or commercial purpose for which we collected or sold the personal information;
- the categories of third parties with whom we shared the personal information; and
- the categories of personal information that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.
b. The right to deletion
You may have the right to request that we delete the personal information we have collected from you. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide our Services to you, and may retain certain information for important business purposes, such as fulfilling our legal obligations, or for security, auditing or de-bugging purposes.
c. How to exercise your access and deletion rights
California residents may exercise their California access or deletion rights by accessing our Do Not Sell link or, by sending an email to firstname.lastname@example.org.
For security purposes, we will verify your identity – in part by requesting or automatically capturing certain information from you — when you request to exercise your California privacy rights. For instance, you may need to provide your email address. To request that we provide you with the specific pieces of personal information we have from you or to delete personal information we have collected from you, we may also need to ask you for additional information to verify your identity. Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate:
- Where you have requested the categories of personal information that we have collected about you, we will provide the information you have requested, except where not permitted under applicable law or otherwise exempted by the CCPA.
- Where you have requested specific pieces of personal information, we will provide the information you have requested, except where not permitted under applicable law or otherwise exempted by the CCPA.
- Where you have requested that we delete personal information that we have collected from you, we will delete any information about you that is not necessary for the purposes indicated above or another permissible business, security or legal purpose. Certain information may be exempt from such requests under applicable law.
If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.
d. The right to nondiscrimination
We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.
e. The right to opt-out of the sale of your personal information
You have the right to opt out of the sale of your personal information. California law broadly defines sale such that it may include, for example, allowing third parties to receive and use certain information, such as cookies IP address and/or browsing behavior, to deliver targeted advertising.
If you wish to “opt out” of our “sale” of your information, i.e., for purposes of personalized advertising, we recommend employing the options we provide and explain in Section C. (as we believe those methods are the easiest and most efficient). However, you may also visit the interactive form that we make available at our opt-out location.
f. Authorized Agents
You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.
Support for IAB’s CCPA Consent Solution
We anticipate timely support of the IAB CCPA Compliance Framework. Read more about the framework and how it is helping all parties in the digital advertising ecosystem ensure that they comply with CCPA when processing personal data or accessing non-personal or personal data on user devices.