Last Updated: June 2020

This privacy statement describes how Column6 collects, uses, shares or otherwise processes Platform Data. It may describe how Column6 enables or allows clients and third-party providers to use Platform Data, but otherwise does not apply to our clients' or other third parties' practices.

You'll find the following information in this document:

1. Who we are?
2. What is the Column6 Platform?
3. What do we mean by Platform Data?
4. Glossary of Basic Terms
5. What Information Do We Collect and Use?
6. How do we collect information?
7. How do we use the information we collect?
8. Cookie use by the Platform
9. Legal basis for processing Personal Data
10. How and why do we share the information we collect?
11. How is Platform Data stored and how long is it kept?
12. What are your choices?
13. What are your personal data access rights?
14. California Do Not Track Disclosures
15. Industry Self-Regulation
16. Changes to the Privacy Statement
17. Contact Us

1. Who we are?

Sileo, LLC, a Delaware limited liability company, doing business as Column6 (“Column6”, “we”, “us” and “ours”), is an advertising technology company. When our technology is used by companies running websites, apps and other internet-connected properties, it helps those companies generate revenue by assisting them in showing advertisements to their users. When our technology is used by marketers and other advertisers, it helps them show advertisements to individuals online who may be interested in their products or services.

If you are interested in learning about how we collect, use, and disclose information through our digital advertising technology Platform, you have come to the right place.

2. What is the Column6 Platform?

Column6 is not an ad network or a data broker. Column6 is a digital advertising technology platform (the "Platform"). We do not own digital properties on which we advertise, other than our corporate website, and we partake in advertising on that site or otherwise, in a limited manner for our own recruiting purposes and to advertise to other businesses (not to consumers). By "Platform," we mean we provide technology that websites, mobile apps and publishers of other internet-connected properties (such as internet-connected TV's), our sellers, use to sell ad space on their websites, mobile apps and other digital media properties (which we collectively refer to as "Digital Properties") and that advertisers or companies on the advertiser's behalf, our buyers, use to purchase that ad space in the most efficient way possible. Sellers want their ads to be relevant to their readers, which helps them to offer content for no cost or lower cost. Buyers want to use their advertising dollars efficiently by reaching the right audiences, and by measuring the effectiveness of their ads. To accomplish these goals, buyers and sellers and their partners use our Platform to engage in a variety of techniques, including interest-based advertising, real-time (or programmatic) advertising, and location-based advertising.

The Platform also provides buyers and sellers other tools, like the ability to measure the effectiveness of their ads, to help prevent malware or other bad activity, and similar functions designed to make the buying and selling of ad space seamless, efficient, and effective.

Buyers, sellers, and other companies may also use our Platform to buy and sell data to help make the ads that end users see more relevant.

3. What do we mean by Platform Data?

The Platform is designed to use certain types of information, that all together we call Platform Data, which includes:

• Information sent to or uploaded to our Platform which may include information about you, such as IP address, unique device identifiers, and the latitude and longitude of your device when you view a website that wants to show you an ad.
• Information sent to or uploaded to our Platform that ties unique device identifier(s) to perceived interests and behavior (e.g., women, ages 40-59), which may include information about you.

See below “What Information Do We Collect and Use?”, for more details on the type of information we include in Platform Data.

"Personal Data" is defined as any data relating to a living individual who can be identified directly from that data, or indirectly in conjunction with other information. Some of this information (including for example IP addresses and certain unique device identifiers), may identify a particular computer or device, and may be considered Personal Data in some jurisdictions. This data allows us to recognize a particular computer or device over time. We do not allow information that by itself identifies an individual in the "real world", such as name, address, phone number, email address, or government identifier, to be collected or used on the Platform.

When an internet user first visits a Digital Property (i.e. a website) that has integrated our technology, this triggers a request to our Platform to fill ad space or measure information about an ad shown to you. When this occurs, we assign a random unique identifier (a Digital Identifier, a "Column6 ID") to your browser or device, which allows the Platform to automatically recognize your browser or device the next time it visits another Digital Property that has integrated our technology.

This allows our clients and certain third-party providers to sync their own Digital Identifiers against this Column6 ID (see ID Synching below) so that our clients and certain third-party providers can use their own data on the Platform that they may have associated with their own Digital Identifiers.

4. Glossary of basic terms

Ad Server: An ad server, in its simplest form, is the computer responsible for delivering an ad to be shown in a web page or a mobile app. Today, communications may be sent to several servers in the process of selecting and delivering an ad. This occurs in a matter of milliseconds (thousandths of a second).

Beacons, Pixels, Tags, and SDKs: Beacons (also sometimes referred to as web beacons or pixels) and tags are elements included in web pages to enable companies to collect data, serve advertising, and provide related services, such as measuring ad effectiveness or preventing fake ad traffic. They do this by allowing communication between a web browser and a server. A beacon is a small transparent image that is placed on a web page. A tag is a small piece of website code that is run by the web browser. An SDK is a piece of computer code that developers include in their mobile applications.

Browser: A browser or web browser is the user interface or application through which you view Digital Properties. Examples of prominent browsers are Microsoft's Internet Explorer, Google's Chrome, Apple's Safari, and Mozilla's Firefox.

Cookie: A cookie is a small text file that is stored in a web browser by a website or Ad Server. By saving information in a cookie, websites and servers can remember preferences or recognize web browsers from one visit to another or from one website to another.

Cross-Device Mapping: Cross-device mapping is the process of making inferences that certain devices are related to each other, i.e. they belong to the same user or household. This is done using either "statistical" or "deterministic" methods (or a combination). "Statistical" refers to using mathematical techniques to make intelligent guesses that certain devices are related. "Deterministic" means using known relationships, for example logins that use the same email address or other personal information, to link multiple devices to a single user. When this method is used companies typically mask the actual email address.

Device Identifiers: Cookies, Mobile Advertising Identifiers or other identifiers that do not identify an individual but identify a specific device.

ID Synching: ID synching (sometimes also referred to as cookie syncing) is a common and long-standing process in the digital advertising industry. It enables advertisers to link up data from multiple advertising platforms. (In other words, it helps advertisers buy ads in more than one place.)

Here's an example of how it works. Let's say you sell a product on your website. A customer visits your site. Your website stores a cookie to identify that customer's browser, and the cookie contains an ID of 12345. You then associate that ID with information about what the customer shopped for on your site.

If you want to then use that information to advertise to that user, you might go to an online advertising marketplace to buy ad space. In order to buy the right ad space to show your ads to the right user, you'll need to match your ID, which is 12345 to the ID that the marketplace has assigned to the same customer (which let's say for this example is ABCDE).

The result is a record that says ID 12345 = Marketplace ID ABCDE. That way, when the marketplace offers to sell you ad space to show your ad to ABCDE, your system will know that ABCDE is the same as 12345, and you can pick the right ad to show the customer.

Interest-Based Advertising: Interest-based advertising uses information collected across multiple web sites or mobile apps to predict users' preferences and to show ads that are most likely to be of interest to them. For example, if a user visits a travel site or uses a travel app, she might see travel-related ads on another site or app and the ads may be about the destinations or kinds of trip the user has looked at. Advertisers may also use other information they have or can acquire about users' interests and demographic information like age group and approximately where a user lives. Users have choices with respect to this type of advertising, as discussed below.

Mobile Advertising Identifiers: Mobile advertising IDs (e.g., Apple's iOs Identifier for Advertising (IDFA) or Google's Android Advertising ID (AAID)) are unique IDs that are similar to cookies, but instead of being stored on your web browser, they are associated with individual mobile devices. Mobile Advertising Identifiers do not reveal a user's real world identity. They usually are user-resettable. Mobile Advertising Identifiers are used in connection with apps on your mobile device as opposed to websites that you access through a browser.

Non-Cookie Technology: Companies sometimes use alternative methods that perform functions similar to cookies in order to identify unique browsers or devices. For example, some platforms, such as Apple's iOS and Google's Play Services for Android, provide unique IDs to be used for advertising. Additionally, mathematical or statistical techniques are sometimes used to try to identify devices. These "Statistical Identifiers" are not 100% accurate.

Precise Geographic Location: Your device may be capable of sharing your precise geographic location with the apps or web pages you visit using that device. Devices use one or more methods to determine your location, including GPS coordinates and information about wifi networks in your vicinity. (Geographic location determined from IP address is typically not considered to be "precise.") Devices such as iPhone or Android phones typically ask for users' consent before installing or using an app that accesses the device's precise geographic location. The app, in turn, may make this information available to third-party advertising companies in order to make the ads you see more relevant.

Real-Time Transactions (Also called Real-Time Bidding, Real-Time Advertising or Programmatic Advertising): Advertising buyers are able to bid in "real time" for the opportunity to show an online advertisement when a web page is loaded or an app is used. The winning bidder gets to show its ad.

Of course, the explanations above are simplified. There are many resources available on the web to learn more about these concepts and online advertising in general. Although we have no responsibility for the content of these sites, we offer the following as good places to learn more:

• OnGuardOnline.gov: onguardonline.gov
• All About Cookies: www.allaboutcookies.org
• Wikipedia: en.wikipedia.org/wiki/Online_advertising
• AboutAds.info, for consumers page: www.aboutads.info/consumers
• The Network Advertising Initiativ: networkadvertising.org/managing/learn_more.asp
• In the EU: www.youronlinechoices.com
• About web browser cookie settings:
  • Explorer: http://windows.microsoft.com/en-US/internet-explorer/delete-manage-cookies#ie=ie-11 
  • Firefox: support.mozilla.com/en-US/kb/Cookies 
  • Chrome: www.google.com/support/chrome 
  • Safari: http://support.apple.com/kb/PH19214?viewlocale=en_US&locale=en_US

5. What information do we collect and use?

Platform Data

When you visit a Digital Property that uses our technology (or that uses technology that transacts with parties using our Platform) we collect or receive certain information about you and your device including:

• Information about your browser, including the type of browser, browser language, browser settings, and cookie information.
• Information about your device, including information about the device's operating system including its version and connection type, device make, device model, Device Identifiers such as your IDFA or AAID,
• Precise Geographic Location data when location services have been enabled for an app on your device that has integrated our technology or that sends that information to our Platform, the IP address from which the device accesses a client's Digital Property.
• Information about your activity on a Digital Property, including web pages or apps visited or used and the time those web pages or apps were visited or used. Note this information is only collected and received by us in connection with requests to us initiated by Digital Properties using our technology to show ads to you or to track your activity in connection with the delivery of an ad or to place Digital Identifiers associated with your browser or device into interest-based segments. This means we do not passively track your activity but only receive information about your activity in connection with requests specifically made to our Platform to serve you an ad, measure your interaction with an ad or to place you into an interest-based category for future use by a client to help make the ads they show to you more relevant.
• Information about ads served, viewed or clicked on, including the type of ad, where the ad was served, whether you clicked on it and whether you visited the advertiser's website or downloaded the advertiser's app.
• Information about you or inferences about your interests that a seller, buyer or third-party provider has collected about you and shared with us such as information about your interests or demographic information (your age or gender) or to help make the ads served to you more relevant. For clarity, we do not independently collect information about your interests or demographic information for use within our Platform, but we do allow our clients and third-party providers to utilize their own data or third-party data they have access to in connection with the Platform.
• Information about your Internet service including information about which Internet Service Provider is used by you.

Data from Third-Party Sources

The Platform allows clients to use information about you such as demographic information (e.g. your age or gender) or information about your interests provided by third-party sources such as third-party data providers and our clients' data management platforms in order to show more relevant ads to you.

Clients, data providers and data management platforms may use ID Synching to enable the use of this information through the Platform.

Information our Clients, our Vendors and our Clients Third-Party Providers Collect

Our clients, our vendors, and our clients' third-party providers, who use our technology, may use their own tags, pixels, cookies, or other similar technology (or those of their other affiliates) within their advertisements and on certain Digital Properties. We are not responsible for our clients, vendors and/or our clients' third-party providers. use of such tracking technologies or for their privacy practices.

6. How do we collect information?

The Platform uses Cookies, Beacons, Pixels, Tags, mobile SDKs, and in some cases Non-Cookie technologies, to collect data associated with particular web browsers or devices. The Platforms also receives data from Clients and Third-Party Sources (as set out above).

7. How do we use the information we collect?

For our legitimate business interests to provide and operate our services to our clients, including:

• Compiling statistics about the advertising transactions occurring through our Platform and conducting research and development for our own internal business purposes, such as analyzing campaign forecasting including conducting machine learning to better help our clients' sale of ad space and our clients' delivery of ads to you.
• Analyzing and reporting on campaign and ad performance (such as reporting to buyers about when and how you have been exposed to ads or clicked on ads and reporting to sellers information about when and how ads were shown on their Digital Properties and whether they were clicked on).
• Investigating, protecting against and deterring malicious activity, fake traffic or fraudulent, unauthorized or illegal activity on the Platform and on the internet.
• Hands on Help: The Platform enables Column6's clients to collect, buy, and sell data and to use Platform Data to buy and sell online advertising. Sometimes our staff give "hands-on" help to clients using the Platform for these purposes, for example by configuring advertising campaigns for clients to best meet their objectives.

We may also allow our Clients to use Platform Data for the following advertising-related purposes:

• Interested Based Advertising: Using Platform Data to infer what you may be interested in and to serve ads to you based on these inferred interests. Our clients may use their Platform Data to create interest profiles about you but Column6 does not create or use interest profiles about you for use by us or across our clients. Any interest profile used on our Platform is created by or for a client to be used by that client or by another client or clients (as permissioned by the client that created the interest profile).
• Frequency Capping: Limiting the number of times you see an ad, so you don't see the same ad or type of ad too many times.
• Showing ads in a particular sequence: Showing you ads in a particular order to provide a better user experience
• Geo-Targeting: Customizing ads shown to you based on your current or prior location
• Contextual Ads: Showing ads to you based on the content you are viewing
• Ad Measurement: Understanding how users respond to ads (e.g., clicking on the ad)
• Aggregated Statistics: Reporting aggregated statistics regarding, for example, the effectiveness of online advertising campaigns
• Cross-Device Mapping: Enabling Cross-Device Mapping in order to serve or measure advertising on related devices on behalf of our clients.

Companies using the Column6 Platform may have some rights over the information that they get from the Platform. While we take care to obtain assurances from our clients and partners that their use of information collected through the use of our technology will comply with applicable laws, their use of that information is governed by their own privacy policies and applicable laws, rules, or regulations.

8. Cookie use by the Platform

Although the specific cookies employed on the Column6 Platform may change from time to time, this describes how and why the Platform may use cookies. These cookies enable our clients to target ads to users, to evaluate how well their ads work, and to see users' opt-out choices. The Platform uses unique cookies to distinguish between unique web browsers, and to store data for advertising purposes, including interest-based advertising.

• The Platform may use unique cookies to store ad delivery and reporting data for clients, such as, for example, which ad was shown, the number of times a particular ad has been shown, and how recently an ad was shown to a particular web browser.
• The Platform may use unique cookies to enable ad buyers to track users' responses (i.e. whether a user clicked on an ad, visited a website or bought something after seeing an ad) to ads purchased on the platform.
• The Platform may use cookies with non-unique values for server load-balancing and similar technical purposes.
• The Platform may use non-unique cookies to store users' opt-out choices.
• The Platform may also use some Non-Cookie Technologies for these purposes (as defined above and as detailed below).
• Cookies play a role in Cross-Device linking in that cookies from different browsers or devices might be associated with each other.
• Some browsers or other software may be configured to block 3rd party cookies by default.

9. Legal basis for processing Personal Data

Our legal basis for processing the personal data will depend on the data concerned and the specific context in which we collect or use it. However, we normally rely on our legitimate interest to collect Personal Data, except where such interests are overridden by an Internet user's data protection interests or fundamental rights and freedoms.

Our legitimate interests are the operation of our Platform and business and the provision of online advertising services to our clients as required by our agreements with them. In some cases, we may rely on the user's consent obtained by the operator of the Digital Properties that use our technology or have a legal obligation to collect user information, or use Platform Data, or may otherwise need the Platform Data. We may also have a legal obligation to collect personal data from you. If we rely on consent to process your data, we will obtain such consent in compliance with applicable laws.

10. How and why do we share the information we collect?

Column6 shares Platform Data with third parties in the following cases:

Clients and third-party vendors: When you visit a Digital Property (i.e. a site) and that Digital Property wants to show you ads, in order to show you those ads, the Digital Property must let certain third parties access your device or receive and use the information noted above. Depending on how those third parties collect and use that information, those parties may be: (1) independently making decisions about how your data is used in different ways, for different reasons based on different legal bases, or (2) using your data strictly at the instruction of another party solely on behalf of that party.

At the instruction of our clients, we share information with clients and third-party vendors: (1) so that they can decide whether to bid on ad inventory or serve an advertisement and choose the best ad for you using their data and our and our partners' technology (and measure and report on those ads after they're delivered); (2) so that certain of them can create demographic and interest profiles to help our clients choose the best ad for you using our and our partners' technology; and (3) so that they can improve their products and services for use by us and others across the broader online advertising ecosystem (e.g. your Device Identifier may be used to improve fraud detection services).

When our clients integrate our technology in order to show you ads and enable us to collect your data, other than for the reasons noted below, we do not decide which third parties may receive your information.

Service Providers: We share with Service Providers (including data centers, hosting providers, anti-fraud, technology and security providers) Platform Data so that they can perform functions and provide services to us including for purposes of protecting the safety and security of the online ecosystem, including to detect and prevent malicious activity or fake traffic. Our Service Providers are subject to obligations consistent with this Privacy Policy and appropriate confidentiality and security measures.

Legal Rights and Compliance with Law: We may also disclose Platform Data in the event that we reasonably suspect malicious activity or fake traffic or when we reasonably believe it is required by law, subpoena or other legal process, including to meet national security or law enforcement requirements.

Column6 Affiliates: We may share Platform Data with other companies affiliated to us, for any of the purposes described in this Privacy Policy.

Business Transfers: We may transfer Platform Data to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.

Aggregated Data: We may also share aggregated data derived from the Platform, including, for example, statistics about Platform activity.

11. How is Platform Data stored and how long is it kept?

Security

Column6 uses generally accepted industry security standards to protect information transmitted over or stored on the Platform. We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.

We restrict access to information to employees, contractors and agents who need the information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

Please note, however, that no transmission or storage of information can ever be guaranteed to be completely secure. Once we receive Platform Data, we will use strict procedures and security features to try to prevent unauthorized access. Please also be mindful that we are not responsible for the security measures of third parties.

Retention

We never store any information longer than we need it. Platform Data is usually aggregated or deleted within 3-60 days but may be retained in the Platform for up to 24 months for specific clients and for use for security and the detection and prevention of fraud and invalid traffic from the date of collection before aggregation or deletion.

When we no longer need the information we collect, it is deleted or aggregated. Aggregated information is used for reporting and analysis and may be stored in the Platform for up to 2 additional years.

When third party vendors receive information through us or clients remove their information from the Platform, their storage and retention of the removed information is governed by their own privacy policies and applicable laws, rules, or regulations.

12. What are your choices?

Opt Out of Interest-Based Advertising: You can opt out of interest-based advertising, click here to opt out. The link will take you to a general opt-out website that will allow you to opt-out from a list of online advertising companies. Important things to note about the opt out:

• Blocked cookies: The opt out cookie may not work if your browser is configured to block third-party cookies.
• Deleting or protecting opt outs: If you delete your cookies, you will need to opt out again. There are browser plugins to help you preserve your opt out cookies.
• Only this browser: The opt out only applies to the browser profile in which you set it. For example, if you set the opt out while using Firefox, but then use Chrome, the opt out will not be active in Chrome. To opt out in Chrome, you will need to repeat the opt out process. This is because the cookies cannot be read between different browsers or browser profiles.
• The opt out does not block or delete cookies: It also does not prevent the use of cookies or other technologies for purposes other than selecting ads based on your interests as inferred by your online behavior. If you wish to block or delete cookies, you can use your web browser settings to do so.
• If you opt out, data may still be collected about your web browsing activities and you will still see advertising. Ads may be selected, for example, based on the content of the web page in which they are shown.

Mobile App Opt Out: 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 Interest-Based Ads" on Android devices and "Limit Ad Tracking" on iOS devices).

Location: Most mobile devices offer you the ability to stop the collection of location information at any time by changing the preferences on your device. You may also be able to stop the collection of location information by particular apps by adjusting the settings for individual apps or following the standard uninstall process to remove specific mobile apps from your device. Note: when location services have not been enabled in any of your apps, we will still infer data about your location based on your IP address.

13. What are your personal data access rights?

We collect the minimum amount of Personal Data about you that is necessary to provide our services. Because we do not collect and we prohibit clients and third party vendors from storing information that directly identifies an individual on the Platform, it is generally not feasible for us to provide individuals information that is tied to their identities.

14. California Do Not Track Disclosures

Some internet browsers have incorporated "Do Not Track" features. Most of these features, when turned on, send a signal or preference (the "DNT Signal") to the web sites you visit indicating that you do not wish to be tracked. Because there is not yet a common understanding of how to interpret DNT Signals, nor a common definition of "tracking", we do not currently respond to DNT Signals. However, our platform does pass these signals on to our clients and other third party partners who may respond to the DNT signal. Our Clients or third party vendors may engage in so-called online behavioral advertising on third-party sites, and Column6 Platform is used to collect Personal Data as described in this Policy. The Personal Data that our Platform collects may uniquely identify a browser but does not identifies you as an individual in the "real world."

15 California Consumer Protection Act (CCPA) and your rights.

California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

• The right to know the categories and specific pieces of personal information we collect, use, disclose, and (to the extent our use of any personal information constitutes a “sale” under the CCPA) sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information.
• The right to request that we delete the personal information we have collected from you or maintain about you.
• The right to opt out of our sale(s) of your personal information.

To exercise any of the above rights, email us at privacy@column6.com and submit your name and your cookie/Android/IDFA identifier. Under the CCPA, you have a right not to receive discriminatory treatment when you exercise the above rights.

16. Industry Self-Regulation

Column6 supports industry self-regulation and endorses best practices and self-regulatory requirements that apply to the Platform. Column6 adheres to the NAI Code of Conduct for Web and Mobile.

Additionally, the following industry sites provide useful information about industry self-regulation of interest-based advertising: www.networkadvertising.org and www.aboutads.info

17. Changes to the Privacy Statement

This Privacy Policy is effective as of the date indicated above and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

18. Contact Us

If you have questions about privacy on the Column6 Platform, you can contact us at privacy@column6.com