Platform Privacy Policy

This Platform Privacy Policy applies to information that DeepIntent, Inc., its affiliates, and subsidiaries (“DeepIntent,” “we,” “us,” or “our”) collects, receives, uses, and shares about individuals (“users” or “you”) from desktop, mobile devices, and/or internet-connected television and similar devices (“Devices”) via our Services (as defined below). If you have questions about this Platform Privacy Policy, please email contact@deepintent.com.

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This Platform Privacy Policy does not govern the collection and use of data on our website (www.deepintent.com) and sites or mobile applications that are managed by our platform members and/or third parties that may supply ad space, data, technology, or provide other services to us (together, “Third Party(ies)”).  Each Third Party will have their own privacy policies and practices. We encourage you to refer to the Website Privacy Policy found here and each Third Party’s respective privacy policies for information about such data collection and use practices. For an overview of our practices, see our Notice at Collection. Residents located in California, please see our “For Our California Residents” section of this Platform Privacy Policy.‍

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Overview of Platform Services

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DeepIntent is an online marketing and advertising technology platform specializing in audience insights and media buying (“Platform”). Through our Platform, companies and entities that represent them (“Clients”) can place advertisements on websites, mobile apps, and other digital media properties (“Partner Properties”) belonging to publishers with whom we are partnered (“Publisher”). Our Platform uses data and technology to help Clients strategize how and when to market their products and/or services and to track campaign performance on Partner Properties (“Services”).

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Information We Collect, Store, and/or Access

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When you visit a Partner Property, we or our service providers may collect the following categories of information about you and your Device. When this information is linked back to you or your Device, it is considered “personal information” as referred to in the U.S., or “personal data” as referred to in the European Economic Area (“EEA”), the personal information we collect may include the following:

• Information about Your Browser. This includes information about your browser type, browser language, browser settings, and any information about your preferences and/or signals that you share via cookies or pixels.
• Information about Your Device. This includes information about your IP address, device type, device operating system, device make and model, and device identifiers such as your IDFA (identifier for advertisers), CTV ID (connected television identifier), MAID (mobile advertising identifier) or AAID (android advertising identifier), including through mobile applications and across multiple devices that you may use (“Device Identifiers”). We also collect information about your Device’s Internet Service Provider (ISP).
• Information about Your Interactions with Partner Properties. This includes information about the Partner Properties you visited or used (including those of Clients and Publishers), the date and time of such visits to Partner Properties, content view data, and location information (including city, state, country, region, and/or zip code, some of which may be based on information collected from your Device).  GPS-level location information and precise geolocation is only shared with us on a limited basis by Publishers who are responsible for obtaining your permission to do so.  
• Information about Your Interactions with Ads and Content. This includes information about the type of ad served to you, where the ad was served or content was viewed, whether you clicked on the ad or content, and whether you interacted or engaged with the ad or content in any other way.
• Demographic Information. This information includes your interests or demographics (including your age or gender). We collect this information from Third Party Data Vendors (as defined below), Clients, and/or Publishers.
• Information You Share with our Data Vendors.  This information may include offline data about you, including any of the information described in this section that our Data Vendors share with us for platform service purposes.  This may include personally identifiable information such as name or email (“PII”) which the Data Vendors collected.  We may sync this information with any other information we collect about you.  In some cases, you may have opted-in or permitted our Data Vendors to collect and share this information with us.
• Information You Share with our Clients and/or Publishers.  Any information outlined in this section that our Clients and/or Publishers share with us for the platform service purposes. This may include PII which the Client and/or Publisher collected.  In some cases, you may have opted-in or permitted our Client and/or Publisher to collect and share this information with us.
• Information about Healthcare Providers. We collect publicly available information about health care providers (HCPs), including National Provider Identifiers, which we obtain from public sources and/or Third Parties. Data Provider may also share information about a health care providers interactions with and interest in information regarding certain medications or conditions.
• Non-identifiable Information.  We also collect information that is not linked to a device or person, such as metadata, counts, or information considered de-identified based on expert determinations.  This may include de-identified healthcare and demographic information.  We do not attempt to re-identify de-identified data, and we rely on the assessments of statistical experts to help us protect such data from being linked with any information that could be tied to you or your device.

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Information Collected by Third Parties

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Third Parties that work with us or support our platform, including our Clients, Publishers, Data Vendors, and each of their third-party service providers, may use their own or their affiliates’ cookies, pixels, web beacons, and/or other internet technology within ads and on the Partner Properties. For example, when you click on an ad served on a Partner Property, both our Client and Partner may drop their own cookies to collect information about you. We do not control the information collection and usage practices of these Third Parties. Therefore, we recommend that you review the terms and privacy policy on such Third Parties’ websites.

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Our Sources of Information

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Cookies and Similarly Technologies.  We use cookies, pixels, scripts, web beacons, and/or other similar technology to help us understand your digital actions when you visit a Partner Property on your Device. For example, when you interact with ads presented on our Partner Properties, cookies on such Partner Properties allow us to collect information, like your IP address or other device identifiers, from your Device.  We may also receive your Device Identifiers from Third Party cookies, including but not limited to Google Ads, which help us to reach you on Partner Properties.  You can opt out of Google’s use of cookies by visiting the Google Ad Settings website here. For more information about the privacy practices of Google, please visit the Google Privacy & Terms website here.

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Third Parties.  We also receive other data (e.g., demographic information) from Data Vendors, Clients, Publishers, and/or their service providers, that separately collect and use your information from visits to various websites, applications, or other sources by which they or their partners interact with you, to create “segments” – groups of users that are inferred to share similar interests. We may use information about your inclusion in specific segments based on Client requests so that they may serve ads effectively to you to improve awareness on a brand, drug, clinical trial, and/or disease. You can see a representative sample of our custom awareness segments here.

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How We Use Your Information

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We use the data we collect for these basic purposes:

• Core Functionality and Improvement. We use the information we collect to run the core functionalities of the Services, including delivering relevant ads to you, and to improve the utility and accessibility of the Services such as by adding new features or capabilities.
• Research and Development. We use the information we collect for compiling statistics and conducting research and development for our internal business purposes
• Campaign Performance Analytics. For example, analyzing and reporting on ad campaigns and performance, such as number of ad views and click rates on ads. We may also measure whether ad campaigns resulted in improved brand or clinical trial engagement.
• Performance of the Services. For example, delivering ads to you on Partner Properties, grouping individuals into segments (groups of people with common interests or demographics), and assessing the effectiveness of ad campaigns.
• Ad Targeting.  For example, showing ads based on the content you are viewing (contextual targeting), targeting ads to general locations such as states, cities, or zip codes (general location targeting), requesting to target users who fit into certain interest-based segments (IBA, or online behavioral targeting), or targeting ads to users that engaged with certain Partner Properties or ads (retargeting).   We typically receive information to target ads through requests sent by our Publishers to fill a Partner Property with an ad.  We use this information to track your engagement with an ad or associate your identifiers with a single identifier associated with your browser or Device. We then use this information through our Platform to help decide whether to serve you an ad, to measure your interaction with an ad, and to help Clients serve more relevant ads to you.
• Location Based Targeting. We may target ads to you based on the location of your device or based on your proximity to certain areas, such as conference centers; however, we do not collect precise geolocation information during this process.
• Security, Safety, and Dispute Resolution. We use data to protect the security and safety of our Platform, to detect and prevent fraud, to protect against misuse or unauthorized use of the Platform, to resolve disputes, to enforce our agreements, to limit our legal liability and protect our rights or to protect the rights, property or safety of other users or the public.
• Communications. If you email us with any questions or concerns, we may use any personally identifiable information that you provide to us in such email to respond to you.
• Legal Obligations. We may provide access to your information, including personally identifiable information, when legally required to do so, to comply with a court order, to cooperate with police investigations or other legal proceedings.
• Mergers and Acquisitions. If we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your information will likely be among the information transferred. You will be notified by a prominent notice on this Platform Privacy Policy of any such change in ownership or control of your data.
• Disclosed and Other Purposes. We may use information for any purposes disclosed to you at the time we collect such information or as otherwise stated in this Platform Privacy Policy.

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Legal Bases for Processing Personal Data

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We do not intentionally engage with consumers in the EEA.  If you are using a Device from the European Economic Area (“EEA”), our legal basis for processing your information will vary depending on the information concerned and the specific context in which we collect or use it.

• Legitimate Interests. We rely on legitimate interests to collect information from you unless your data protection interests or fundamental rights and freedoms override our legitimate interests. For example, it is in our legitimate interests to use your information for research and development, analytics, security, safety and dispute resolution, internal administrative purposes. and to comply with our legal obligations.
• Consent. We will ask consent to use your information for certain purposes, as required by applicable laws.
• Legal Obligations. In some cases, we may require use of your data to fulfill a legal obligation.  

If you have any questions about or need further information regarding the legal basis on which we process specific information, please contact us here privacy@deepintent.com.

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Information Sharing

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In order to provide our services for the purposes listed above, we may share your information with the following categories of recipients:

• Data Vendors. We may share your information with data management platforms, identity resolution providers, and other companies that provide data –related services to us that allow us to maintain and run the Platform and provide the Services (“Data Vendor(s)”).
• Service Providers. We may share your information with our service providers, who provide services on our behalf and at our instructions for the following purposes:
  • Support and Development. To provide technical and development support for purposes of maintenance and improvement of the Platform and Services.
  • Platform Functionality. For functionality and performance support for purposes of providing Clients with access to ad targeting controls.
  • Communications. In external and internal communications to respond to your inquiries and address any technical, security or other issues internally.
  • Technology support. To support our infrastructure and for the purpose of providing us with software, networking, storage, and other related technology required to run our Platform.
• DeepIntent Affiliates. We share your information with our affiliates, subsidiaries, and parent companies to use for the purposes described in this Platform Privacy Policy.
• Mergers and Acquisitions. We may share your information in connection with a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, to a third-party buyer.
• Law Enforcement and Regulatory Authorities. We may share your information with law enforcement, regulatory authorities, courts with competent jurisdictions, emergency services or other necessary third parties when legally required to do so, to comply with a court order, to cooperate with police investigations, or for other legal proceedings.

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Your Choices and Controls

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You have various options to opt-out of receiving targeted advertising that our Clients may conduct via our Platform. Note that different devices require separate opt-outs because each Device type uses different technologies.

• EEA User Consent: If you are physically located in the EEA and visiting a Partner Property using the IAB Europe Transparency and Consent Framework (“Consent Framework”), the Partner Property will provide you with an option to choose which third parties you wish to allow access to your device and information.
• Desktop-Based Opt-Out Mechanism: If you wish to opt-out of interest-based advertising through the Partner Properties (when our Clients show you more relevant ads based on your inferred interests), you may use the DAA WebChoices opt-out tool here.
• Browser-Based Opt-Out Mechanism: DeepIntent is integrated with the Global Privacy Control (“GPC”), a browser based tool that notifies businesses of your privacy preferences automatically when you visit their website. You can control your preferences and opt-out of sale/sharing for targeted advertising at https://globalprivacycontrol.org/.
• Global Privacy Platform (“GPP”): DeepIntent is integrated with the Interactive Advertising Bureau’s (“IAB”) state specific Global Privacy Platform US Privacy String. DeepIntent’s partners, including Publishers, Clients, and Data Vendors, can pass opt-outs to DeepIntent via the GPP.
• Network Advertising Initiative (“NAI”) – DeepIntent is a member of the NAI and is fully integrated with the NAI’s opt out tool, which can be found here. Additionally, the NAI’s Connected TV and Mobile opt-out sections can be found using the links below.
  • NAI Connected TV Choices
  • NAI Mobile Choices
• You may visit www.aboutads.info to learn more about targeted advertising and how to opt-out of this type of advertising by companies participating in various advertising networks. Because DeepIntent adheres to Digital Advertising Alliance’s (“DAA”) Self-Regulatory Principles, you can opt-out of targeted advertising by participating companies (including DeepIntent) at: aboutads.info/choices/.
• You may also opt-out of targeted advertising from DeepIntent and/or other advertising networks that are members of applicable self-regulatory organizations by visiting their opt-out links below:
  • Network Advertising Initiative – networkadvertising.org/choices
  • Digital Advertising Alliance Canada (DAAC) – youradchoices.ca/choices
  • Digital Advertising Alliance EU (EDAA) – youronlinechoices.com
• To learn more about how identifiers are used and to enable a better ad experience and learn about controls you may access, visit the DAA’s website on identifiers at: https://www.aboutidentifiers.org/.
• Mobile App-Based Opt-Out Mechanism: You may opt-out of targeted advertising provided by DeepIntent by downloading and using the “AppChoices” mobile application, which you can download to your mobile device from your mobile phone’s app store or via the Digital Advertising Alliance App Choices page here.
• Mobile Device Location Based Targeting: You may prevent location data from being collected via your mobile device through your mobile device settings. To enable this opt-out, select the “limit ad tracking” option (iOS) or “opt-out of interest based ads” option (Android) in the privacy settings of your device. If you opt-out of sharing your location information via the location settings on your mobile device, you will not receive targeted advertisements to your mobile device based on your location.
• Please note that electing to opt-out will not stop advertising from appearing on your device. The ads you see will simply be less relevant to your interests. For example, ads may be based on the context of the content with which you are engaging at the time an ad appears. When you opt out, we record the opt-out on our servers and on cookies in the browser of your Device, and DeepIntent will no longer serve you targeted ads on that browser on such Device. If you configure your browser to reject certain cookies, the opt-out may not function properly. If you change browsers or Devices, or delete cookies, you may need to opt-out again to stop receiving targeted ads.

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Retention of Information

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We only keep your personal information until we no longer have a necessary purpose to process your information as set forth in this Platform Privacy Policy (such as for legitimate business purposes and as permitted by applicable law). The cookies we set on your browser or Device expire within eighteen (18) months after collection. We retain all other information, such as your IP address and other personal information described above, for up to eighteen (18) months after collection. After 18 months, we de-identify, delete, and/or aggregate all information unless we need that information to comply with our legal obligations, tax or accounting obligations, to resolve disputes, for solely internal purposes related to the maintaining the technical functionality of our Platform, or to enforce agreements. If for some reason we are unable to de-identify, delete, or aggregate your information (i.e. if your personal information is archived or included in backup files), then your information will be securely stored and restricted from further processing.

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Where We Store and Process Your Information

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If you are a user based in the EEA, you should be aware that the information we collect and receive or permit Third Parties (such as Data Vendors) to process may be transferred to, stored and/or processed outside of your country of residence and in any country or territory where one or more of our affiliates, subsidiaries, parent companies, or Data Vendors (“Related Companies”) are located, including in the United States. Such information will also be processed by personnel operating outside the EEA who work for us or for one of our Related Companies.

We rely on multiple legal bases to lawfully transfer personal data around the world. These include your consent and standard contractual clauses created by the European Commission (and the ICO for UK residents) which require certain privacy and security protections. A sample copy of such agreements is available on request.

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Security

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We have implemented industry-standard technical and organizational security measures to protect your information from unauthorized access and improper use. We periodically review our security procedures and tools to consider appropriate new technology and methods to better keep your information secure. Please be aware though, that, despite our reasonable efforts, no security measures are impenetrable, though we take all reasonable precautions to protect against security incidents.

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Your Personal Data Rights in the EEA

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If you are in the EEA, you have certain rights the collection, processing, and use of information classified as “personal data” according to applicable data privacy laws in the EEA. If you would like further information in relation to these rights or would like to exercise them, please contact us using the contact details below at any time. You have the right to request that we:

• Provide access to any personal data we hold about you, which may be provided in format that allow such information to be ported to a third party when required by law;
• Correct any personal data about you which is out of date or incorrect;
• Erase any personal data which we are holding about you in certain circumstances except where we have a right to retain such data to comply with legal obligations by European or Member State law or we have an overriding interest to retain such data;
• Consider valid objections or restrictions of the way we use of your personal data, including for direct-marketing purposes, as applicable; and
• Withdraw your consent in cases where we rely on your consent to process your personal data (please see the section on Your Choices and Controls above). You do not need a valid reason for withdrawal in such cases, and you may withdraw your consent at any time.
• You may also opt-out of target advertising from DeepIntent and other advertising networks that are also members of applicable self-regulatory organizations by visiting their opt-out links in this policy.

We will consider all such requests and provide our response within a commercially reasonable period (and in any event within any time-period required by applicable law).

Keep in mind that certain personal data may be exempt from such requests in certain circumstances. If an exception applies, we will inform you of this when responding to your request. Additionally, we may request that you provide us with information necessary to confirm your identity before responding to any request you make.

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Your Rights as a United States Resident

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If you are a resident of certain states in the U.S., you may have the following rights regarding your personal information:

• Right to Know. You have the right to request that we disclose the categories of personal information we collected about you, the categories of sources from which we collected the personal information, the categories of personal information that we sold or disclosed, our business or commercial purpose for collecting and selling your personal information, the categories of third parties with whom we might share your personal information, and the specific pieces of personal information we collected about you. Residents of certain states also have the right to request a list of the specific third parties with whom we might share your personal information.
• Right to Correct. In certain circumstances, you have the right to request that we correct any inaccurate personal information that we have collected directly from you. To protect your personal information, we are required to verify your identity before we can act on your request.
• Right to Be Forgotten/Delete. You have the right to request that we delete the personal information we have collected about you, subject to certain exemptions. This includes the Right to Be Forgotten, where we delete all personal information we have collected, and the Right to Delete specific pieces of information.
• Right to Appeal. If you believe that a request has been denied in error, you have a right to appeal that decision. You may do so either through DeepIntent’s data subject access request portal (see “Exercising Your Rights” below) or by e-mailing DeepIntent directly.
• Right of Data Portability.  You have the right to request a portable copy of your personal information, to the extent technically feasible, in a readily accessible format.
• Right to Limit Use of Sensitive Personal Information. Some states provide their residents with the right to limit the use of Sensitive Personal Information. This means you can direct us to restrict our use of such information to what is necessary to provide the services your request or as otherwise permitted by law. What is considered Sensitive Personal Information differs on a state by state basis but may include data such as precise geolocation, racial or ethnic origin, health information, or government identifiers.
• Right to opt out of certain uses of your personal information (e.g. targeted advertising, sale, or profiling). We may sell or share your personal information in connection with providing our Services.  For example, we may share your IP address or Device information with a Data Vendor to help us understand more about you so that our Clients can determine whether you are the right audience for their ads. You can opt-out of the sale of your personal information, including the sharing of your personal information for targeted or cross-contextual behavioral advertising. Some browsers allow you to opt out of cookie-based and other online tracking, which may be considered a “sale” or “sharing” of your personal information. Currently, the only browser-based opt-out signals we respond to are ones sent through the Global Privacy Control (GPC). When you opt-out of sale or share via the GPC, we honor that request in the same manner as we honor all do not sell/share requests. We do not respond to do not track or other browser-based signals. We do not knowingly collect, sell or share the personal information of anyone under 18.
• Right to Appeal. You have the right to appeal a decision to not take action on a request
• Non-Discrimination. You have the right not to be discriminated against for exercising the rights above.

We rely on the assessments of statistical experts to confirm that we are processing de-identified datasets. As stated above, we do not attempt to re-identify this data or otherwise use it to specifically identify you.

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Exercising Your Rights

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Depending on where you reside, your state might grant you one or more of the rights listed above. If you are a resident of a state that grants you one or more of the above rights, including, but not limited to California, Connecticut, Colorado, Virginia, Utah, and/or any other state privacy laws that may be in effect, and wish to submit a request to exercise one of your rights, please click here, or submit a request at privacy@deepintent.com. We will need to verify your identity before responding to your requests.

If your state allows the use of authorized agents to act on your behalf to exercise your rights or opt-out of the processing of your personal information, your authorized agent may do so following the same steps as above. If we are unable to verify the validity of the authorization, we may be unable to process your request.

If you wish to opt out of the sale of your personal information you can click here. We will need to verify your identity before responding to your requests.

If you are a consumer in Washington State and believe that we have improperly targeted you with an ad based on your consumer health data, please contact us at privacy@deepintent.com.

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Privacy Notice

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• Categories of Personal Information:
  We collect the categories described above in Information We Collect, Store, and/or Access
• Sources of Personal Information:
  Our sources are described in Our Sources of Information
• Purpose of Collecting Personal Information:
  Our purposes are described in How We Use Your Information
• Categories of Personal Information Sold or Shared:
  Online and/or device identifiers
• Third Parties Sold to:
  Clients, Publishers, and Data Vendors

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If you are a California resident, you may designate an authorized agent to make a request to access or a request to delete on your behalf. We will respond to your authorized agent’s request if they submit proof that they have your signed permission to submit the request or submit evidence you have provided them with power of attorney pursuant to California Probate Code section 4000 to 4465. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf.  Note that you will still need to verify your identity with us before we can process your request.‍

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California “Shine the Light” Rights. In addition, California Civil Code Section 1798 entitles California Users to request information concerning whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. We will not sell or share, as defined by California state law, your personal information with non-affiliated companies for their direct marketing purposes without your consent. California Users who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices and policies may contact us by email at privacy@deepintent.com.

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California defines Sell and Share as the following:

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“Sell” is defined as selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for monetary or other valuable consideration.

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“Share” is defined as sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged.

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Data Protection Officer

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Users who are in the EEA have access to a designated Data Protection Officer (“DPO”) who is responsible for ensuring that your privacy rights are respected and to review and oversee how we collect and use your personal data. The DPO can be reached by contacting privacy@deepintent.com.

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Children’s Privacy

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DeepIntent does not direct ads via the Platform to children under the age of 18 years old or knowingly collect information from children under the age of 18 years old.

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Changes to this Policy

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If we change our privacy practices, we will post those changes to this Platform Privacy Policy or other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances if any, we disclose it.

We reserve the right to change this Platform Privacy Policy at any time, so please review it frequently. If we make material changes to this Platform Privacy Policy, we will notify you here, including via the website or Platform prior to the change becoming effective. You can tell when this Platform Privacy Policy has been last updated by checking the date at the top of this page.

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How to Contact Us

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If you have questions or complaints regarding our privacy policy or practices, you may contact us using the following details:

For EEA Users: privacy@deepintent.com
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For Users Outside of the EEA:
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DeepIntent, Inc.
ATTN: Privacy Compliance
4 Bryant Pk Floor 4,
New York, NY 10018
privacy@deepintent.com

EEA Users also have the right to raise a complaint to our supervisory body for data protection matters or another supervisory authority. You can contact the Information Commissioner’s Office via any means provided here.

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