Privacy Policy

Effective: July 20, 2016

Qualia (“Qualia”, “we”, “our”) operates a digital advertising technology (the “Technology”) enabling marketers to target advertising based upon our proprietary composite of multiple intent signals of users and to recognize devices that you may use to connect to the Internet such as computers, mobile devices, tablets, smart TVs, game consoles and any other device that enables data collection and exchange (all referred to as “Screens”) for the purpose of sequential targeting, interest-based advertising, cross-screen attribution, and optimization of digital advertising. We help advertisers, advertising networks, online merchants and websites (our “Clients”) do a better job at engaging with their customers and prospects (their “Users”). This Privacy Policy covers the data collected by Qualia’s Technology as well as the information collected on qualia.id (the “Website”).

Qualia is a member of a number of industry associations that govern the policies around online consumer privacy and digital advertising, including the Digital Advertising Alliance (DAA). We comply with Self-Regulatory Principles for Online Behavioral Advertising (OBA) and Internet Advertising Bureau (IAB).

OUR WEBSITE

When visiting the Website, we may collect certain information that can be used to identify or locate a particular person generally known as personally identifiable information (“PII”). We collect PII that you voluntarily choose to provide to us, such as your email address. We use this information in connection with offering our service to our clients, and other general business purposes. In addition, we automatically collect and store from visitors to the Website some non-personally identifiable information (“non-PII”) that you do not actively provide, such as your internet protocol (IP) address, software and hardware attributes such as browser type, the date and time of your visit, the last website you visited, and your computer or mobile device’s operating system, which are used to enhance the services we provide to you. We use cookies (small text files maintained by your browser) in connection with the Website to help manage our relationship with visitors, to better understand how the Website is being used, to improve the Website and for site analytics purposes. Most browsers are initially set up to accept cookies, but you can change your browser’s settings to refuse all cookies or to indicate when a cookie is being sent. However, some features and services will not function properly if cookies are disabled. For more information about cookies and web beacons, please click here.

OUR TECHNOLOGY

INFORMATION COLLECTED VIA THE TECHNOLOGY

We collect information from your use of our Technology. When you visit any website, mobile site, app or other digital media property where our Technology is enabled (“Client Sites”), we may collect information about your interaction with, and the content on, that Client Site. The information collected includes data about your Screens, such as information about the particular Screen (e.g., hardware make and model), its operating system, advertising identifiers (such as Apple IDFA or AAID), IP address, carrier identifiers and other connectivity information, browser version, precise geolocation information (as defined by DAA), and cookies. Qualia does not collect PII through the Technology.

We also receive information provided to us by a variety of third party data providers and partners, which we may use to supplement the information we collect. This third party provided data includes information similar to the information we collect directly as described above. In addition, it may include partner cookies, which may uniquely identify your browser or Screen to us. This data may be collected by such partners themselves or may be collected by such partners from other sources, but in each case, it is collected subject to the third party’s own privacy policy. We take measures to prevent third-party data providers and partners from providing us with PII. The information that we collect and receive in connection with the Technology is used to help our customers better identify appropriate target audiences for their products and services among web and mobile users. Qualia may collect and match non-PII across Screens, browsers, or applications in order to provide Clients with the ability to deliver more relevant advertising.

COOKIES AND WEB BEACONS

We use cookies, HTML5, web beacons, device identifiers, non-cookie technologies and other similar technologies in connection with our Technology to help us deliver targeted advertising on Client Sites that you visit which use our Technology. We use these technologies to help recognize a unique Screen and other non-PII attributes so that we and our Clients are able to deliver relevant advertising, measure the impact of that advertising and better understand and recognize digital media usage patterns. Your browser and Screen are assigned a unique Qualia ID the first time Qualia serves an ad to it or identifies it on a Client Site, and this Qualia ID is used to help Qualia and its Clients deliver more relevant ads to you.

HOW INFORMATION IS USED IN THE TECHNOLOGY

The information collected via the Technology is put into a “snapshot” and is sent to our servers each time a User visits a Client Site. Our servers use the information to create a unique ID for every Screen that our technology is able to recognize within a reasonable probability. Our Technology uses machine learning to perceive common characteristics between multiple Screens (e.g., common IP address) to infer the likelihood that two Screens belong to the same household. By inferring these types of relationships, we can help our Clients understand how Screens might be related so Clients can deliver advertising and content personalized to their Users based on User interests gathered across multiple Screens. Qualia may use non-PII that it has collected or that it obtains from third parties to create data segments and intent profiles, based upon User interactions with our Clients as well as other User behavior, such as the websites visited and mobile applications used by a User.

INFORMATION SHARING VIA THE TECHNOLOGY

Qualia licenses the data collected as described herein to third parties in connection with our business, including to our Clients, our partners and other third parties (collectively our “Business Partners”). This shared information may include non-PII information about your particular Screen (e.g., hardware make and model), its operating system, advertising identifiers (such as Apple IDFA or AAID), IP address, carrier identifiers and other connectivity information, browser version, precise geolocation information, and cookies. This information may be categorized to create audience segments with common interests, intent or other characteristics, but does not include PII. We may also share aggregated, non-PII with our Business Partners, such as aggregated reports derived in part from the information we have collected. The information we share may also be combined with third party data to provide an even broader service to our Clients and Business Partners.

For more information describing Qualia’s use of interest-based advertising data, visit our Technology privacy policy here.

PRIVACY PROVISIONS FOR THE WEBSITE AND TECHNOLOGY

GENERAL INFORMATION SHARING

We may disclose information collected from the Website and through the Technology we have if we have a good-faith belief that the disclosure is reasonably necessary to comply with the law, legal process or an enforceable government request; to enforce applicable terms of use for our services; to detect, prevent or otherwise address illegal activity, fraud, or security issues; or to protect the property or safety of our users, Qualia, or the public as required or permitted by law. We may also make both PII and non-PII available to subsidiaries and affiliated companies that are under common ownership or control within the Qualia family.

We may transfer information, including PII, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If Qualia is involved in any such transaction, you will be notified via prominent notice on our Website of any change in ownership or uses of your information, as well as any choices you may have regarding your information.

We also provide information to third parties who provide services to Qualia in connection with operating and maintaining the Website and the Technology. These service providers are prohibited from using the information we provide for purposes other than performing services for Qualia. In addition, we may share aggregated information with Business Partners and the general public, such as usage statistics or demographic trends regarding how you and others may interact with the Website and/or Technology.

INFORMATION SECURITY

The security of your information is important to us. Qualia has implemented reasonable security measures to protect the information, both during transmission and once it is received, including without limitation, use of firewalls, application controls, and encryption. No method of electronic storage or transmission over the Internet is 100% secure. So while Qualia strives to use commercially reasonable means to protect your information, we cannot guarantee complete security. Qualia do not store advertising related information for more than a period of one year of inactivity and reporting and measurement information for two years of inactivity. If you have any questions about these security practices, please email us at privacy@qualia.id.

THIRD PARTIES

This Privacy Policy only addresses the use and disclosure of information we collect from you on the Website and through our Technology. If you follow links from our Website to another website, you should be aware that such sites will have their own privacy and data collection practices. In addition, each of our Clients has its own privacy policy and data collection practices. Qualia has no responsibility or liability for the independent policies of the linked sites or of our Clients. For more information regarding any other website’s privacy policies, we encourage you to check that site.

CHILDREN

Qualia’s Website and Technology is designed for people 18 years of age and older. We do not knowingly collect PII from anyone under the age of 13. If we are made aware that we have received PII from someone under the age of 13, we will use reasonable efforts to remove that information from our records.

OPT-OUT CHOICE MECHANISM

Qualia wants you to be in control of your experience while interacting with the Website and our Technology. We help our Clients provide you with digital advertising that’s meaningful and supports the Client Sites you use for free, so everyone wins. For more information about online behavioral advertising, please visit the DAA website.

Qualia Intent Data Collection Web Browser opt-out: If you’d like to opt-out from web-based targeted advertising from Qualia, please click here. Qualia uses partners to deliver targeted advertising. One such partner is Appnexus and if you’d like to opt-out from Appnexus, click here. If you’d like to opt-out from online behavioral advertising from any DAA member company, please click here. When you opt-out, our partners such as Appnexus will drop an opt-out cookie that tells our Technology not to deliver targeted advertising to that particular browser or device. If you delete, block, or otherwise restrict cookies, or if you use a different browser or device, you will need to renew your opt-out choice. Please note that you will still see ads if you opt out. The ads delivered through the Technology will just be less relevant to you. We provide you with meaningful choices regarding opt-outs for data collection, including the opt-out links above. However, we do not recognize or respond to browser-initiated Do Not Track (DNT) signals, and we do not control how our Clients respond to DNT.

Qualia Intent Data Collection Mobile Device opt-out: We also honor the mobile device settings for Android and Apple iOS devices. To exercise this opt-out, please visit the privacy settings of your Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest-based ads” (Android). For devices where we are able to see that such a selection has been made, we will not use information collected from that device to deliver targeted advertising.

Qualia Cross-Device opt-out: If you’d like to opt-out of cross-device tracking from Qualia we will not share the identity of your device with our Clients for the purpose of enabling online behavioral advertising. Note that we do have some Clients who use our Technology on their own Client Sites, including for things like fraud prevention, which are not subject to opt-out choice. To opt-out of tracking click here.

PRIVACY GROUPS AND SELF-REGULATORY MEMBERSHIP

SAFE HARBOR PRIVACY PRINCIPLES
Qualia complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Qualia has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Qualia’s certification, please visit http://www.export.gov/safeharbor/.

DIGITAL ADVERTISING ALLIANCE
Qualia adheres to the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising (www.aboutads.info). The DAA offers a Consumer Choice Page (opt-out) and other privacy tools and resources.

INTERNET ADVERTISING BUREAU
Qualia is a member of the Internet Advertising Bureau (www.iab.net).

NETWORK ADVERTISING INITIATIVE
Qualia is a member in good standing of the Network Advertising Initiative (NAI), and adheres to the NAI Code of Conduct. Click here to learn more about the NAI.

POLICY REVISIONS

We may modify this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will post the modified Privacy Policy to the Website with an updated “Last Updated” date at the top of the Privacy Policy, and other places we deem appropriate. We reserve the right to modify this Privacy Policy at any time. If you have questions or concerns, you may contact us at:

QUALIA
Attn: Privacy Officer
37 West 28th Street, 5th Floor
New York, NY 10001
privacy@qualia.id