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Motus Media Platform Privacy Statement

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Last updated August 28, 2019

Motus Media is not a data broker or ad network. Motus Media is a digital advertising and marketing agency (Agency) that uses software and technology platforms (Platforms) to help businesses, organizations and advertising agencies (Clients) manage their Internet advertising and marketing campaigns in the most efficient way possible across third-party websites and other digital media properties (including mobile and TV apps) and intermediaries that have integrated with the Platforms we use (Sites) (collectively, the Services). Our Clients and Sites own their own data, and Motus Media has only limited rights to process their data on their behalves for the purpose of providing the Services. We may process your data when you (an Internet user) visit a Site and grant permission (“opt in”) to access your data on that Site for the purposes of delivering quality advertising and marketing experiences to you on behalf of our Clients.

What is this document
We take privacy seriously and want to be transparent about the data processed on the Platforms. This notice describes our Platforms and Services and explains how we may process your data. We also will explain how you can manage your privacy choices and exercise your rights to your data.

To ensure privacy, Motus Media and its Platform providers comply with the EU General Data Protection Regulation (GDPR) e-Privacy Directive and support initiatives for self-regulation, including the Internet Advertising Bureau (IAB) GDPR Transparency & Consent Framework.
If you have any questions or comments regarding this notice, please see the “contact us” section at the end of this notice.

Your choice
You can opt out of receiving the tailored advertisements shown on our Clients’ Sites via the Platforms we utilize in your current browser. https://pixel.motusmedia.co/opt-out
Please note that Cookies and other device IDs are different on different browsers and devices. This ‘opt-out’ only applies to the browser on this Site and this device.

What we do
Motus Media is an advertising and marketing services company. Our Clients include businesses, advertising agencies and organizations that use our Services to run their Internet advertising and marketing campaigns. Motus Media does not provide services directly to any consumers. We use Platforms provided by software and technology providers that allow us to remotely access and buy advertising on the Sites on behalf of our Clients.

Third-party advertising platforms enable Motus Media to a) buy the most relevant advertising inventory corresponding to the parameters of the Client’s advertising campaign as submitted by the Client to us and b) deliver the Client’s advertisements to the Sites (collectively, the Ad Platforms). This is how our Ad Platforms work:

1. The Sites send notices (bid requests) to the Ad Platforms when an advertising space (Inventory) becomes available. Each bid request contains the description of the interests of the audience that is likely to see the advertisement.
2. The Ad Platforms compare the description of the audience under the bid request with the parameters of the Client’s advertising campaign. If they match, the Ad Platforms automatically make a transaction to buy such Inventory and deliver the advertisement to the Site on behalf of our Clients.
3. As a result, the Client will show the advertisements to the users who are likely to have an interest in the Client’s advertisements. The Ad Platforms help to make online advertising more relevant and not generic and consequently help to keep the Internet meaningful and free. Our clients are likely to pay more when their advertisements are tailored to your interests, which may allow the publishers of the Sites to provide their content to you for free.
The Platforms Motus uses also include other tools that measure the effectiveness of the Client’s advertising campaign and prevent fraudulent activities and malware.

Do we collect personal data?
Motus and the Platforms we use do not collect personal data that identifies you (an Internet user) in the ‘real world’. When you visit a Site, we do not know your name or email address or any information that directly identifies you. We take care to ensure that we do not collect any information that tells us who you are.

When the Sites send bid requests (as explained in section What we do above) to the Ad Platforms, these bid requests may include some information about you including your IP address, unique device identifiers and the latitude and longitude of your device when you view a Site or use a mobile app. This information (including IP addresses and certain unique device identifiers) may identify a particular computer or device, and this type of information is considered ‘personal data’ in the European Union. When we receive such personal data from the Sites we act as an independent controller (and never as a joint controller with the Site from which we receive such data).

What data is processed
We may also process certain data for and on behalf of our Clients relating to your interaction with the Sites, such as:
The type of browser used by you and that browser’s settings;
Information about your device’s operating system;
Information about Cookie IDs and other device IDs;
IP addresses from which your device interacts with the Site (IP addresses may be encrypted as required by applicable laws);
Information about your activity on the Sites, including time of activity and URL;
Information about the approximate geographic location (city, region, post code) of your device when it accesses the Sites derived from the IP address information or GPS data.
The Platforms may receive the data from third parties for use in our Clients’ advertising campaigns; in doing so we will always act strictly in accordance with the permissions and restrictions imposed by the third party providing the data. We may also use data received from other sources (not from Motus Media) and other data that identifies the Client that is collected as a result of or generated by Motus Media’s use of the Platforms (Client Data). When Motus Media receives the Client Data, in legal terms Motus Media and its Platforms partners process the Client Data on behalf of our Clients. Furthermore, Motus Media acts as a data processor and is bound by the instructions of the Client when Motus Media processes such Client Data. Motus Media gives such instructions to the Platforms we use, and Motus Media’s instructions are recorded by the respective Platforms. Motus Media does everything in its power to ensure all Client Data used on the Platforms is collected and used according to applicable laws and consumer data practices. While this notice may also explain how Motus Media may use the Client Data when using the Platforms, this notice does not apply to the use of the Client Data outside of the Platforms.
For the purpose of providing the Services, the Platforms collect and process the Client Data used by the Platforms for bidding and delivery (bid requests), the data derived from or generated by the use of the Platforms and the data relating to any error, issue or enhancement to the operation or use of the Platforms. In order to provide the Services, the Platforms may process the following data:
Cookie ID / Pixel ID
The Platforms generate a unique device ID for every new device that interacts with a Site. The unique device ID is included in a Cookie stored in the user’s browser. By default, the Cookie expires 30 days after the last interaction. [The device ID is usually generated as a random number or sometimes combined with an ID generated by the browser and device configuration.]

Mobile Advertising ID
A Mobile Advertising ID is a technical ID on a smartphone operating system (such as Android and Apple iOS) that is under the control of the user and owner of that device, and the user can reset this ID at any time.
Cross-Device IDs
The Platforms generate Cross-Device user IDs by using its algorithms to try to link devices and identifiers belonging to the same user.
Partner IDs
The Platforms may automatically exchange pseudonymous IDs with their business partners. These IDs are strictly pseudonymous on both sides.

How data is processed
The Platforms use the following technologies to process the data about web browsers and devices across the Sites and over time:
Cookies. A Cookie is a small text file that is stored in a web browser by a Site or placed on the Site by Motus Media in order to provide the Services via the Platforms. By saving information in a Cookie, the Sites and Motus Media can remember preferences or recognize web browsers from one visit to another or from one website to another. Motus Media may also use alternative methods with the functions similar to Cookies in order to identify unique browsers or devices. For example, Apple iOS and Google Play Services for Android provide unique IDs for advertising.

Beacons, pixels, tags, mobile SDKs. Beacons (including clear GIFs or 1×1 pixels) and tags are items included in a webpage that enable the Platforms to collect data, serve advertisements, and measure ad effectiveness or prevent fake ad traffic. They do this by allowing communication between a web browser and a server. A beacon is a small transparent graphic that is placed on a webpage. A tag is a small element of the website code that is run by the web browser. An SDK is an element of the computer code included by the developers in their mobile applications.
We may also receive the data from our Platforms or Sites via server-to-server connection, or via secure file transfer.

Use of Cookies
We may use Cookies for different purposes. When we refer to the term ‘Cookie’, we mean various device identifiers not limited to Cookies. Cookies enable the Platforms to serve targeted advertisements to you, to evaluate how efficient the Clients’ advertisements are, and to see your ‘opt-out’ choices. The use of Cookies helps the Platforms to recognize the web browsers and to store data for advertising purposes. The use of Cookies allows the Platforms to store data about the delivery of ads for reporting purposes (for example: which advertisement was shown, the frequency an advertisement was shown, and the last time an advertisement was delivered to a particular browser).

How data is used
We use the data processed by the Platforms for the purposes of providing the Services to our Clients, in particular:
To analyse and report on advertising performance: the data processed is attributed to each of our Client’s particular advertising campaign, so Motus Media and the Client can monitor the performance of the said advertising campaign;

To improve the online advertising experience and efficiency: the Platforms help Motus Media to decide on behalf of our Clients which advertisement to show to you or whether to show it and to display the Client’s particular products in response to users’ interest;

To limit consumers exposure to the advertisements and facilitate more relevant advertising to you: for this purpose, we use Cross-Device IDs;

To satisfy your ‘opt-out’ requests based on your choices stored in Cookies and other IDs;

To detect not ‘real’ traffic, and to prevent fraudulent activities, including the use of robots, malware and other suspicious activities to generate advertising engagements such as viewing and clicking on advertisements delivered by the Platforms.
How data is shared
With Motus Media
Motus Media has access to the data collected, uploaded or used on the Platforms, and may have access to the data generated through their use on the Platforms.
With Third Parties
We may share information with our affiliates and third-party service providers (if any) who process the data for purposes that are described in this Privacy Policy.

The Platforms may also disclose the data as follows:
To a potential buyer (and its agents and advisers) in connection with any proposed acquisition of any part of our business, provided that we inform the buyer it must not use your personal data for the purposes other than disclosed in this Privacy Policy.

To any applicable law enforcement body, regulatory, government agency, court or other third party where in our opinion the disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;

To any other person with your consent to the disclosure.
Legal Basis for Processing
If you are an Internet user from the European Economic Association (EEA), Motus Media and the Platforms collect and process your personal data (if any) only where we have your consent or a legitimate interest to do so depending in each case on what data is processed and the context of the processing activities.
For example, the Platforms may rely on their legitimate interests when they process Cookie IDs for advertising-related purposes (as explained in ‘How data is used’ above). Where the Platforms process the data on behalf of Motus Media when providing the Services, we may process your data on the basis of consent obtained by our Clients, or if our Clients have a legitimate interest to use your data on the Platform.

Data Retention
The Cookies sets by the Platform expire 30 days after the last interaction.

Mobile Advertising IDs may be reset by mobile users, and the Platforms do not have control of any Mobile Advertising ID. We will see the same Mobile Advertising ID until it is not changed by the mobile user.

Advertising ID information (as explained in ‘What data is processed’) may be stored for up to 13 months (for EEA users), and longer for users from other regions.

International Data Transfers
Users’ data may be transferred to and processed in countries outside of the European Union, where data protection laws may be different from the laws of the European Union. If the Platforms transfer your data to third parties outside of the European Union, your data will be processed outside of the European Union. The Platforms and Motus Media are committed to taking appropriate safeguards to ensure an adequate level of data protection in accordance with this Privacy Policy by the recipients outside of the European Union.

Security and integrity of your data
Data Security
The Platforms have implemented reasonable security measures to protect your data collected, used and processed by the Platforms on behalf of Motus Media and our Clients. The Platforms use encryption and pseudonymisation. The Platforms may store data and their related technologies only in Tier 3 or Tier 4 data centers, classified according to official data center classification.
Please note however that no method of electronic storage or Internet transmission is entirely secure. The Platforms take commercially reasonable efforts to protect your data, but Motus Media and the Platforms cannot guarantee its absolute security.
Also the Sites where the Platforms serve their advertisements may have data protection and privacy practices practices that differ from ours. We do not control and cannot be held responsible for the content of the Sites and data collection on the Sites by any third party. You are advised to consult the respective privacy policies of every website you visit.
Data Integrity
The Platforms process your data in a way that is compatible with and relevant to the purposes for which it is processed. To the extent necessary for those purposes, the Platforms are committed to taking reasonable steps to ensure that your data is accurate, complete and reliable for its intended use.

Your privacy rights
You have the following privacy rights:
You can opt out from having a Cookie identifier stored on your device when ads are shown by our Clients from the Platforms. Please refer to the next section

Your privacy choices.
You can request deletion of your personal information at any time by sending an email to privacy@motusmediagroup.com
You can object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information (for EEA Internet users only) at any time by sending an email to privacy@motusmediagroup.com

You can withdraw your consent to use the Platforms that you have given to any Site at any time on such Site according to the procedure set out in the Site’s privacy policy. For the avoidance of doubt, the lawfulness of any processing conducted by the Platforms prior to your withdrawal and any processing conducted in reliance on a lawful processing basis other than consent shall not be affected by your withdrawing of consent. You can register a complaint to a local data protection authority for any allegations that your personal data has been used in a way that is not consistent with this notice or applicable legislation.
Your privacy choices
You can ‘opt-out’ of receiving the tailored advertisements shown by our Clients from the Platforms in your current browser. To ‘opt-out’ or ‘opt-in’ please visit the following page: https://pixel.motusmedia.co/opt-out

The ‘opt-out’ mechanism works as follows. The Cookie previously set in your browser is deleted and replaced with the Platforms ‘Opt-out Cookie’ indicating your ‘opt-out’ only. Please note:
Your ‘opt-out’ will only opt you out of tailored advertising delivered by our Clients through the Platforms in this browser and not other browsers you use.
If you ‘opt out’, you will still see advertisements, but they just may not be relevant to your interests. The Platforms may also continue to process your data information for purposes other than delivering tailored advertisements as explained in this Privacy Policy.

If you delete Cookies in your browser, this may delete the Platforms ‘opt-out’ Cookie and then you may need to update your ‘opt-out’ choice for that browser.
To ‘opt out’ of receiving the tailored advertisements on your mobile devices, you are suggested to consult your device’s settings and instructions provided by the device manufacturer.

Interactive Advertising Bureau Europe
The Platforms and Motus Media adhere to the principles of the IAB Europe EU GDPR Transparency & Consent Framework.

Changes to this notice
We may update this notice from time to time, so you should review this page periodically. Changes to this Privacy Policy are effective when they are posted on this page.

Contact
privacy@motusmediagroup.com