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?
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:
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:
5. What information do we collect and use?
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:
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?
7. How do we use the information we collect?
For our legitimate business interests to provide and operate our services to our clients, including:
We may also allow our Clients to use Platform Data for the following advertising-related purposes:
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
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.
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.
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?
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.
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:
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:
To exercise any of the above rights, email us at email@example.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
18. Contact Us
If you have questions about privacy on the Column6 Platform, you can contact us at firstname.lastname@example.org