Privacy Policy

Last updated version: September 26, 2022

Simulmedia (“Simulmedia”, “we”, “our”, or “us”) is a TV and video game advertising company that provides optimized content and analytics to its customers projected from a data set based on tens of millions of television viewers (“TV Viewership Panel”). This policy explains how we collect, use, and disclose information through our digital advertising technology platform (the “Platform”) and our corporate website at www.simulmedia.com (“Site”).

Simulmedia does not independently collect any data directly from consumers, nor does it sell any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Instead, Simulmedia licenses data from reputable third-party sources (“Data Vendors”) pursuant to agreements which ensure that all of the data provided to Simulmedia, including data in its TV Viewership Panel, is provided on an anonymous and deidentified basis, and does not contain personally identifiable information such as an individual’s name, date of birth, postal address, email address, telephone number, passport number, or social security number. Each Data Vendor represents and warrants that it has complied with all applicable laws and regulations, as well as its own privacy policies, in the collection and the provision of such data to Simulmedia.

Simulmedia associates unique household identifiers with its TV Viewership Panel. Simulmedia uses external, independent third-party safe havens to match different datasets, such as demographic attributes or purchase information, to its TV Viewership Panel. Because of its strict procedures preventing reidentification, and the use of third-party safe havens, Simulmedia has no way of ascertaining what data relates to any particular household or consumer. Simulmedia also maintains technical safeguards that prohibit and prevent any data from being decompiled, reidentified, reverse engineered or otherwise so as to identify the particular household in its Viewership Panel. Simulmedia’s policies and procedures are also designed to prevent any inadvertent release of deidentified information.

For video game content and ad delivery, Simulmedia acts as a data processor for its game publisher partners. It does not control consumer data and only collects and retains data for limited purposes and time periods as required for data processing in strict accordance with its agreements with publisher licensors and their user licenses.

From time to time, Simulmedia may receive internet protocol addresses from third party clients (“IP Addresses”). These IP Addresses are not associated with any personally identifiable information and do not identify or link to any particular consumer or household. Simulmedia maintains these IP Addresses for a limited period of time in a privacy compliant manner solely for the purpose of measuring the impact of an advertisement on web traffic on behalf of third-party clients. Simulmedia promptly deletes the IP Addresses following the completion of these client analytics.

In order to ensure transparency and give you more control over your personal data, this privacy policy (“Privacy Policy”) governs how we, Simulmedia, and its affiliates, including PlayerWON, use, collect and store personal data we collect or receive from or about you (“you”) such as in the following use cases:

  • When you browse or visit our website, https://www.simulmedia.com/ (“Site”);
  • When you make use of, or interact with, our Site
    • When you subscribe to our newsletter;
    • When you download case studies or other informational materials;
    • When you contact us (e.g. customer support, need help, get in touch, and submit a request);
  • When you are a Publisher or Advertiser and you create an account, log in and make use of the TV+ Platform or PlayerWON Platform portal user interface and/or any other software that we provide for its intended use;
  • the Simulmedia API or SDK is initiated by the Publisher's game on a User device;
  • When you attend marketing events and provide us with Personal Data and/or exchange business cards with us;
  • When we use the Personal Data of our service providers and suppliers;
  • When we use the Personal Data of the Advertisers;
  • When we use the Personal Data of the Publisher and Partner;
  • When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn); and
  • Any in-person interaction with you.

Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal Data” or “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

This privacy notice supplements the other notices and is not intended to override them.

Information Simulmedia Collects

Client Analytics Based on Simulmedia Licensed Data

All TV data analytics provided by Simulmedia to customers (through Simulmedia or through a Simulmedia partner) that are based on data received from our Data Vendors are provided in a deidentified form, and do not contain any personally identifiable information, nor is any household level TV viewing information ever provided to Simulmedia customers. As an added protection, Simulmedia also requires that its clients represent and warrant that they will not associate any personally identifiable information with data analytics provided by Simulmedia.

Information Security

Simulmedia is committed to the security of its datasets and we use appropriate technologies and procedures to protect our data. Our information security practices, including administrative, technical and physical safeguards, are designed to ensure that our Vendor Data is protected. In addition, Simulmedia communicates our privacy and security guidelines to all employees and ensures that they are strictly enforced throughout the company. We continually strive to update our policies and procedures in order to continually improve safeguards for the protection of any data maintained at Simulmedia.

As a Site visitor or supplier, service provider, partner, or customer of our digital advertising Platform

When you (an internet user) interact with our corporate Site at www.simulmedia.com, we collect certain information about your visit.

Information Collection

We may collect various types of information through the Site. For example, when you register with Simulmedia to use our Platform you may provide us with personal information such as your name, email address, phone number, mailing address, user name, and password. You may also provide us with payment information when you submit or receive a payment, or other information when you complete the online forms available on the Site.

We may also collect certain types of technical and usage information automatically, including through the use of Cookies and other similar tracking technologies. These tracking technologies allow Simulmedia to personalize your experience on the Site. This information may include your IP address, device identifier, browser type, device type, the date and time of your visit, and the areas of the Site you visit. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Site or Service. We may also acquire information from other trusted sources to update or supplement the information that you voluntarily provide to us or that we collect automatically.


Information Use

We may use the information we collect or you provide to us through the Site for various purposes, including:

  • To communicate with you, for example through newsletters or with other information about our products and services;
  • To operate and improve the Site and our Services;
  • To customize the Site;
  • For analytics and research;
  • For marketing purposes; and
  • For purposes disclosed at the time of collection.

Information Sharing

We may share information collected through the Site for purposes including:

  • With your consent;
  • For advertising and marketing purposes;
  • In response to a subpoena, court order, or other legal process;
  • To protect our rights and the rights of others;
  • With our affiliates;
  • With service providers that help us operate the Site and Services;
  • As part of a sale, merger, or acquisition, including at bankruptcy; and
  • For purposes disclosed at the time of collection.

Links to Other Websites

The Site may provide links to other websites that we do not control. We encourage you to review the privacy policy of those websites you may visit.

Updating Information

You can update the personal information you provide to us by correcting, updating or deleting the information associated with you via your Simulmedia account. To add, modify, remove, or request access to the personal information about you that we hold please email privacy@simulmedia.com

Cookies and Other Similar Technology

The Site may use cookies, web beacons, or other similar technology to collect information. You may be able to limit the use of cookies through your browser, note that certain parts of the Site may not function properly without cookies. We also partner with Google Analytics to learn more about how you use our Site. For more information about how Google Analytics works you can visit here. To opt-out of Google Analytics, you can visit here and follow the instructions.

Your Choices

From time to time third parties will collect information from the Site and other non-affiliated websites and mobile applications over time in order to deliver relevant advertising to your browser or device, as well as other browsers or devices associated with you. This type of advertising is called interest-based advertising.

You may also limit the collection of information from mobile apps on your device for interest-based advertising by adjusting the settings on your mobile device. For iOS mobile devices, go to “Settings” from your Device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.” For Android mobile devices, go to “Google Settings” on your Device; select “Ads”; and check the box labeled “Opt Out of Interest-Based Ads.”

Please note that if you exercise choice you will still receive advertising, but it may be less relevant to your interests. Additionally, data may still be collected from your browser or device for purposes other than interest-based advertising. If you erase your cookies, reset your device identifier, or use different browsers or devices you may need to make your choices again.

If you no longer wish to receive marketing-related emails from us on a going-forward basis, you may opt out of receiving these emails by clicking “Unsubscribe” at the bottom of any marketing email you receive from us.

Children

Our site is not intended for use by Children under the age of 13. We do not knowingly collect personal information from children under the age of 13 through the Site except as permitted by US law.

We retain other information such as customer contact and payment information in our systems for as long as necessary as permitted by law to comply with our legal obligations, resolve disputes, and enforce our agreements.

Information the Simulmedia Platform Collects

As a consumer of a Digital Property integrated with our digital advertising Platform

When you (an internet user) interact with a Digital Property that has integrated our Platform or that uses technology that integrates with our Platform, we collect certain information about your visit. This policy refers this information as “Platform Data”, and includes the following:

  • Information about your instance of the publisher software running on the Digital Property including: the type of game, game engine, game language, game settings, and player information but not your name, email address, or other information that personally identifies you. This may include data about you related to bid requests and ad impressions, collected when we decide to show you an ad on a Digital Property and when we deliver an ad.
  • Information about your device including device operating system version, connection type, device make, device model, device Identifiers such as your IDFA or AAID, and the IP address from which the device accesses a client’s Digital Property.
  • Location information, including precise location information 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.
  • Information about your activity on a Digital Property such as session history, viewing history, search history and information regarding an individual’s interaction with an internet website, app, or advertisement, including the time web pages or apps were visited or used, including in-game or online viewing activity (e.g., videos viewed, pages viewed).
  • Inferences or audience segmentation derived from Platform Data, such as individual profiles, preferences, characteristics, and behaviors.
  • 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.

The information we collect about you does not reflect your name, email address, or “Other Information” that directly identifies you, and we take care to ensure that we do not collect any information that tells us who you are. However, the information listed above could be combined with Other Information to identify or reveal information about you, so it may qualify as personal information or personal data under applicable law.

As described in further detail below, we may collect the categories of personal information listed above from other sources, such as our affiliates.

Simulmedia’s Platform allows D.igital Properties, advertisers, and others to buy and sell data to help make the ads that you see more relevant. Advertisers may share with us information about your interests or demographic information (your age or gender) that they have collected directly from you and from third parties, and they may use that information on our Platform to help make the ads served to you more relevant or for other purposes.

In accordance with the UK Data Protection Act 2018 and Children’s Online Privacy Protection Act (“COPPA”), we do not knowingly request, solicit, access or receive personally identifiable information from anyone under the age of 13 or, in respect of other jurisdictions under the applicable age limit, if higher. Our partners who use our Platform to provide advertising media for customers and store personal data may, however, collect personal data from individuals under the age of 13 (or other applicable age) and we may then receive this data via our Platform. Such partners are the “operators” of the respective media (as defined by COPPA) or “controllers” as defined by the Data Protection Act 2018 or GDPR. While it is our partners’ responsibility, not ours, to ensure compliance with COPPA or other applicable data protection laws in relation to the collection of such data, in the event we have actual notice that a partner has collected personal information in violation of COPPA, Data Protection Act 2018 or other applicable law, we will require such partner to take measure to comply with the applicable legislation.

The Sources from which Simulmedia Collects Platform Data and Other Information, and the Process for that Collection

Cookies and other online tracking technology. When you visit a Digital Property, we may assign a random unique identifier (a “Simulmedia ID”) to your browser or device, which allows the Platform to automatically recognize your browser or device the next time it visits the same Digital Property that has continued to use our integrated technology. This allows our clients and partners to sync their own unique identifiers against this ID so that they can use their own data on the Platform that they may have associated with you (collectively “Digital Identifiers”).

The Platform uses cookies, beacons, pixels, tags, mobile SDKs, and similar technologies to collect this information.

Other Information

We collect other information, including without limitation personal information, from other companies as further described below (collectively “Other Information”).

Other companies. We collect information from other companies such as analytics providers, advertising and marketing firms, information suppliers, and other promotional and strategic partners.


How We Use the Information We Collect

We use, and allow our clients to use, the information we collect for the following purposes:

  • For our legitimate business interests to provide services to advertisers and owners of Digital Properties, including providing and operating our services which includes:
    • 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 forecasts and conducting machine learning to help our clients improve their sales of ad space and delivery of ads to you;
    • Analyzing and reporting on campaign and ad performance, such as reporting to advertisers about when and how you have been exposed to ads or clicked on ads, and reporting to Digital Properties 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; and
    • Debugging errors in systems.
  • Allowing our clients to use Platform Data for the following advertising-related purposes:
    • Interest-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;
    • Frequency Capping: Limiting the number of times you see an ad and to limit the same ad or type displayed to you;
    • Showing Ads in 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., completing an ad, or scanning a QR code);
    • Aggregated Statistics: Reporting aggregated statistics regarding, for example, the effectiveness of online advertising campaigns; and
  • Cross-Device Mapping: Enabling Cross-Device Mapping (grouping the devices that are owned by an individual or household) in order to serve or measure advertising on related devices on behalf of our clients.

Typically, companies using the Platform own the data that they provide to and get from the Platform. While we take care to obtain assurances from our clients and partners that their use of Platform Data will comply with applicable laws, when clients remove data from the Platform, their use of that data is governed by their own privacy policies and applicable laws, rules, or regulations.

How and Why We Share the Information We Collect

We share Platform Data, in some instances together with Other Information, with third parties as follows:

  • Clients and Third-Party Providers: When you visit a Digital Property and that Digital Property wants to show you ads, and to show you those ads the Digital Property may allow certain third parties to access your device or receive and use the information noted above under “What Information do we collect and use.”
    • When our clients integrate our technology to show you ads and enable us to collect your data, other than for the reasons noted in this section below, such sharing of that data is determined by the Digital Property.
    • We share information with advertisers and third-party providers in accordance with the Digital Property’s instructions 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 or our partners’ technology.
    • This shared information may also be used to create demographic and interest profiles to help our clients choose the best ad for you.
    • These advertisers and third-party providers may use the information we provide to 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).
  • Service Providers (including data centers, hosting providers, anti-fraud, technology and security providers): We share with Service Providers (or enable their collection of) 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. More detail about this sharing is listed in the “Disclosures of Information to Service Providers” section below.
  • 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 security or law enforcement requirements.
  • Business Transfers: We may transfer Platform Data and Other Information that we collect 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.

Your Choices and Rights

If you reside or are located in certain jurisdictions, you may have rights and protections regarding the collection, processing, sharing, and use of your data under a particular jurisdiction’s law. This may mean that you may have the right to:

  • Request access and obtain a copy of your data;
  • To request rectification of your data;
  • In certain circumstances, and subject to some specific legal reasons where we may need to retain data, to request that your data be deleted or erased;
  • To opt out of the sale of your data to third parties;
  • If applicable, to enforce your right to data portability;
  • To object to the processing of your data in certain circumstances; and
  • Not be discriminated against for exercising your rights with respect to your data.

Our Global Operations

Simulmedia is a global company headquartered in the United States with data centers located in the United States, Europe and Asia. If you access any of the Digital Properties that use our technology, please be aware that your information may be transferred to, stored and processed by us and our affiliates in our facilities in the United States and other countries, and by those third parties with whom we may share your information.

These countries (including the United States) may not provide an adequate level of data protection for your information (as determined by the European Commission for personal data in its jurisdiction) or have data protection or other laws as comprehensive as those in your country. Please see “Information for Residents of European Countries” below for information on how we protect information that is transferred out of the European Economic Area, United Kingdom, and Switzerland.

California Consumer Privacy Act (CCPA)


The California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.) applies to the collection, use, and disclosure of “personal information” collected from California residents (as those terms are defined by the CCPA). CCPA Personal Information (CCPA PI) is defined by California law as information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or households. The CCPA requires us to disclose to California consumers the categories of personal information (as defined in the CCPA) we collect, our business and commercial purposes for collecting, using, or selling such personal information, the categories of sources from which we collect personal information, the categories of personal information we have disclosed or sold for a business or commercial purpose in the preceding 12 months, and the categories third parties with whom we share personal information. We have provided these disclosures below.

If you are a California consumer as defined by the CCPA, you may have the right to: (i) request access to your personal information and request additional details about our information practices, (ii) request deletion of your personal information, (iii) opt out of the “sale” of your personal information (as that term is defined by the CCPA), and (iv) to not be discriminated against for exercising any of your rights under the CCPA. Your options regarding the personal information we collect or receive about you are described below.

Please note that if you wish to exercise any of your rights with any of Simulmedia’s clients, you must make your request directly to those Simulmedia clients or Digital Properties, based on information and procedures that they supply. Simulmedia clients own the Platform Data that they maintain in the Platform. Simulmedia does not control how those clients use Platform Data.

Simulmedia’s Data Vendors

Simulmedia receives deidentified household-level data from its TV Viewership Panel Data Vendors, to which it may append other data (such as demographic attributes or purchase data) through third party safe havens. Deidentified household data used by Simulmedia in providing data analytics to clients will only include households from Data Vendors comprising the Simulmedia TV Viewership Panel. Simulmedia cannot determine whether it maintains data on any particular household or individual because of the deidentified manner in which TV Viewership Panel data is licensed to Simulmedia. If you are a California resident, you can visit the following websites to determine if these present and/or historic Simulmedia TV Viewership Panel Data Vendors have information related to you:

Charter Communications Operating, LLC (Spectrum Reach)

Gracenote, Inc. (a Nielsen company)

Vizio Services, LLC

TiVo Corporation

If you elect to opt out of the collection of information by these TV Viewership Panel Data Vendors, Simulmedia will no longer receive deidentified (or any other) data regarding your household from these Data Vendors.

If your household is not included in the TV Viewership Panel Data Vendors listed above, or if it is and you exercise opt out rights through the foregoing links, information regarding your household will not be provided to Simulmedia by its Data Vendors.

Simulmedia also works with companies that capture anonymous or de-identified data and create custom reports based on the aggregate of consumers' online browsing activities. We may also link consumers’ various devices. This allows us to deliver consistent services to our clients, their service providers, and other platforms. Simulmedia cannot determine whether it maintains data on any particular household or individual because of the deidentified manner in which this data and services are licensed to Simulmedia. If you are a California resident, you can visit the following websites to determine if these present and/or historic service providers to Simulmedia have information related to you:

Network

Google Customer Info Page | Opt-Out Page

Oracle Customer Info Page | Opt-Out Page

Experian Customer Info Page | Opt-Out Page

Adobe Customer Info Page | Opt-Out Page

LiveRamp Customer Info Page | Opt-Out Page

NeuStar Customer Info Page | Opt-Out Page

PlaceIQ Customer Info Page | Opt-Out Page

Information We Collected From Consumers

The CCPA identifies a number of categories of CCPA PI. In the year before the date this policy was issued, we collected these categories of CCPA PI:

  • Information about your browser including: the type of browser you use, browser language, browser settings, and cookie information. This may include data about you related to bid requests and ad impressions, collected when we decide to show you an ad on a Digital Property and when we deliver an ad.
  • Information about your device including device operating system version, connection type, device make, device model, device Identifiers such as your IDFA or AAID, and the IP address from which the device accesses a client’s Digital Property.
  • Location information, including precise location information 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.
  • Information about your activity on a Digital Property such as browsing history, viewing history, search history and information regarding an individual’s interaction with an internet website, app, or advertisement, including the time web pages or apps were visited or used, including in-game or online viewing activity (e.g., videos viewed, pages viewed).
  • Inferences or audience segmentation drawn from CCPA PI, such as individual profiles, preferences, characteristics, and behaviors.
  • 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.

We collected the above categories of CCPA PI for the following purposes:

  • Performing services on behalf of the business, such as customer service, processing or fulfilling orders, and processing payments.
  • Auditing customer transactions.
  • Fraud and crime prevention.
  • Debugging errors in systems.
  • Marketing and advertising.
  • Internal research, analytics and development – e.g., user-preference analytics.
  • Developing, maintaining, provisioning or upgrading networks, services or devices.

We collected the above categories of CCPA PI from the following sources:

  • Directly from you – such as contact and billing info and customer service interactions.
  • Generated by your use of our services – such as technical and usage information.
  • Social media sites and other online platforms.
  • Other companies – such as vendors, marketing firms and other Simulmedia divisions.
  • Publicly available sources – such as public records.

Information We Shared About Consumers

In the year before the date this policy was issued, we shared these categories of CCPA PI with entities that provide services for us:

  • Unique and online identifiers – IP address, device IDs, or other similar identifiers.
  • Internet, gaming or other electronic network activity information – such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.
  • Location Information (see above).
  • In Game or Online Viewing Activities (e.g., videos viewed, pages viewed).
  • Inferences drawn from CCPA PI, such as individual profiles, preferences, characteristics, behaviors.

We may have shared each of the above categories of CCPA PI with the following categories of third parties who perform services on our behalf:

  • Product and services delivery companies.
  • Marketing services companies.
  • Cloud storage companies.
  • Billing and payment processing companies.
  • Credit reporting agencies.
  • Fraud prevention entities.
  • Analytics companies.

The CCPA defines “sale” very broadly and includes the sharing of CCPA PI for anything of value. According to this broad definition, in the year before the date this policy was issued, a ‘sale’ of the following categories of CCPA PI may have occurred:

  • Unique and online identifiers – IP address, device IDs associated with television viewing, or other similar identifiers.
  • Internet, gaming or other electronic network activity information – such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.
  • Location Information (see above).
  • Inferences drawn from CCPA PI, such as individual profiles, preferences, characteristics, behaviors.

We may have sold each of the above categories of CCPA PI to the following categories of third parties:

  • Analytics and measurement providers.
  • Companies involved in marketing and advertising.

Your Right To Request Disclosure Of Information We Collect And Share About You

We are committed to ensuring that you know what information we collect. You can ask us for the following information:

  • The categories and specific pieces of your CCPA PI that we’ve collected.
  • The categories of sources from which your CCPA PI was collected.
  • The purposes for collecting or selling your CCPA PI.
  • The categories of third parties with whom we shared your CCPA PI.

We are also committed to ensuring that you know what information we share about you. You can submit a request to us for the following additional information:

  • The categories of CCPA PI we’ve sold about you, the categories of third parties to whom we’ve sold that CCPA PI, and the category or categories of CCPA PI sold to each third party.
  • The categories of CCPA PI that we’ve shared with service providers who provide services for us; the categories of third parties to whom we’ve disclosed that CCPA PI; and the category or categories of CCPA PI disclosed to each third party.

To exercise your right to request the disclosure of your CCPA PI that we collect or share, contact privacy@simulmedia.com

Your Right To Request The Deletion Of CCPA PI

Upon your request, we will delete the CCPA PI we have collected about you, except for situations when that information is necessary for us to: provide you with a good or service that you requested; maintain the functionality or security of our systems; comply with or exercise rights provided by the law; or use the information internally in ways that are compatible with the context in which you provided the information to us, or that are reasonably aligned with your expectations based on your relationship with us.

To exercise your right to request the deletion of your CCPA PI, contact privacy@simulmedia.com

Your Right to Ask Us Not to Sell Your CCPA PI

You can always tell us not to sell your CCPA PI by contacting privacy@simulmedia.com

Once we receive your request, we will not sell your CCPA PI unless you later allow us to do so. We may ask for your permission to resume the sale of your CCPA PI at a later date, but we will wait at least 12 months before doing so.

Authorized Agents

You may designate an authorized agent to submit requests on your behalf. Your agent will need a valid power of attorney or written permission signed by you. If the agent relies on written permission, we’ll need to verify the agent’s identity. We may also contact you directly to confirm the permission. Your authorized agent can submit your requests by emailing us at privacy@simulmedia.com

We Don’t Mind If You Exercise Your Data Rights

We are committed to providing you control over your CCPA PI. If you exercise any of these rights explained in this section of the Privacy Policy, we will not disadvantage you. You will not be denied or charged different prices or rates for goods or services or provided a different level or quality of goods or services.

Consumers Under 16 Years Old

As of the effective date of this policy, we do not have actual knowledge that we sell CCPA PI of consumers under 16 years of age. If we collect CCPA PI that we know is from a child under 16 years old in the future, we will not sell that information unless we receive affirmative permission to do so. If a child is between 13 and 16 years of age, the child may provide that permission.

Any customer who wishes to request further information about our compliance with these requirements, or who has questions or concerns about our privacy practices and policies, please use the Contact Us information provided below.


Information for Residents of European Countries

If you are located in the European Economic Area, the United Kingdom, or Switzerland (the “European Countries”), you have certain rights and protections under applicable law regarding the processing of your “personal data” as defined under applicable law. Some of the Platform Data that Simulmedia maintains in its Platform may constitute “personal data” under these laws.

Role of Simulmedia as a Controller or Processor

If you are located in one of the European Countries, Simulmedia may act as a “controller” as defined under applicable law when processing your personal data. Simulmedia may also act as a “processor” as defined under applicable law to the extent that it processes your personal data on behalf of and at the instruction of another party, for example a Simulmedia client.

Legal Basis for Processing

Simulmedia’s legal basis for processing your personal data depends upon the specific context in which we collect or use it. We normally rely on our legitimate interests to collect and use personal data, except where our interests are overridden by your data-protection interests or your fundamental rights and freedoms. Our legitimate interests are described in greater detail in the “How We Use the Information We Collect” section of this policy. These legitimate interests include the operation of our Platform and business and the provision of our online advertising technology services to our clients as required by our agreements with them. In some cases, we may rely on your consent which is obtained for us by the operator of the Digital Properties that use our technology or use technology that interacts with our Platform. If we rely on consent to process your data, we will obtain such consent in compliance with applicable laws. Additionally, we may have a legal obligation to process personal data.

Your Rights

If you are located in one of the European Countries, you may be entitled to exercise certain data-subject rights available under applicable laws. These rights may include the right to request access to personal data we hold about you. You may also have the right to object to, or request that we restrict, processing of your personal data. You may also have the right to ask that your personal data be corrected, erased, or transferred to another party. If you would like to exercise any of these rights, you may do so as explained in the Your Choices and Rights section above.

Data Transfers

When Simulmedia transfers your personal data to group companies or third-party service providers outside of the European Countries, we ensure that appropriate protections are in place under European data protection legislation (which includes Model Clauses). For example, to ensure that your personal data is adequately protected when transferred outside of the European Countries, Simulmedia has entered into intercompany “model clause” and “standard contractual clause” agreements and other adequacy arrangements with other various entities located outside the European Countries with whom we share your information. A copy of such agreements is available on request. Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your Personal Data. When Simulmedia engages in such transfers of personal information, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR), or ii) Standard Contractual Clauses issued by the European Commission.


Questions or Complaints

If you are in one of the European Countries and have a question or concern about how we process personal data you can contact privacy@simulmedia.com. If we are not able to resolve your issue, you have the right to lodge a complaint with the data privacy authority where you reside.