1. Introduction & Applicability 

This ad services privacy policy (“Ad Services Privacy Policy”) explains the data practices of SheMedia, LLC and Penske Media Corporation (collectively, “SM“, “we” and “us”) on the SM publisher network websites, mobile-optimized version of such websites, and digital applications that integrate certain SM technology or onto which SM serves advertisements (collectively, “Publisher Network Websites“).This Ad Services Privacy Policy applies solely to SM’s delivery of advertisements on the Publisher Network Websites (“Ad Services”), regardless of how you access or use the Publisher Network Websites, whether via personal computers, mobile devices or other devices (each a “Device”).  “Publisher Network Websites” includes all subdomains of Publisher Network Websites. SM DOES NOT OWN OR OPERATE THE PUBLISHER NETWORK WEBSITES and this Policy does not apply to Publisher Network Website’s own practices or other third parties, including ad servers, on such sites. Publisher Network Websites are subject to additional or different privacy policies, which are posted on the Publisher Network Website, including without limitation policies that may apply to advertisements served on the Publisher Network Websites by parties other than SM (or third parties acting on our behalf). Please visit each Publisher Network Website for additional privacy policies and terms and conditions.

Your use of or interaction with the Ad Services is also subject to the Penske Media Corporation Terms of Use. 

For information about the data protection practices when you visit SM’s own websites or digital application such as SheKnows.com or related to business customers of SM, please visit the Penske Media Corporation Privacy Policy here. 

For the purposes of data protection laws, SM is the data controller.   

If you do not agree to this Ad Services Privacy Policy, you must discontinue using the Publisher Network Websites and all services and features therein.  By using the Publisher Network Websites, you acknowledge you have read and understand this Ad Services Privacy Policy. 

2. Information We Collect 

(a) Information Automatically Collected As You Access and Use the Publisher Network Websites. 

To provide you with advertisements that are more customized to your interests, SM may use a variety of technologies (including cookies, Flash cookies, web beacons and embedded scripts) (“Cookies”) that automatically or passively collect information when you visit or interact with the Publisher Network Websites and the advertisements we serve on the Publisher Network Websites. 

We (and our partners or vendors) may collect this information the first time you interact with a Publisher Network Website that uses our ad services, and we may combine and associate this information with information we (or our partners) may collect about your interactions with other ads we serve. 

The information we collect includes:  

• Device information and identifiers such as your IP address, the type of web browser, computer, platform, related software and settings you are using; device type and model, manufacturer, operating system type and version, time zone, general location inferred from IP address, and identifiers assigned to a device, such as its iOS Identifier for Advertisers (IDFA), Android/Google Advertising ID (AAID or GAID), or other unique device identifier (typically an alphanumeric string allocated to a device by the device manufacturer, identifiers stored in a our cookie, ETag, or browser or web cache). Your IP address is usually associated with the place from which you enter the Internet, like your Internet Service Provider, your company or your library. We use your IP address and other identifiers for a variety of purposes, including to help diagnose problems with our servers, gather broad demographic information, and other purposes as allowed or required by law. 

• Internet network and device activity data about your interactions on the Publisher Network Websites such as information about the activities or actions on those Publisher Network Websites, the content viewed on the Publisher Network Websites, the URL that referred you to the Publisher Network Websites and all of the areas within the Publisher Network Websites that you visit, and the web sites you visit after the Publisher Network Website;  

• SM ad information and information about your interaction with such ad, such as the content of the ad (what the ad is about, e.g. entertainment, news); the ad type (e.g. text, image, or video); where the ad is served (e.g. the website on which the ad appears); whether you clicked on the ad, the number of times you have seen the ad, and information about your interaction with the ad.  

We may combine information gathered from your use of the Publisher Network Websites with information from third party sources to identify your location by state and region.  

For more information, see “Cookies” below.   

Geolocation Information such as city, state and ZIP code associated with your IP address or derived through Wi-Fi triangulation; time zones.  With your consent, SM may collect and use your geolocation to provide you with information about goods and services within your geographic location or implement other functionality such as to serve targeted advertising.  

(b) Information We Collect From Third Parties. 

We may acquire information from other sources such as public and commercial data sources, affiliates, entities providing conferences and other events, marketers, social media networks, and third party advertising partners in accordance with your privacy preferences on such services to update or supplement the information that you provided or we collected automatically, such as information to validate or update your demographic information and lifestyle information.  The information we acquire from third parties includes contact information; device information and identifiers; connection and usage data; professional information (e.g., company and title); demographic and statistical information, including age, date of birth, gender, income and other personal finance information, religion, union or guild membership, sexual orientation, and race or ethnicity; interest information including, health and wellness information, lifestyle information, hobbies, political views, product ownership, purchase history or intentions; user-generated content, general location, and social media information(data that is considered sensitive under applicable law is processed to the extent permitted by and in accordance with applicable law).  We may also acquire information from other sources about your visits over time and across other  web sites, in order to serve more targeted advertising to you on the Publisher Network Website(s). Those third parties have privacy policies that differ from this Ad Services Privacy Policy. web sites, in order to serve more targeted advertising to you on the Publisher Network Website(s). Those third parties have privacy policies that differ from this Ad Services Privacy Policy. 

We use this information to help us maintain the accuracy of the information we collect, to target our communications so that we can inform you of products, services and offers that may be of interest, and for internal business analysis or other business purposes.  

3. How We Use Your Information

We use the information (except business to business information) we collect for a variety of purposes.  For example, we use the information we collect for the following purposes: 

• Serving and Targeting Advertising: We use the information in connection with serving advertising on the Publisher Network Websites, including to provide ads that are targeted to your inferred interests based on your activities across Publisher Network Websites.  This may include creating targeted advertising segments or audiences, as well as to supplement the information we collect with additional information we receive from third parties to allow us to tailor the ads we display.  

• Ad Reporting, Conversions, Analytics, and Frequency Capping: To create and provide information regarding ad activity, including whether ads are clicked on, tracking views of ads, as well as click-through rates, to prevent you from seeing the same ad too many times, and to measure and improve our ad serving services. 

• Fraud Detection and Prevention and Security: To identify invalid ad impressions, clicks, installs, or ad queries, protect us and the Publisher Network Websites from fraud, and protect our services. Service Support and Improvement: To improve our ad services, to improve navigation and display, and to ensure that our services function properly.  

• Marketing: Subject to applicable law, we may combine and use any and all information we collect on you either online or otherwise, including from third parties, for marketing purposes. Unless we expressly notify you otherwise at the time of collection, we also may disclose information that we receive from you and from third party sources to third parties whose practices are not covered by this privacy statement (e.g. other marketers, retailers, and participatory databases) that want to market products or services to you. This includes licensing information about your interests and activities and marketing segments created with such data to third parties for their marketing purposes.  

• Anonymous Information: To create aggregated, anonymized information about you and other users of the Publisher Network Websites by excluding information that reasonably relates to an identifiable individual (“Anonymous Information”). We may use this Anonymous Information for any purpose permitted under the law and disclose Anonymous Information to third parties in our sole discretion. 

• Cross-Device Tracking:  We may use cookies in combination with the information we collect — for instance, IP addresses and unique mobile device identifiers — to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with service providers that do this, in order to save your preferences across devices and analyze usage of the Publisher Network Websites. 

We may also use any of the information we collect for: 

• Security, Fraud, and Legal Compliance purposes, including to  

  • Detect, protect against, and prosecute security incidents, fraud, and illegal activity including to: 

    • Monitor, prevent, and detect fraud, such as through verifying your identity; 

    • Combat spam or other malware or security risks 

    • Monitor, enforce, and improve the security of our Ad Services  

  • Comply with any applicable procedures, laws, and regulations, subpoenas, governmental requests or legal process, or in connection with a legal investigation, if in our good faith opinion such is required or permitted by law 

  • Establish, exercise, or defend our legal rights (e.g., to enforce compliance with our contracts or other policies) 

  • Protect or defend our Ad Services , users, or others 

4. How We Disclose Your Information

In addition to the other disclosures described in this Ad Services Privacy Policy, SM may (and you authorize us to) disclose information collected from and about you on the Publisher Network Websites to other companies or individuals as set forth below.   

• We may provide access to information to vendors that are performing services on our behalf, in order to carry out such services. 

• Affiliates: We may transfer your information to other SM offices and affiliates, including Penske Media Corporation which uses the information as set forth in the PMC Privacy Policy. Administrative and Legal Reasons: Notwithstanding anything herein to the contrary, we may at all times and in any manner access, use, preserve, transfer and disclose your information, including disclosure to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process, or in connection with a legal investigation, if in our good faith opinion such is required or permitted by law; (ii) to ensure compliance with the terms applicable to your use of the Publisher Network Website(s), as applicable, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of SM, its products or services; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use identifiers and other information to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion. Such disclosures may be carried out without notice to you. 

• Third-Party Advertising Partners. As discussed below, we may integrate or use third-party advertising technologies that allow for the delivery of relevant advertising on the the websites you visit and other applications you use. These third parties include advertising networks, data exchanges, ad servers, certain analytics providers and others. Except for the choices provided herein, this Privacy Policy does not govern the use of cookies or other tracking by such third parties. In addition, we sometimes provide certain information (such as email addresses) to entities that may “match” this information in hashed form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit other websites and mobile applications. 

• Sales or Transfer of Business or Assets: In connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock, or otherwise, including via bankruptcy) of all or a portion of the business conducted by SM, in which case the company will possess the information collected by us and will assume the rights and obligations regarding your information as described in this Ad Services Privacy Policy. 

5. Legal Grounds for Using (Processing) Your Information

If you are a visitor from the European Economic Area Switzerland, or the United Kingdom, our legal basis for collecting and using the information described above will depend on the information concerned and the context in which we collect it.   

We collect information from you: 

• where we need it to perform our contract with you; 

• where the processing is in our legitimate interests, provided that these aren't overridden by your interests or rights (such as personalizing our services and marketing for example); or  

• if we otherwise have your consent. 

If you have questions about or need further information concerning the legal basis on which we collect and use your information, please contact us using the contact details provided under the “Contact Us” section below. 

6. Third Party Advertising Partners

In addition to ads that we serve you directly, SM may use third party advertising providers (more fully described below) to serve ads when you visit the Publisher Network Websites and elsewhere on the internet and in other media. We also use analytics services supported by third party companies to perform analytics and track trends. Those third-party companies may use tracking technologies to collect and store usage information about you and may combine this information with information they collect from other sources.  

To provide ads on the Publisher Network Websites, we use a variety of third-party advertising providers, including networks, data exchanges, ad servers, analytics providers and others. The list of third-party providers is found in the Section below entitled “Third Party Cookies” here. This list may be updated from time to time. These third parties may use technology to send, directly to your Device, the advertisements and links that appear on the Publisher Network Websites. They may automatically receive your IP address, web browser, operating system, and time and location information, geodevice type and device ID when this happens. SM, the third-party service providers, as well as the advertisers themselves, may collect and use information about your visits over time and across the Publisher Network Websites and other third party web sites, as well as information received from other sources, in order to serve more targeted advertising to you on the Publisher Network Websites. Third parties may also use information gathered from your usage of the Publisher Network Websites to serve targeted advertisements to you on third party websites and applications. Google is one of the companies that we use to serve advertising and perform analytics on some of the Websites. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to help implement the above uses of your information.  

We also use Google Analytics along with audience data (such as age, gender and interests of users) to help understand users’ visits to the Publisher Network Websites and to optimize the content that we serve to users. 

7. Data Subject Rights & Your Choices

Laws in certain jurisdictions grant consumers the right to exercise certain controls and choices regarding our collection, use, and disclosure of your information.  

If you are a California or Virginia resident, or a resident of the EEA, UK, Canada, or Switzerland, you may request that we: 

provide access to and/or a copy of certain information we have about you; 

• correct information which is out of date or incorrect;

• delete certain information which we have about you; 

• restrict or object to the way that we process and disclose certain of your information; 

• transfer your information to a third party provider of services; and 

• revoke your consent for the processing of your information. 

Residents of California and Virginia also have sale/targeted advertising opt out rights described below. 

California residents may also:  

• Request information about the categories of personal information we collect, disclose or sell or share about you; the categories of sources of such information; the business or commercial purpose for collecting or selling or sharing your personal information; and the categories of third parties to whom we disclose personal information. Such information is also set forth in this Privacy Policy.   

• Limit processing of sensitive personal information as described in the California Privacy Notice below) by clicking on the Your Privacy Choices link in the site footer and following the directions. 

For additional information and rights for California residents, please see the California Privacy Notice below. 

Residents of certain other countries may be able request one or more of the above under applicable law. 

Applicable law may further provide you with the right to not be discriminated against for exercising your rights. 

Certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request. 

Verification. We will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address.   

Authorized Agent. California residents are also permitted to designate an authorized agent to submit certain requests on your behalf.  In order for an authorized agent to be verified, we may require proof of your written authorization before processing the request. We may also follow up with you to verify your identity before processing the authorized agent’s request.  

• Further Information.  

  • California Residents: If you would like further information regarding your legal rights under California law or would like to exercise any of them, please click here or call our toll free number at (877) 365-3500.  

  • Virginia Residents: If you would like further information regarding your legal rights under Virginia law or would like to exercise any of them, please click here.

Notice of Right to Opt Out of Sale of Personal Information or Sharing or Processing Information for Targeted Advertising. California and Virginia residents may opt out of the “sale” of their personal information or processing or sharing of your information for online targeted advertising purposes.  We sell or share certain of your information to third parties to provide you with offers and promotions and opportunities that may be of interest to you.  We also allow third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising to you on the Services or other services.  This activity may also be considered a sale under applicable law. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you offers relevant to you.  

• Depending on what Services you use, we may provide the following categories of personal information to third parties for these purposes: 

  • For online targeted advertising purposes: demographic and statistical information, user-generated content, contact information, device information and identifiers, connection and usage data, geolocation, and social media information. 

  • For sharing with third parties to send you relevant offers and promotions and opportunities:  contact and registration information; demographic and statistical information, employment and education data, user-generated content, and geolocation. 

• If you would like to opt out of SM’s use of your information for such purposes, you may do so as outlined on the following page:  Your Privacy Choices. You can also submit an opt-out request for contact and other non-cookie or similar tracker based information by emailing us at [email protected]. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization. 

• Even if you opt out, you will still see advertising from SM and its third party vendors, it just may be less relevant to you, or it may be personalized for you based only on the data that SM has collected about you.   You must opt out on each device and each browser where you want your choice to apply. Your preference may be lost if you clear, or your browser is set to clear, cookies.  If you have enabled a legally recognized browser-based opt out preference signal (such as Global Privacy Control) on your browser, we recognize such preference in accordance and to the extent required by applicable law. You will need to turn this on for each browser you use. 

• Non-Discrimination. Applicable law may further provide you with the right to not be discriminated against (as provided for in applicable law) for exercising rights.  

8. Your Choices about Ads and Analytics

To learn more about how to manage your preferences regarding our cookie-based advertising in addition to the options outlined above, please see the “Cookie Management” section in our Cookie Notice below.  

Please note that you may still receive (from us or third parties) and SM and  third parties on our behalf may still serve advertisements within the Publisher Network Websites even if you opt out of tailored advertising, but the ads delivered by us will not be based on your activity across unrelated web sites or apps. 

Do Not Track.  SM does not act on “do not track” requests from your browser because, this way, we are able to personalize your experiences on the Publisher Network Websites. For more information, go to http://www.networkadvertising.org or http://www.aboutads.info.  Please note that “Do Not Track” is a distinct privacy mechanism from the legally recognized browser-based opt out signals described above, which we honor in accordance with applicable law. 

9. Retention of Your Information

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws. 

10. Cookies and Other Tracking Technologies

We use and allow certain other companies to use certain tracking technologies, including cookies, web beacons, and other similar technologies (collectively, “Cookies”) on the Publisher Network Websites. This section (“Cookie Notice”) explains what these technologies are and why we use them, as well as your rights to control our use of them.   

What are Cookies? 

Cookies are text files that contain a certain amount of information and are downloaded to your computer or mobile device when you visit a website. They are useful because they allow websites to recognize a user's device. They are then returned to the original website on each subsequent visit or to any other website that recognizes them. For more information on cookies, go to www.allaboutcookies.org.  

The term "Cookie" is used in this Notice in the broad sense to include all similar techniques and technology, including web beacons and log files. For more information on these additional tools, see our glossary below. 

Types of Information We Collect

Cookies help us to understand Publisher Network Website usage and to improve the advertising content and offerings on the Publisher Network Websites. Examples of the types of information that we collect through Cookies include:  

• The number of users visiting Publisher Network Websites, the number of times a Publisher Network Website was viewed, the pages or ads viewed, the clicks made on the Publisher Network Websites or ads and the total duration of navigation on the Publisher Network Websites; 

• The name of the page that referred you to the Publisher Network Websites; 

• Whether this is your first time visiting the Publisher Network Websites; 

• Your viewing preferences (e.g. layout, sizing preferences, language etc.); and 

• Your the type of browser used and your IP address, so that we can identify you during your next visits. 

How We Use Cookies

Examples of ways that we use Cookies include: 

• To control the display of ads; 

• To track usage patterns on the Publisher Network Websites; and 

• To personalize information.  

SM (or third party service providers on our behalf) may also use cookies to collect aggregate information about Publisher Network Website users. We may share aggregate demographic and usage information with our prospective and actual business partners, advertisers and other third parties for any business purpose. 

Types of Cookies We Use on Our Publisher Network Websites

We use Cookies for several reasons. Some Cookies also enable us to track and target the interests of our users and to enhance the experience on our Publisher Network Websites. Third parties, including those acting on your behalf and those that may be not acting on our behalf, also serve Cookies through the Publisher Network Websites for advertising, analytics and other purposes. The specific types of Cookies served by SM through our Publisher Network Websites and the functions they perform are described in more detail below.  As a reminder, we do not operate or own the Publisher Network Websites and such Websites will include other cookies.  You should review the Publisher Network Websites’ privacy policies for more information.  

Functional Cookies: These cookies allow certain aspects of the ads to function.  To refuse these Cookies, please follow the instructions below under the section Cookie Management. Note that by disabling functional cookies, certain ad features may not function properly.  

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Publisher Network Websites, such as the links you click on. The code is temporarily downloaded onto your computer or other device, is active only while you are connected to the Publisher Network Websites, and is deactivated or deleted thereafter. 

Cross-Device and Analytic Cookies: SM may use cookies in combination with the information we collect from third parties or from our affiliates such as PMC— for instance, IP addresses and unique mobile device identifiers — to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with service providers that do this, in order to save your preferences across devices and analyze usage of the Publisher Network Websites. To refuse these Cookies, you may install the Google Analytics Opt-out Browser Add-on by clicking here. 

We and our third party partners (including advertisers) may set and access Cookies on your computer as well. We do not have control over how third parties use such cookies and similar technologies or the information derived therefrom, and this Ad Services Privacy Policy does not cover any use of information that such third parties may have collected from you or the methods used by the third-parties to collect that information. These types of cookies include: 

Advertising Cookies: These Cookies  collect several types of data about your browsing habits, as well as your preferences for products and services. This information allows SM to serve you relevant advertisements on the Publisher Network Websites. To refuse these cookies from us or our vendors, please follow the instructions below under the section Cookie Management. Some advertisements may also contain an icon that you may click on to find out more about how to manage your advertising preferences. 

As of the Effective Date above, the third party partners of SM may include the following. These vendors and this list may be updated from time to time: 

Ad Servers

• DCM 

• Sizmek 

• Celtra 

• Flashtalking 

• Atlas 

• Clipcentric 

• Jet Pack 

• Teads 

• Spotible 

• AdButler 

• LiveIntent  

Tracking Vendors

• Nielsen 

• Integral Ad Science (IAS) 

• Double Verify 

• Moat 

• Innovid 

• Millward Brown Digital 

• Placed 

• Bluekai 

• Sizmek/Peer39 

• Adrizer 

• Adobe Audience Manager DMP 

• Salesforce DMP / Krux  

• Neustar (aggregate knowledge) 

• Conversant 

• Samba TV 

• Keywee 

• Digioh 

• Adjuster 

• Delloite 

• Google Analytics 

• Ceros 

• Optimera 

• Optimizely 

• Procter & Gamble 

Other

JW Player 

• Comscore 

• Google DFP/AdX 

• AppNexus 

• Amazon A9 

• Facebook 

• Rubicon 

• Index Exchange 

• OpenX 

• Yieldbot 

• Outbrain 

• Taboola 

• Zergnet 

• Sonobi 

• Sharethrough 

• Polar 

• Instinctive 

• Criteo 

• Triplelift 

• Pubmatic 

• Sovrn 

• Kargo 

• bRealtime 

• DistrictM 

• JustPremium 

• Parsec 

• Consumable.IO 

• Ideon 

• Collective UK 

• SpotX 

• Apester 

• Stanza 

• Skimlinks 

• Captify 

• Magnetic 

• GumGum 

• Inuvo 

• Kixer 

• Microsoft 

• NewsCred 

• Swoop 

• Vibrant 

• Video Elephant 

• ALC Pixels/Digital 

• Vemba 

• Amazon – RoundForest 

• Amazon Associates (VigLinks) 

• Bringhub 

• Twitter 

• Pinterest 

• Hotjar 

• Chartbeat 

• Disqus 

• Spot.IM 

• Confiant 

• AdLightning 

• Admiral 

• Jivox 

• Nativo 

• Socius 

• Youtube 

• PowerINbox 

• Adslot 

• Rhombus 

• Whizzo 

• Chicory 

• Fluct 

• Pluto 

• Gotchosen 

• Mobkoi 

Web Beacons

Small graphic images or other web programming code called web beacons (also known as “clear GIFs” or “pixel tags“) or similar technologies may be included in our web pages and messages. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Publisher Network Websites, to monitor how users navigate the Publisher Network Websites, or to count how many particular articles or links were actually viewed. A clear gif may enable us to relate your viewing or receipt of a web page or message to other information about you, including your personal information. To refuse Web Beacons, please follow the instructions below under the section Cookie Management. 

HTML

HTML, the language some websites are coded in, may be used to store information on your computer or device about your interaction with and use of the Publisher Network Websites. This information may be retrieved by us to help us manage our Ad Services, such as by giving us information about how the Publisher Network Websites are being used by visitors, how they can be improved, and to customize ad content for their visitors. 

Duration of storage of cookies on your device  

We use both “session cookies” (which expire once you close your web browser) and “persistent cookies” (which expire after a longer period of time unless you delete them).  

Cookie Management 

Analytics 

To learn about Google Analytics’ currently available opt-outs for the Web, please visit https://support.google.com/analytics/answer/181881?hl=en.  

Disabling Advertising Cookies 

To opt-out of SM advertising cookies, please select your privacy preferences utilizing the consent management platform on the applicable Publisher Network Website, or as applicable, depending on your jurisdiction, on the Your Privacy Choices link on the SM footer or other consent management platform offered by SM.    

Some of our advertising service providers may be members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. If you opt-out of receiving targeted ads in this manner, you will continue to receive advertising messages from us and/or our advertising service vendors after you opt-out, but they will not be customized to you based on your use of the Publisher Network Websites. If you would like more information about advertisers’ use of tracking technologies and about your option not to accept these cookies, you can go to http://www.networkadvertising.org. If you would like to learn more about how interest-based information is collected, whether the companies we use are part of an industry network regarding behavioral advertising and to know your choices about not having information used in this manner, you can go to http://www.aboutads.info. The collection of information via certain ads served to users in Canada may be managed by visiting youradchoices.ca.  

Please note that the-opt out is cookie-based and will only affect the specific computer and browser on which the opt-out is applied.  

When necessary pursuant to applicable law, we will use signals from an IAB-compliant consent management platform running on the Publisher Network Websites for enabling or disabling advertising cookies.   

Using Browser Settings 

You can disable and/or delete most types of cookies by using your browser settings. Please note that if you use your browser settings to block all cookies you may not be able to access parts of our ads or the  Publisher Network Websites. The following links provide information on how to modify the cookies settings on some popular browsers: 

Apple Safari http://support.apple.com/kb/PH5042 

Google Chrome https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies 

Microsoft Internet Explorer http://windows.microsoft.com/en-US/windows7/How-to-manage-cookies-in-Internet-Explorer-9 

Mozilla Firefox http://support.mozilla.org/en-US/kb/Cookies 

Do Not Track Signals 

SM does not act on “do not track” requests from your browser because, this way, we are able to personalize your experiences on the Publisher Network Websites. For more information, go to http://www.networkadvertising.org or http://www.aboutads.info. 

If you have questions about the use of Cookies on the Publisher Network Websites, please contact us as described in Contact Us below. 

11. Third Party Sites

We are not responsible for the privacy practices of the Publisher Network Websites or any third parties that you may access from the Publisher Network Website or any other third parties serving ads on the Publisher Network Website other than third parties engaged by SM .  You understand that this Ad Services Privacy Policy does not apply to your use of such Publisher Network Websites or the operations of such third parties on such sites.

12. Security

We implement appropriate administrative, technical and security safeguards to help prevent unauthorized access, use, or disclosure of the information we collect. However, no systems can be completely secure. Therefore, while SM uses reasonable efforts to protect your information, SM cannot guarantee its absolute security, and your use of the Publisher Network Websites indicates your agreement to assume this risk. 

13. IAB Europe Transparency & Consent Framework Compliance

SHE Media participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. SHE Media’s identification number within the framework is 337.

14.  Transfer Information to the United States 

If you are located outside of the USA, please note that the information you provide to us will be transferred to and processed in the United States of America (USA), where laws regarding processing of personal data may be less stringent than the laws in your country.  

15. Changes to This Ad Services Privacy Policy

We reserve the right to change this Ad Services Privacy Policy at any time without prior notice. Any changes will be effective immediately upon the posting of the revised Ad Services Privacy Policy. 

16. No Rights of Third Parties

This Ad Services Privacy Policy does not create rights enforceable by third parties. 

17. Dispute Resolution. PLEASE READ THIS CAREFULLY. IT AFFECTS YOUR RIGHTS

Any and all disputes between you and SM arising under or related in any way to this Ad Services Privacy Policy must be resolved through binding arbitration as described in this section. This agreement to arbitrate is intended to be interpreted broadly. It includes, but is not limited to, all claims and disputes relating to the Ad Services. YOU AGREE THAT BY ENTERING INTO THIS AGREEMENT, YOU AND SM ARE EACH WAIVING THE RIGHT TO TRIAL BY JURY OR TO PARTICIPATE IN A CLASS ACTION. YOU AND SM AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING. ANY ARBITRATION WILL TAKE PLACE ON AN INDIVIDUAL BASIS; CLASS ARBITRATIONS AND CLASS ACTIONS ARE NOT PERMITTED. The arbitration will be conducted by JAMS in accordance with its then-current Streamlined Arbitration Rules and Procedures (“JAMS Rules”) and will be held in New York, New York. The arbitration will be conducted by one neutral arbitrator chosen by the parties. If the parties cannot agree upon an arbitrator, they shall submit to the procedure used by JAMS to choose an arbitrator. The current rules may be found on the Internet at: http://www.jamsadr.com/rules-streamlined-arbitration/. This arbitration agreement is made pursuant to a transaction involving interstate commerce, and shall be governed by the Federal Arbitration Act (“FAA”), 9 U.S.C. §§116. The arbitrator shall apply the law of the State of New York (U.S.A.), without givine effect to any law that would result in the application of the law of any other jurisdiction, consistent with the FAA and applicable statutes of limitations, and shall honor claims of privilege recognized at law. Notwithstanding anything herein or in the JAMS Rules to the contrary, the arbitrator shall not have the power to award punitive damages against you or SM. The arbitrator’s ruling is binding and may be entered as a judgment in any court of competent jurisdiction. In the event this agreement to arbitrate is held unenforceable by a court, then the disputes that would otherwise have been arbitrated shall be exclusively brought in the state or federal courts located in the City and County of New York, New York.  

18. Contact Us 

If you have any questions or concerns about any aspect of this Ad Services Privacy Policy, please contact our Ad Services Data Privacy Officer at the address set forth below. 

Ad Services Data Privacy Support  

SheMedia, LLC 

11175 Santa Monica Boulevard

Los Angeles, CA 90025 

Or 

[email protected]  

19. California Privacy Notice 

This Privacy Notice for California residents supplements the SM Privacy Policy.  This Notice applies to website visitors, app users, and customers in California. This supplemental privacy notice gives California residents additional information about our information collection and use practices required by the California Consumer Privacy Act of 2018 (“CCPA”).  The CCPA also provides California residents with specific privacy rights, which are outlined in our Privacy Policy above.  

This notice provides additional information about the categories of personal information that we collect from California residents generally and  the purposes for which we use the information, and certain rights you may have.  More detailed information is available in our Privacy Policy above.  

Information we collect (except business to business information): 

Categories of information collected:

Device information and identifiers  such as IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers 

• Purposes of use (see “How We Use Your Information” in our Privacy Policy for additional information) 

  • Serving and Targeting Advertising 

  • Auditing Consumer Interactions (e.g., Ad Reporting, Conversions, Analytics, and Frequency Capping) 

  • Cross-Device Tracking 

  • Service Support and Improvement 

  • Our Marketing and Third-Party Marketing and Targeted Advertising Purposes 

  • Bug detection and error reporting 

  • Security, Fraud, and Legal Compliance 

• “Sold” or “Shared” as defined in the CCPA: Yes 

Internet network and device activity data such as information about your interactions on our Publisher Network Websites such as information about the activities or actions on those Publisher Network Websites, the content viewed on the Publisher Network Websites, the URL that referred you to the Publisher Network Websites and all of the areas within the Publisher Network Websites that you visit, and the web sites you visit after the Publisher Network Website. (See “Cookies and Other Tracking Technologies” below for more information about how we collect and use this information.)

• Purposes of use (see “How We Use Your Information” in our Privacy Policy for additional information) 

  • Serving and Targeting Advertising 

  • Auditing Consumer Interactions (e.g., Ad Reporting, Conversions, Analytics, and Frequency Capping) 

  • Cross-Device Tracking 

  • Service Support and Improvement 

  • Our Marketing and Third-Party Marketing and Targeted Advertising Purposes 

  • Bug detection and error reporting 

  • Security, Fraud, and Legal Compliance 

• “Sold” or “Shared” as defined in the CCPA: Yes 

Advertising information such as the content of the ad, the ad type, where the ad is served, whether you clicked on the ad, and the number of times you have seen the ad. 

• Purposes of use (see “How We Use Your Information” in our Privacy Policy for additional information) 

  • Serving and Targeting Advertising 

  • Auditing Consumer Interactions (e.g., Ad Reporting, Conversions, Analytics, and Frequency Capping) 

  • Cross-Device Tracking 

  • Service Support and Improvement 

  • Our Marketing and Third-Party Marketing and Targeted Advertising Purposes 

  • Bug detection and error reporting 

  • Security, Fraud, and Legal Compliance 

• “Sold” or “Shared” as defined in the CCPA: Yes 

 Demographic, interest, and lifestyle information including age, date of birth, gender, income and other personal finance information, religion, union or guild membership, political views, sexual orientation, and race or ethnicity; interest information including, health and wellness information, lifestyle information, hobbies, product ownership, purchase history or intentions; (to the extent certain data is sensitive under applicable law, processing is as permitted by and in accordance with applicable law) 

• Purposes of use (see “How We Use Your Information” in our Privacy Policy for additional information) 

  • Serving and Targeting Advertising 

  • Auditing Consumer Interactions (e.g., Ad Reporting, Conversions, Analytics, and Frequency Capping) 

  • Cross-Device Tracking 

  • Service Support and Improvement 

  • Our Marketing and Third-Party Marketing and Targeted Advertising Purposes  

• “Sold” or “Shared” as defined in the CCPA: Yes 

Geolocation information  such as city, state and ZIP code associated with your IP address or derived through Wi-Fi triangulation;. 

• Purposes of use (see “How We Use Your Information” in our Privacy Policy for additional information) 

  • Serving and Targeting Advertising 

  • Auditing Consumer Interactions (e.g., Ad Reporting, Conversions, Analytics, and Frequency Capping) 

  • Cross-Device Tracking 

  • Service Support and Improvement 

  • Our Marketing and Third-Party Marketing and Targeted Advertising Purposes 

  • Bug detection and error reporting 

  • Security, Fraud, and Legal Compliance 

• “Sold” or “Shared” as defined in the CCPA: Yes  

Inferences such as information about your potential preferences that we infer from your activities on the Services, and inference information we receive from other parties 

• Purposes of use (see “How We Use Your Information” in our Privacy Policy for additional information) 

  • Serving and Targeting Advertising 

  • Auditing Consumer Interactions (e.g., Ad Reporting, Conversions, Analytics, and Frequency Capping) 

  • Cross-Device Tracking 

  • Service Support and Improvement 

  • Our Marketing and Third-Party Marketing and Targeted Advertising Purposes 

• “Sold” or “Shared” as defined in the CCPA: Yes 

Right to Opt Out of Sale of Personal Information or Sharing Personal Information.  

California residents may opt out of the “sale” of their personal information or sharing of your information for online targeted advertising purposes.  We sell or share certain of your information to third parties to provide you with offers and promotions and opportunities that may be of interest to you.  If you would like to opt out of SM’s use of your information for such purposes, you may do so as outlined on the following page:  Your Privacy Choices.L You can also submit an opt-out request for contact and other non-cookie or similar tracker-based information by emailing us at [email protected]. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally required affirmative authorization. 

Even if you opt out, you will still see advertising from us or our third party advertising vendors, the ads from us just may be less relevant to you.   You must opt out on each device and each browser where you want your choice to apply. Your preference may be lost if you clear, or your browser is set to clear, cookies.  If you have enabled a legally recognized browser-based opt out preference signal (such as Global Privacy Control) on your browser, we recognize such preference in accordance and to the extent required by applicable law. You will need to turn this on for each browser you use. 

Right to Limit Sensitive Personal Information.  The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes.  We may use certain sensitive personal information such as race, ethnicity, union or guild membership, health information, political affiliation, and sexual orientation  to enable marketing to you and the delivery of targeted advertising.  You can opt out here [insert Your Privacy Choices link].  

Retention.  We keep your information to fulfill the purposes described above, unless a longer retention is required or permitted by law.  Our retention is based upon the amount, nature and sensitivity of the information, our purposes for which we process the information, applicable legal requirements, and our legitimate interests.  The different purposes for which we process information may result in different retention periods for the same types of information.   

California “Shine the Light” Disclosure.  We do not disclose personal information as identified under California Civil Code sections 1798.83-1798.84, with third parties for those third parties’ direct marketing purposes.