Digital Remedy Privacy Notice for California Residents

Effective Date: January 1, 2020

Last Reviewed on: July 21, 2021

This Privacy Notice for California Residents supplements the information contained in Digital Remedy’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

We may, through our own websites, through our marketing partners, or through and at the direction of our advertising clients,  collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (”personal information”). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.

In particular, we may have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
NO
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. YES
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

We obtain the categories of personal information listed above from the following categories of sources:

  • Indirectly from you. For example, from observing your actions on our Website
  • Directly from you. For example, if you submit a Contact Form through our Website.
  • Indirectly from our marketing partners. For example, from publishers in our Digital Remedy network, technology partners, marketing agencies, and advertisers.

Some of our services, such as FLIP, utilize partners who observe signals generated from internet activity received from devices connected to the internet, and use various processing logic to establish likely connections and groups together identifiers that are likely associated. The associated identifiers may include those IDs associated with mobile applications on both smartphones and tablets, web browsers across various devices, and connected TVs or applications on connected TV. We collect this information on behalf of and at the direction of our advertiser clients. If we collect your Personal Information from or on behalf of one of our advertising partners, we will not share it with other advertising partners in our network.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
  •  To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We may share your personal information with the following categories of third parties:

  • Service providers. For example, our internal cloud network and our ad serving partners.

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category D. Commercial information.

Category F. Internet or other similar network activity.

Category G. Geolocation data.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request , we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request , we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service to:

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

 

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us through the contact information listed below.

    Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

    Response Timing and Format

    We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

    We will deliver our written response by mail or electronically, at your option.

    Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

    Personal Information Sales Opt-Out and Opt-In Rights 

     If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

    Non-Discrimination

    We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    • Provide you a different level or quality of goods or services.
    • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

    Contact Information

    If you have any questions or comments about this notice, the ways in which Digital Remedy collects and uses your information described here [and in the Privacy Policy], your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

    Online Verification Form: available here 

    Email: [email protected]

    Toll-Free Number: 855-977-1665

    Postal Address:

    10 Times Square, 20th Floor, New York, New York 10018

    Attn: Legal Department

     

    Reach Us

    If you have any questions, think that we could be the right fit for your business, or just want to chat about anything digital (or not digital), shoot us a message. We would love to hear from you.

    Get In Touch

    Mike Seiman

    Mike Seiman, CEO & Chairman, is the founder of Digital Remedy, a digital media solutions company leading the tech enabled marketing space he co-founded while still a college student at Hofstra University in the early 2000s. The company has grown quickly and is now a major player within the crowded digital advertising landscape. The rapid growth of Digital Remedy, formerly CPXi led to its inclusion on Inc. Magazine’s list of fastest growing privately held advertising/marketing companies in 2008, 2009, 2010 and 2014. Mike was selected as a semi-finalist in Ernst & Young’s Entrepreneur of the Year initiative in 2010 and 2013 and as a finalist in 2009 and 2014. In his free time, Mike serves on the Board of Trustees of his alma mater, Hofstra University. He also focuses on numerous philanthropic initiatives including sitting on the boards of the H.E.S. (Hebrew Educational Society non-profit community center) and Children International, where he spearheaded the development of community centers in both Guayaquil, Ecuador in 2010 and Barranquilla, Colombia in 2014.

    David Zapletal

    Before graduating in 2005 with degrees in Retail and Consumer Science (with an emphasis in eCommerce) and a Minor in Public Business Administration at the University of Arizona, David Zapletal had already successfully grown a start up ad network from serving an initial 1 million impressions per day to over 10 million impressions per day. It was his deep understanding of internet advertising during the industry’s beginning stages that led him to another start up at the time, CPXi. More than 8 years that have passed and Zapletal currently serves as Chief Innovation & Media Officer for Digital Remedy. In that role he continues to help grow and implement optimization tactics across various ad serving platforms, oversee daily operations of the account management and trafficking groups and maximizes ROI for Direct Response advertisers as well as for Publishers. Outside of Digital Remedy, Zapletal commits his efforts to an organization called Camp Dream Street, a camping program for children with disabilities, where he serves on the Board of Directors.

    Jeff Reitzen

    Jeff has worked in multiple facets of the online industry, from sales to operations as well as consumer engagement, content analytics and most recently in data optimization. His career began as a wedding, bar mitzvah, and Sweet 16 DJ where he learned the delicate balance of crowd energy management. Quickly, this skill made him incredibly successful in managing online sales for Geico. He joined CPXi at its startup stage as employee number 4 and has been a key driver of continued growth. His unique knowledge of what converts in the digital ad space, the application of data, and how to optimize platforms for efficiency continues to be invaluable to Digital Remedy clients. Today, Jeff is responsible for innovating and optimizing all Digital Remedy offerings including platforms, systems, tools, and internal processes—ensuring the organization remains on the precipice of the marketplace.

    Mike Juhas

    Mike Juhas, has over 13+ years of experience in ad tech client services, working with brands, agencies, and publishers ranging from top 10 advertisers to small regional organizations, to rep firms, holding companies and independent shops. An integral member of the Digital Remedy team, Juhas leads all client relationships, including facilitating onboarding and integration, establishing relationship protocols, overseeing Quarterly Business Reviews and status meetings, navigating financial coordination, and overseeing 24/7 team support. His specialties include consultative services, planning strategy, and account management disciplines. Juhas lives in New Canaan, CT with his wife and two daughters, and their dog, Perry–the unofficial company mascot.

    TJ Sullivan

    TJ Sullivan has over 20 years of media sales and leadership experience. His knowledge of the digital media landscape, ability to develop strategic solutions that solve brand challenges, and talent for motivating sales teams, have made him a vital member of several media and ad tech organizations. Before joining Digital Remedy, Sullivan was VP, Connections at iHeart Media, a cross-divisional group that enabled national advertisers to seamlessly work with multiple iHeart business units; CRO of Reelcontent, a video distribution company for brands; SVP of sales at AdoTube, a video ad network; and was Co-Founder and SVP of video measurement company, OpenSlate—for which he is still an advisor.

    Sullivan had served as the President of 212, New York’s Interactive Advertising Club, and currently advises many early stage start-ups in the programmatic and video space. Notably, RUN (sold to Publicis in 2014), Futures Media, Transmit.Live, and Kubient.

    Outside of his work in the media industry, Sullivan sits on the Board of St. Elizabeth School in Wyckoff, New Jersey and the Advancement Committee of St. Peter’s Prep in Jersey City, New Jersey. He resides in New Jersey with his wife and four children.

    IP Zone: Leverage the relationship between users and the location of their IP addresses in a cookie-free, safe and scalable way.

    Behavioral: Combine first party with network analytics and enormous scale to define custom audience channels that are optimized to sites with high brand engagement.

    Demographic: Reach the right audience based on demographic characteristics such as age, gender and income.

    Mobile Device: Target users by mobile device type (Smartphone, tablet, etc.), carrier and operating system.

    Geo-Location: Target your audience residential cluster, proximity to retail locations, campaign level DMAs and more.

    Contextual: Place a relevant ad in front of a user who is reading content that contains specific terms.

    Buying Power and Quality

    Let’s be honest. Your ad ops are limited by your access to only a handful of channels and DSPs. You want more reach and better prices, but don’t want to sacrifice quality in order to achieve those goals. Digital Remedy has access to a vast multitude of channels based on relationships we’ve cultivated over nearly 20 years in business. That means we get the best prices, have personal relationships, and don’t get sent to voicemail when we call.

    It also means that we can execute omni-channel ad ops for better prices than an internal team, while ensuring the quality is up to industry standards. On top of access to all sorts of specific audiences we’re able to to leverage first- and third-party data across all your campaigns and pivot across platforms based on results. Any campaign, any budget, any platform, any audience. Digital Remedy backed by AdReady is restriction free ad ops….and what could be better than that?

    Resources, Time, and Overhead

    When was the last time you enjoyed balancing budgets, reading resumes, dealing with aggressive sales teams, or wasting years of time for small gains in performance. By partnering with Digital Remedy you get the full support of $30m in OPEX including marketing teams, sales teams, and a dedicated 24/7 ad operations team. No hiring new employees for media optimization, business development, or account management. No months of training and on-boarding. No long meetings crafting sales materials. Just your team focused on making deals, and our teams and tech focused on supporting and executing those deals in a tech-enabled, digital ecosystem designed to get the most out of any KPI.

    Reporting and Support

    How nice would it be to have all of your data and insights in one location. We don’t mean an excel sheet sent out once a week with complicated charts, or an XML file with pages and pages and pages of tables (what is this, 2003?). We mean a fully customizable dashboard reporting in real time, or as real time as possible. You get to decide the how, what, and when of the reporting you’re seeing. And that’s ALL of the how, what, and when’s. If you want to see breakouts of all of the individual campaigns in your system, done. If you want broad scope comparisons of all of the campaigns in the last year, done. If you want to see CTR’s for specific audiences and compare them to CPM for your best performing advertiser but limit the scope to campaigns greater than 30k, done. All of this is at your fingertips with the AdReady Dashboard, all in one place.

    Jessica Cortapasso

    With more than a decade of experience in human capital management, Jessica Cortapasso serves as SVP, People at Digital Remedy. After graduating from Muhlenberg College, she quickly recognized her passion for people and entered the workforce in Human Resources where she gained expertise in employee relations, designing strategic benefit plans, and the development, implementation, and curation of corporate engagement initiatives for big-name brands and small companies alike. Becoming a member of the Digital Remedy family in 2013 while simultaneously acquiring her Masters Degree in Human Resources Management and Development from New York University, Jessica has steered company culture through significant events ranging from acquisitions and a rebranding, to the development and application of our Core Values that shape our daily business practices. Cortapasso resides in Brooklyn, plays competitive volleyball, and loves spending time with her nieces.

    Erez Feld

    Responsible for the financial and legal practices of Digital Remedy, Erez brings 22 years of experience in precision financial analysis, growth management practices, strategic acquisition, and investment leadership. A graduate of Hofstra University, Erez began his career modeling for corporate finance, and expanded his accounting prowess in the real estate sector. Erez joined Digital Remedy in 2008 as a senior accountant, and helped to create and build an accounting department that could support the rapid growth of the company and aligned with those needs. Over the past 12 years he has evolved through various positions at the company within the finance discipline, supervising and mentoring additional finance personnel, while growing under the tutelage of Michael Fleischman, former CFO of Digital Remedy. Today, he leads the Finance Department by supporting high-level projects such as acquisitions and restructuring, and is responsible for overseeing all financial assets, establishing financial procedures, controls, and reporting systems.

    Michael Fleischman

    After a successful career as an accomplished Fortune 500 financial professional leading Corporate Finance and Strategic Planning at Cablevision Systems Corporation and its programming subsidiary Rainbow Media Holdings, Michael currently plays a role in the overall management of Digital Remedy including direct responsibility for all financial-related activities including accounting, financial planning, M&A, legal, insurance, real estate and banking relationships. Michael brings more than 25 years of media experience at Cablevision and Rainbow Media and during his career was instrumental in the launching and managing of a number of cable television networks including 10 Regional Sports Networks across the US, American Movie Classics, Bravo, and the Independent film channel as well as the structuring of corporate partnerships with companies including Liberty Media, NBC, Fox/NewsCorp and MGM. Additionally, he was the finance lead on a number of professional sports team acquisitions including Madison Square Garden, the successful IPO of Cablevision and a tracking stock at Rainbow Media.Michael was involved in the creation and launch of Rainbow Advertising Sales which was one of the Cable Industry’s first Local Advertising Sales Divisions.

    Tony Pascal

    With over two decades of experience in the design, product, and technology space, Tony joined Digital Remedy as a graphic designer in 2007. His responsibilities quickly expanded, landing him in leadership roles across multiple disciplines including creative direction, analytics, monetization optimization, and management of platform development. He continued to grow with the organization over the last fourteen years, overseeing all design, development, and execution of Digital Remedy products and platforms. In his current role as SVP, Product & Technology, Tony leads product and technology development for the company and acts as the go-to liaison across teams, ensuring alignment on all aspects of internal and client-facing technology initiatives.

    Prior to Digital Remedy, Tony built and ran his own direct response company from 2002-2007 after graduating from New York Institute of Technology, where he learned the fundamentals of digital advertising and optimization strategies that still remain relevant today.

    In a previous life, Tony was a ski instructor and still remains an avid skier today. When he is not leading product development, he can be found working on old cars, rock climbing and hitting the slopes.

    Gayle Meyers

    Gayle Meyers is an entrepreneur, venture partner, investor, and operating resource in the digital media and marketing industry, with over two decades of executive leadership experience. After launching a management consulting firm, Growthing which is focused on optimizing growth strategies for executive leaders and their organizations, Meyers has frequently been tapped for high-profile consulting and advisory positions to help marketing technology companies enhance their in-market presence.

    “Gayle is widely recognized as a leading strategist with years of expertise in the ad tech space,” said Mike Seiman, Chairman and CEO of Digital Remedy. “Her career in discovering and integrating game-changing technologies in the marketing industry will serve as an invaluable resource as we continue to enhance our product suite in the months ahead.”

    With expertise spanning multiple disciplines, Meyers frequently serves as a keynote speaker at industry conferences for companies such as Google, Verizon, Omnicom, LiveRamp, LinkedIn, Twitter, and Oracle. A list of her notable past clients who have benefitted from her unique insights to increase shareholder value includes Tinuiti (acquired by New Mountain Capital), Adometry (acquired by Google), MediaForge (acquired by Rakuten), Integral Ad Science (acquired by Vista Equity Partners), and Tapad (acquired by Telenor).

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