May 24, 2018

This Privacy Policy describes how Collective, Inc. dba “Visto” (“we,” “us,” “our”) gathers information from advertisements we serve on websites and mobile apps where our Services are used (“Websites”) and how we use and share this information for our business purposes, including our offering of the Visto™ Advertising Hub Platform (“Services”) For information about the data practices related to our corporate site, www.vistohub.com, see the Visto Website Privacy Policy.

Services Data Collection and Processing

Our third party clients (“Clients”) use our Services to manage and optimize their digital advertising campaigns. To provide the Services, with your consent where local law requires, we, or our Visto Clients using the Services, collect and process data about your visits to and activity on websites or mobile apps. This data is known as “Activity Information” and includes IP address, general location information, web viewing data (i.e., web pages which have been viewed by you), date and time, device type, mobile device identifier, mobile application use information, domain type, and your responses to an advertisement delivered by us or a third party advertising technology vendor. We will not use this information to attempt to discern your identity. Activity Information is collected across different websites, browsers or mobile devices.

We use different types of technologies, such as cookies, pixels, and other technologies to process Activity Information. These technologies help us to operate and improve our Services, provide tailored advertising (known as interest-based advertising), and to measure the performance of advertising delivered through our Services. Some of Visto”s Clients may ask their users to register and provide Personal Information. None of this Personal Information is combined by Visto with any other data.

Non-Sensitive Health Data

Where permitted by applicable laws governing online privacy, Visto uses non-sensitive health-related data segments to serve or optimize advertisements. In order to provide transparency around these data segments, please click here to view our list.

How We Use and Share Information

Visto uses Activity Information, subject to your consent where local law requires, collected from websites and mobile apps for interest-based advertising through automated-decision making processes to determine consumer interests; measurement, reporting and optimization purposes; and for the purpose of associating various browsers and devices together. Visto also requires all Visto partners engaged in Personal Data processing to obtain consent prior to any collection and use for digital advertising. These Services help us better target advertisements and other content to individuals in an effort to create a more relevant experience for each person. Activity Information is also used for our legitimate interest in operation and system management purposes, including compliance, public purpose and consumer safety, authentication, verification, fraud prevention and security, billing or product or service fulfillment, and market research or product development and as otherwise permitted under the Network Advertising Initiative and Digital Advertising Alliance Principles (see below), and when not outweighed by an individual’s interests. Activity Information is also combined with data from other sources, such as data provided by our advertising and publisher Clients or ad serving partners, and shared with our affiliates and partners for similar uses, including interest-based advertising and delivering ads for our Clients on our behalf. These Clients and partners are based in the United States. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, bankruptcy proceeding, or similar event, we reserve the right to include any information we have among the assets transferred to the acquiring company.

Cookies

A cookie is a small text file placed on your browser. We use cookies, for example, to provide information to advertisers on users’ web browsing activity. This enables us and our advertiser Clients to provide users with a more meaningful web experience.

Data Retention

Visto generally stores Activity Information, such as IP addresses and cookie IDs and device IDs from mobile apps and websites for 14 days and then stores them for another 90 days on backup servers. Other IP addresses and identifiers we receive in log files from our partners is kept for 180 days.

Choice and Opt-Out

Visto is a member of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”) and adheres to their respective self-regulatory codes. The NAI and DAA administer programs that provide consumer awareness and choices regarding the collection and use of web viewing data and mobile application use data over time and across non-affiliated websites and mobile apps in order to infer consumer interests and deliver relevant advertising back to browsers or mobile devices and across associated browsers and mobile devices. This practice is known as interest-based advertising. Additionally, Visto partners with other advertising networks and providers to deliver ads on our behalf, or on behalf of others, across the Internet. As a member of these programs, we and other participating companies provide choice via the DAA choice tool available at www.aboutads.info/choices, and honor your mobile device’s choice tool such as “Limit Ad Tracking.” Exercising choice through these tools will stop the collection of data from the browser or device where choice was made for interest-based advertising on that browser or device and associated devices, and the use of information collected from associated devices for interest-based advertising on the opted-out browser or device. When you exercise choice, Visto places an opt-out cookie on your computer. The Visto opt-out cookie tells us not to collect data from your browser or device to tailor online advertisement campaigns. Note that electing to opt out will not stop advertising from appearing in your browser or mobile device. It may make the ads you see less relevant to your interests. In addition, note that if you use a different browser or device, reset your advertising identifier in your device settings, or delete cookies from your browser, you may need to renew your opt-out choice. Visto will still collect data for other purposes including reporting, analytics, and other business purposes.

Individual Rights

You have the right to request the exercise of the following individual rights where relevant:

  • To access information we maintain about you.
  • To correct information we maintain about you, such as an email address.
  • To request that we erase information we maintain about you.
  • To restrict our processing of information we maintain about you.
  • To object to our processing, or exercise your right to data portability.

If you provided us with information based on consent, such as information used for interest-based advertising, you can withdraw that consent. In order to exercise these rights you can contact us at legal@vistohub.com. We may be unable to facilitate these rights in certain circumstances

Children

Visto does not knowingly collect personal information from children under the age of 13 through our Services, nor via any websites. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to instruct their children to never provide personal information on any website without parental permission. If you have reason to believe that a child under the age of 13 has provided personal information to Visto, please contact us.

EU-U.S. Privacy Shield

Visto complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union or European Economic Area to the United States. To learn more, please view our EU-U.S. Privacy Shield Policy.

Links to Other Websites

We may provide links to third-party sites, which are maintained by third parties. Please be aware that we are not responsible for and cannot control the privacy policies of these other linked sites or their practices. We suggest that you visit those sites directly for information on their privacy, security, data collection and distribution policies because they may differ from Visto’s own position under this Privacy Policy.

Security

We have reasonable security measures in place intended to help protect against the loss, misuse or alteration of any personal data processed. However, we are unable to guarantee that the security measures we take will not be penetrated or compromised or that your information will remain secure under all circumstances. We retain Activity Information used for advertising purpose for up to two (2) years from the last interaction between our cookie and your browser or device.

Changes to Our Privacy Policy

This Privacy Policy is effective as of the date listed at the top of this policy. We may change this Privacy Policy from time to time, and will post prior notice of any such changes on our website.

Data Protection Authorities

You have the right to make a complaint about Visto’s data practices to the local supervisory authority in your country of residence. To do so, you can visit the appropriate authority’s website.

How To Contact Us

If you wish to contact us about this Privacy Policy you can reach us by email at legal@vistohub.com or by telephone at US +1 646.790.8575. You may reach Visto’s office of data protection at legal@vistohub.com and the below:

Visto Legal Department
72 Madison Avenue, 3rd Floor
New York, NY 10013
United States of America