Privacy Policy

We serve our customers, partners, and advertisers through our advertising platform, our corporate website, and through other products and services.

To assure your greatest experience, we provide tools to help you maintain greater control of your data with us.

Our Privacy Pledge

At Upscale Digital, we take privacy very seriously. As such, we pledge to be totally transparent in regard to how we collect and use your data, keeping it secure while adhering to all current privacy policies and regulations.

Our commitment is to keep your information secure and to provide you meaningful choices in how that data is used, as well as to provide you, the data subject with control of the data to request to view or to delete what we have collected.

The Privacy Policies below are designed to help you understand what information Upscale Digital collects, why we collect it, how we use it, how we share it, and how we protect it.

Upscale Digital, LLC. (“Upscale Digital DSP”, “Upscale Digital”, “DSP”, “we”, “us” or “our”) is a digital advertising platform that delivers sponsored content also known as “native content” to third party websites or applications. This Privacy Policy and our Terms of Service forms an agreement between you and Upscale Digital for your use of the Website and Services. Collection of your personal information and data is governed by the Upscale Digital Privacy Policy in effect at the time the information is collected or processed. This Privacy Policy may be changed at any time and without notice to you by updating this page.

Upscale Digital DSP provides technology that enables advertisers and their advertising agencies manage digital advertising campaigns across mobile devices, video and display.

Our DSP uses data to make ads more effective and to measure their performance. Data is collected and used to ensure that the ads/content that we provide are relevant to your interests and to measure the effectiveness of ad delivery.

References to the DSP throughout this policy only refer to the Upscale Digital’s own advertising technology platform and do not include the technology or systems of clients or partners that use or integrate with us. They are bound by our policies when they use our DSP.

Information We Collect

 

Personal Identifiable Information (PII) We Collect

We may collect PII such as your name, email address and phone number when you interact with our website as an advertiser in the manners described below. PII is distinguished from “pseudonymous” data we collect about your browser or device (as described below) in that PII links to, or is, data which can directly identify you as an individual, client or prospective client.

PII we collect may be voluntarily provided, for example when you request more information through a form on the Websites, subscribe to our blog or apply for employment. The PII that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your PII.

The DSP does not collect or maintain explicit Personal Information in any form and only collects and stores pseudonymous data, data that does not directly identify any individual. Names, email addresses, phone numbers, etc. are not stored within our Platform, and we prohibit our clients and partners from providing explicit PII to our Platform.

As part of our digital advertising platform and reporting Services, we and our Service Providers log page views and collect anonymous information about activities and interactions on the Website, third party websites, and in mobile apps for the purpose of delivering ads or providing advertising-related services, including providing a specific advertisement based on a particular type of browser or time of day, statistical reporting in connection with the activity on a website or app, and tracking the number of ads served on a particular day to a particular website or app.

This includes:

• Unique cookie identifiers (cookieID)
• Mobile device advertising identifiers (MAIDs – IDFA/AAID)
• IP addresses
• Location information based on IP address or latitude/longitude
• Ad measurement information
  • Ad metrics
    • Time shown
    • Device/Platform
    • User (cookieID)
    • Website URL
    • Mobile application
  • User interest information

We also work with Service Providers that collect additional data and non-personally identifiable information about users who interact with our Platform.

Pseudonymous Data

We may automatically collect pseudonymous data that does not directly identify you personally but is linked to your computer or device. We collect this data from you in the normal course of operating our Websites. When you visit our Websites, we automatically collect information about your computer that your browser sends, such as IP address, browser type and language, access times, pages visited, and referring website addresses.

We may also collect information about your mobile device such as the type and model, operating system, carrier name, mobile browser, applications using our Websites, and identifiers assigned to your device, such as IDFA and AAID.

We may also collect your location information, such as your zip code or the approximate geographic area derived from your IP address or location positioning information provided by the location services and GPS features of your mobile device when location services have been enabled.

Pseudonymous data may contain cookie data. To understand more about how cookies are used on our Websites, see the Upscale Digital Cookie Policy section below.

How We Collect Your Data

The Platform receives data in several ways, including the following:

• Bid requests received from our supply partners on “supply” (publisher) side of the advertising ecosystem.
  • These bid requests contain information about the placement (ad real estate on the website or app), the device, the user, and sometimes location information. They also usually have an ID that enables us to match the request with information we may already have.

• Tags (pixels) and cookies, which allow us to recognize websites across.
• Mobile device IDs [MAIDs: Apple (IDFA), Android (AAID))] provides ability to identify the device. We use these IDs the same way we use cookies.

How We Use Your Information

Any PII you provide to or through the Websites shall be used for the purposes for which you provided it that were disclosed at the time it was collected.

We use PII to respond to inquiries initiated by individuals, to provide services requested by such individuals, to alert you to changes in services or features and to provide you with requested information regarding our services. We may also use your email address to send you our newsletter or blog if you are a client or have chosen to receive it. If you no longer wish to receive marketing email communications, you can follow the unsubscribe instructions contained in the emails you receive or by contacting us at privacy@upscale.digital

We also use pseudonymous data to assess the use and operation of our Websites and to better understand how our Websites are used. We use this information to conduct analytics, measure trends, and streamline website usability.

The DSP processes data both on our own behalf and on behalf of clients and partners for purposes related to the targeting, delivering, measuring of and reporting on advertising.

The combination of data (Cookie, MAID, IP, and audience segment) is used for providing our basic service of ad delivery for maximizing advertising effectiveness.

We use this combination of data to target the proper advertising through processes and determination of interests and behaviors in support of personalization of delivery of tailored content for Interest Based Advertising.

Information is also used to improve a unique User’s experience across multiple browsers and devices (such as smartphones, tablets, or display) by providing better targeted ad campaigns to that User. We may identify a User on a mobile device and may want to provide similar content through other devices that are associated with the same user. To do this, we identify unique Users across devices, or we may sync cookies and identifiers with our service providers to help our Customers enhance their own data and data segments.

How We Share Information

We will share your information with third parties only in the ways that are described in this policy. In addition, we do not, and will not, sell your information collected through our Websites to any third party.

Cookies Policy

“Cookies” are data files that are stored on your browser or device and are used to remember user preferences and behaviors over time. Cookies allow us to recognize your device and remember information, such as your preferred language and other general settings.

Cookies set by the website owner (in this case, Upscale Digital) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Our Websites use both first party and third-party cookies.

First Party Cookies

First party cookies on our Websites are used for a variety of reasons, including purposes which may be strictly necessary for our Websites to function properly.  Because these cookies are strictly necessary to deliver our Websites, we do not seek consent for such uses.

Third Party Cookies

Our Websites may contain content, pixels or cookie syncs from third parties, as outlined below. Note also that, in jurisdictions where consent is required for the placement of cookies, the appearance of any third parties on our Websites is subject to these consents being obtained by or on behalf of these third parties through, for example, the IAB’s Transparency and Consent Framework. We do not control these third parties, and you should refer to the privacy statements of our partners and service providers listed below to find out how they use cookies on our Websites and any data derived from such cookies.

Our Websites may contain content or pixels from service providers providing certain services on behalf of Upscale Digital. These third parties currently include:

Google Analytics

Website analytics services

Google opt-out

Our Websites may also contain content, pixels or cookie syncs from other ad tech partners, including Upscale Digital and our pixels. These third parties may collect data about your web viewing behavior on our Websites and combine this data with information collected from other websites over time for purposes that include targeted advertising. Most advertising networks offer you a way to opt-out of targeted advertising. If you would like more information, please refer to the “Customer Options” section below.

You can remove or manage cookies by following directions provided in your browser or device’s “help” or “preferences” areas. Note: if you reject cookies, you may still use our Websites, but some functionalities and areas of our Websites may be limited. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information. You may also seek additional information here.

Other Technologies

Our third-party partners or service providers may employ other tracking technologies like clear gifs (sometimes called “web Beacons” or “tracking pixels”), that are pieces of code that can be embedded on websites and can be used to learn how you interact with that website. Clear gifs help us better manage content on our Websites by informing us what content is effective.  We also use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functionality.

Customer Options

Upscale Digital Opt-Out

If you do not want our trusted business partners to place cookies on your device when browsing our Sites, you can adjust your browser settings to manage or reject cookies, or to notify you when a cookie is being placed in your Internet browser software. These settings are usually found in the ‘Options’ or ‘Preferences’ menu of your Internet browser. For more information on how to change your browser settings, click on the Help section of your Internet browser. Modern Internet browsers also allow you to see what cookies are currently stored on your device and selectively delete them as you wish.

If you do not want us to place cookies on your device when you interact with or use our Services in order to tailor content and information that we may send or display to you and otherwise personalize your experience while interacting with our Services, you can either adjust your browser settings (as explained above).  

On browsers that are configured to reject cookies, the opt-out may not be effective, since we identify the choice to opt-out based on a cookie delivered to the User. In this case, the User will need to confirm that the browser is configured properly in order for the opt-out to be effective. For a Safari browser on iOS11 or macOS High Sierra, a User must first adjust the Privacy and Security Settings to turn off both “Prevent Cross-Site Tracking” and “Block All Cookies”, and then return to this privacy policy or preferred opt-out platform to reset opt-out preferences.

Opting out of Cookies does not necessarily mean that the User will no longer see the Services.  However, opting out does mean that the Services will be less relevant because it will not be based on information collected about the User or the User’s browsing history.

Industry Opt-Out

The online advertising industry also provides websites from which you may opt out of interest-based advertising from Upscale Digital and other companies that participate in self-regulatory programs.

• United States based opt out:
  • aboutads.info/choices
  • networkadvertising.org/choices

• European based opt out:
  • youronlinechoices.com

• Canada based opt out:
  • ca/choices.

Mobile Apps

You can opt out of Upscale Digital using information about your usage of mobile apps that are targeted to your interests by using your device settings, for most devices. We are not able to directly access the Mobile App Opt Out on devices that offer it. To learn how to use the mobile app opt out, consult your device instructions. To find information on Opting out on Mobile Devices please visit http://www.networkadvertising.org/mobile-choice.

Adherence to Do Not Track Signals (“DNT”)

DNT is a privacy preference that you may set in certain browsers or may be preset in certain instances. Please note that Upscale Digital does not currently honor DNT signals sent by browsers or otherwise included through third party intermediaries.

Your Rights

You have the right to request access to or deletion of the information we have collected about you through our Websites. If you’d like to access, update, correct, or request deletion of your information that you have provided to us on our Websites or elsewhere, please do so by visiting https://privacy.bttrack.com. We may take reasonable steps to confirm your identity. You will not be discriminated against for the exercise of such rights (for example, we will not provide you with a different level or quality of goods or services).

Additional Privacy Rights for California

Effective January 1, 2020, if you are a resident of the State of California (as defined in Section 17014 of Title 18 of the California Code of Regulations), then you have the below additional rights under the California Consumer Protection Act (CCPA). Any terms defined in the CCPA have the same meaning when used in this Section.

Deletion. You have the right to request the deletion of your personal information that we have collected and retained, subject to certain exceptions.

Disclosure. You have the right to request, no more than twice in a 12-month period, disclosure of the personal information about you that we collect, use, disclose and sell during the preceding year, which shall include as follows:

• The categories of personal information that we’ve collected and sold about you, or shared for a business purpose with our service providers.
• The categories of sources from which we collected such information.
• The categories of third parties with whom we’ve shared that personal information and to whom we’ve sold that personal information.
• Our business or commercial purpose for collecting or selling that personal information.
• The specific pieces of personal information we collected about you.

 

Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights.

Effective January 1, 2020, if you wish to contact us to submit a request under the California Consumer Privacy Act of 2018, please feel free to contact us through by email at privacy@upscale.digital. Your request must: (a) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (b) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

For purposes of exercising your rights above, please refer to the “Information We Collect”, “How We Share Information” and “Cookie Policy” sections of this policy, which discloses the categories of personal information we have collected about consumers in the previous 12 months and the business purposes for which we use and disclose the information we collect.

For clarity, under CCPA personal information does not include de-identified or aggregated consumer information.

How We Protect and Retain Personal Information

We take security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data and Personal Information. These include firewalls and encryption, internal reviews of our data collection, storage and processing practices, and security measures, as well as physical security measures to guard against unauthorized access to systems.

If we retain data and Personal Information on our systems, we restrict access to data and Personal Information to employees, contractors, and agents who need to know that information in order to operate, develop, or improve our Websites, products, and services. These individuals are bound by confidentiality obligations through a signed Non-Disclosure Agreement (NDA) and may be subject to discipline, including termination, if they fail to meet these obligations.

We retain identifiable data, which is directly collected for purposes of serving ads, for twenty-eight (28) days from the User’s last interaction with our Services, after which time we de-identify the data by removing unique identifiers or aggregating the data.

We retain aggregated data, which cannot identify an individual or device and is used for purposes of reporting and analysis, for as long as commercially necessary. We keep opt-out information for longer than this period so that we can continue to honor opt-out requests.

Upscale Digital reserves the right to delete any or all data and Personal Information that relates to you, the User, at any time and in Upscale Digital’s sole discretion, notwithstanding its normal data retention policies. If Upscale Digital changes its retention data policies by updating this Privacy Policy, its new policies will apply to all data then retained by Upscale Digital.

COPPA Compliance

Upscale Digital adheres to the Children’s Online Privacy Protection Rule (COPPA). We do not knowingly collect any data or target an advertisement on a website directed towards on a website directed to children under the age of thirteen (13). If you, a Customer or User, are the parent or guardian of a child under the age of thirteen (13) and have a concern regarding the Information we collect, please contact support@upscale.digital.

Modification of this Policy

This Privacy Policy is current as of the Effective Date set forth above.

Upscale Digital may change this Privacy Policy from time to time, so please be sure to check back periodically. We will post any changes to this Privacy Policy on our Sites.

If we make any changes to this Privacy Policy that materially affect our practices with regard to the Information we have previously collected from you, a Customer or User, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Sites. We will not apply these changes retroactively.

It is your responsibility to review this Privacy Policy frequently and remain informed about any changes to it, so we encourage you to visit this page often. By continuing to use the Services or this Website or by sharing information with us, you consent to the use of your information as disclosed in this Privacy Policy.

How To Contact Us

For questions or concerns regarding this Policy, contact: