Privacy Policy

This Privacy Notice explains how MediaGo (“MediaGo” “we” “us”or “our”) collects, processes, uses, and discloses personal information in connection with our websites (the “Sites”) and the related content, products, services, and other functionality offered on or through the online services, including where you interact with MediaGo through mobile applications and/or websites that have integrated with MediaGo’s advertising platform either directly or via an advertising exchange (collectively, the “Services”). It does not address our privacy practices relating to MediaGo job applicants, employees and other personnel.

MediaGo is an advertising platform the enables advertisers to serve advertisements on third-party mobile applications and/or websites owned or operated by partners or to which a partner has the right to serve advertising. We are an official vendor of Interactive Advertising Bureau (IAB) Europe’s Transparency and Consent Framework (TCF).

When our Customers (as defined below) deliver advertisements or use our Services to submit, manage, or otherwise use content relating to our Customers’ data (“Customer Data”), we have contractually committed ourselves to only process such information on behalf of and under the instruction of the respective customer, who is the “data controller.” This Privacy Notice does not apply to such processing and we recommend you read the privacy notice of the respective Customer if their processing concerns your personal information.

Table of Contents

1. Information We Collect

2. How We Use Your Information

3. How We Disclose Your Information

4. Third-Party Links

5. Children’s Personal Information

6. Regional Privacy Disclosures

7. Contact Us

8. Updates to This Privacy Notice

9. Last Revision Date

1. Information We Collect

We collect personal information about individuals in a number of ways, including automatically when an individual interacts with our Services and directly from an individual. We also collect information about our customers who are advertising business partners, such as advertisers, agencies, ad exchanges, ad networks, ad optimization and measurement/attribution partners, and publishers (“Customers”).

1.1 Personal Information Collected From our Customers

We may collect the following personal information from our Customers:

  • Customer Contact Information, including name, email address, phone number, company name, job title, country/region, state/region and communication preferences. We also collect any information you provide in custom messages sent to us.
  • Customer Account Information, including name, company name, job title, email address, login credentials, profile information, dashboard information, campaign information (including ad content, the platform used, and budget information), postal address, phone number, payment and purchase history information, payment card information, and any other information you provided to us. Please note we utilize a third-party provider to process payments on our behalf and do not accept payment directly through our Sites. As such, we do not retain any financial account information, such as credit card numbers. Rather, all such information is provided directly by you to our third-party processor. We do, however, receive information form the payment processors regarding your transaction such as order ID, payment amount, payment time, payment status (success/failure), and email address. The payment processor’s use of your personal information is governed by their privacy notice.
  • Inferences About Individuals’ Interests, Preferences, and Other Behavioral Data, including hobbies, demographics, interests, and characteristics, e.g., purchases and consuming tendencies.

1.2 Personal Information Automatically Collected

General. As is true of many digital properties, we and our third-party partners may automatically collect certain information from or in connection with users’ and other website visitors’ devices when visiting or interacting with our Services, such as the list below and in the sub-sections here:

  • Device Data, including internet protocol (IP) address, operating system, device type and version, browser type and version, the URL entered and the referring page/campaign, date/time of visit.
  • Analytics data, including the path taken to our Services, through our Services, and when exiting our Services, usage and activity on or in connection with our Services, metrics on how many links are opened, clicked, or viewed (such as via pixels, as described further below), web log data and other information normally transmitted in HTTP/HTTPS requests.
  • Location data, such as approximate geolocation from your device’s IP address.
  • Advertising/Advertising Measurement Data, including data associated with your view of, or click on, advertisements served on our Services, cookie IDs or other digital or proprietary identifier assigned to such device, and device metadata and analytics data described above, in each case, for purposes of serving advertising (personalized or otherwise) or facilitating advertising measurement/attribution to better optimize or otherwise understand the effectiveness of ad campaigns. We may also process information about your interactions with any advertisements we deliver, such as information about the advertisements served, viewed or clicked on, and any preferences you may have expressed in respect of that advertisement.

For more information on our and third-party partners’ data collection and online advertising practices, please see the “Third-Party Data Collection and Online Advertising” section of our Cookie Notice.

For more information about these practices and your choices regarding these technologies, please see our Cookie Notice.

1.3 Personal Information from Third Parties

We also obtain personal information from third parties, which we often combine with personal information we collect either automatically or directly from you.
We may receive the same categories of personal information as described above from the following third parties:

  • Your Employer / Company: When an individual interacts with our Services as an employee or representative of their company, we may receive their information from their employer or other employees at their company.
  • Our Customers/Ad Partners: We may receive your information from our Customers, ad partners, or other individuals who interact with our Services.
  • Service Providers: Our service providers that perform services solely on our behalf, such as payment processors or survey and certain advertising/marketing providers, collect personal information and may share some or all of this information with us.
  • Other Sources: We may also collect personal information about individuals that we do not otherwise have from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions.

2. How We Use Your Information

We collect the above-mentioned information for various purposes, including:

  • To fulfill your requests and provide our Services to you. This includes:
    • Making our Services, including our ad services and MediaGo products, available to you and our Customers and partners.
    • Serving you with relevant and personalized advertisements and understanding the audiences who see the advertisements we serve.
    • Auditing and reporting.
    • Providing ad campaign analytics to our Customers.
    • Cross-device targeting to link or resolve the same user across their various devices.
    • Coordinating access to Customers’account.
    • Responding to requests, suggestions, questions, and comments, and providing other types of user support.
    • Fulfilling Customers’ payments and transactions.
    • Sending Customers service/transaction-related messages, such as changes to Customers’ account.
    • Communicating about, and administering your participation in, programs, contests, surveys, and other offers or promotions.
  • For marketing and advertising purposes. We may send Customers communications about new features, updates, products, and special offers. We may also use Customer information to serve ads about our products or other products or services we (or our advertising partners, such as other third-party brands) think our Customers might find interesting. We may also use individual and aggregate information about our Customers to inform our marketing and advertising campaigns. For more information on your choices about marketing communications, see our Cookie Notice.
  • To personalize your experience on our Services and tailor content. We use personal information to tailor the content that we display on our Sites in order to provide users with a personalized experience.
  • To communicate with our Customers. We use Customers’ information to communicate with our Customers about Customers’ account activities, to introduce our new products, to respond to Customers’inquiries, requests, or complaints, and to introduce our product updates. We may communicate with Customers by email.
  • To monitor, improve, and develop our products and services. We use personal information to understand our website visitors, users, and Customers and to tailor or optimize our Services. For example, we may analyze statistics and trends to make our Services better, to develop the Services or new services and features, to display how many Customers use our dashboard, or to show which webpages on our Sites you have viewed. This information helps MediaGo analyze what features our users and Customers are interested in.
  • To protect the security and integrity of our business, comply with legal requirements and obligations, or as otherwise permitted by law. We may use information to protect our company, our affiliates, our customers, and our Services. We may also use information in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, protect and defend our rights and property, or the rights or safety of third parties, enforce our Terms of Use, this Privacy Notice, or agreements with third parties, detect and prevent fraud or for crime-prevention purposes, or for any other reason permitted by law. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets and may use information in connection with or as an asset in such a corporate business transaction. Personal information may also be used in the event of insolvency, bankruptcy, or receivership.
  • For any other purposes with your consent, at your direction, or where notice is provided: We may use your personal information for any other purposes with your consent, at your direction, or where notice is otherwise provided.

3. How We Disclose Your Information

We may share your information in the following ways:

  • The Baidu group. This includes other brands owned or controlled by Baidu and other companies owned by or under common ownership as MediaGo, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Notice.
  • Service providers. This may include cloud services providers, consultants and other service providers that perform services on our behalf, in order to carry out their work for us, which may include dentifying and serving targeted advertisements, content or service fulfilment, or providing analytics services.
  • Future parties to the Baidu group. Other parties in connection with any MediaGo or Baidu company transaction, such as a merger, sale of all or a portion of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy or related or similar proceedings.
  • Customers/Online advertising partners. We may share information with our Customers and third-party online advertising partners, including ad exchanges and demand side platforms (DSPs), or permit these Customers and partners to collect information from you directly on or through our Services to facilitate online advertising.
  • Third parties as required to. For example, to: (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms of Use Agreement, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of MediaGo, its users or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.
  • With your consent or at your direction. In addition to the sharing described in this Privacy Notice, we may share information about you with third parties whenever you consent to or direct such sharing.

In connection with any of the above, we may share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you.

4. Third-Party Links

The Services operate on third party websites and may contain links to third party websites of our business partners, advertisers, social media sites, and our customers may post links to third party websites. If you follow a link to any of these websites, or browse on our customers’ websites, please note that these websites have their own privacy notices and policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

5. Children’s Personal Information

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If an individual is under the age of 13, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.

6. Regional Privacy Disclosures

We may choose or be required by law to provide different or additional information relating to the processing of personal information (as defined below) about residents of certain countries, regions or states. Please refer below for additional information that may be applicable to you:

  • Notice to EU individuals: If you are located in the European Economic Area (“EEA”), United Kingdom (“UK”) or Switzerland, or otherwise engage with our European operations, please see the European Privacy Notice below for additional European-specific privacy information, including what constitutes your personal data, the lawful bases we rely on to process your personal data, how we use cookies when you access our Services from the EEA, UK or Switzerland, and your rights in respect of your personal data.
  • Notice to California residents: If you are a resident of the State of California in the U.S., please see our California Privacy Notice below for additional California-specific privacy information.
  • Notice to Nevada consumers: If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Please contact us at mediago-privacy@baidu.com to submit such a request.

7. Contact Us

If you have questions about the privacy aspects of our Services or your user information, please contact us at: mediago-privacy@baidu.com

8. Updates to This Privacy Policy

We reserve the right to modify this Privacy Notice from time to time. If we make any changes to this Privacy Notice, we will change the “Last Revision” date below and will post the updated Privacy Notice on this page. However, in case the modifications are significant, we will provide you with a more prominent notice.

9. Last Revision Date

This Privacy Notice was last revised on, and effective as of, February 15, 2023.





CALIFORNIA PRIVACY NOTICE

1. SCOPE OF NOTICE

This California Privacy Notice (the “CA Notice”) supplements the information contained in our Privacy Notice above and applies solely to individual residents of the State of California (“consumers” or “you”).

This CA Notice describes how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (CCPA).

Unless otherwise expressly stated, all terms in this CA Notice have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.

When we use the term “personal information” in this CA Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

2. COLLECTION AND USE OF PERSONAL INFORMATION

We collect personal information from and about consumers for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to the “Information We Collect” and “How We Use Your Information” sections of our Privacy Notice.

In the last 12 months, we have collected the following categories of personal information:

From our Customers:

From users/web visitors:

We collect this information from a variety of sources, including: directly from you, from your employer or organization, from our customers and other users, from our business partners and affiliates, from your browser or device when you use our Services, or from third parties that you permit to share information with us. Please see the “Information We Collect” section of the Privacy Notice for more information about the sources of personal information we collect.

3. DISCLOSURE OF PERSONAL INFORMATION

As described in the “Our Disclosure of Personal Information” section of our Privacy Notice, we share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales.

The categories of third parties to whom we sell or disclose your personal information for a business purpose may include: (i) other brands and affiliates in our family of companies; (ii) our service providers and advisors; and (iii) marketing and strategic partners.

In the previous 12 months, we have disclosed or sold all of the categories of personal information we collect, explained in the “Collection and Use of Personal Information” section of this CA Notice, to third parties for a business purpose.

4. YOUR CALIFORNIA PRIVACY RIGHTS

As a California resident, you may be able to exercise the following rights in relation to the personal information that we have collected about you (subject to certain limitations at law):

The Right to Access/Know

You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:

  • The specific pieces of personal information we have collected about you;
  • The categories of personal information we have collected about you;
  • The categories of sources of the personal information;
  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of personal information we have sold about you (if any), and the categories of third parties to whom the information was sold;
  • The business or commercial purposes for collecting or, if applicable, selling the personal information.

You may request this information no more than two times per year.

The Right to Request Deletion

You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.

The Right to Opt Out of Personal Information Sales

You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.

If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.

The Right to Non-Discrimination

You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

“Shine the Light”

California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code §1798.83).

5. HOW TO EXERCISE YOUR CALIFORNIA CONSUMER RIGHTS

To Exercise Your Right to Access, Right to Know or Right to Deletion

To exercise your Right to Access, Right to Know or your Right to Deletion, please submit a request by emailing us at mediago-privacy@baidu.com with the subject line, “California Rights Request.”

Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address, phone number, and/or date of last transaction on our Services.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

To Exercise Your Right to Opt-Out of “Sales”

We “sell” personal information to third parties, as such term is broadly defined under the CCPA. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties.

To exercise your right to opt-out of “sales,” you may submit a request by clicking the following link:

Do Not Sell My Personal Information

Authorized Agents

In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in this CA Notice where we can verify the authorized agent’s authority to act on your behalf.

For requests to know or delete personal information, we require the following for verification purposes:

  1. a power of attorney valid under the laws of California from you or your authorized agent; or
  2. sufficient evidence to show that you have:
    1. provided the authorized agent signed permission to act on your behalf; and
    2. verified your own identity directly with us pursuant to the instructions set forth in this CA Notice; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

For requests to opt-out of personal information “sales”, we require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

Minors Under 16

We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at mediago-privacy@baidu.com to inform us if you, or your minor child, are under the age of 16.

“Shine the Light”

If you have an established business relationship with us, you may have rights to know how your information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83). To make such a request, please send an email to mediago-privacy@baidu.com.





EUROPEAN PRIVACY NOTICE

Effective Date: February 15, 2023.

This European Privacy Notice contains information on how we collect, store, process, transfer, share user data that identifies or is associated with residents of the European Economic Area (“EEA”), Switzerland, and the United Kingdom (“UK”) (“personal data”) and information regarding our use of cookies and similar technologies. This European Privacy Notice applies solely to residents of the EEA, Switzerland, and the UK (“you”). Please ensure that you have read and understood this European Privacy Notice before accessing or using the Services. Unless otherwise expressly stated, all terms in this section have the same meaning as defined in our Privacy Notice or as otherwise defined in the General Data Protection Regulation (“GDPR”).

Baidu (Hong Kong) Limited is the controller of the personal data we hold about you in connection with your use of the Services. This means that we determine and are responsible for how your personal data is used.

1. Personal Data We Collect from our Customers When Customers Use the Services and How We Use It

We collect personal data as set out in the “Information We Collect” and “How We Use Your Information” sections of our Privacy Notice above. We will indicate to Customers where the provision of certain personal data is mandatory. If Customers choose not to provide such personal data, we may not be able to provide those parts of the Services to our Customers or respond to Customers’ other requests.

The table at Annex 1 sets out in detail the categories of personal data we collect about our Customers and how we use that information when Customers use the Services, as well as the legal basis which we rely on to process the personal data and recipients of that personal data.

2. Information We Collect About You Automatically

We also automatically collect personal data indirectly about how you access and use the Services, and information about the device you use to access the Services, or otherwise engage with us. Please see the “Personal Information Automatically Collected” section of our Privacy Notice for more information about what data we collect and how we use it.

3. How Long Will We Store Your Personal Data

We will usually store the personal data we collect about you for no longer than necessary for the purposes set out in Annexes 1 and 2, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements, and in accordance with our legal obligations and legitimate business interests.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.

4. Recipients of Personal Data

We may share your personal data with the recipients as set out in the “Our Disclosure of Personal Information” section of our Privacy Notice (as required in accordance with the purposes set out in Annexes 1 and 2).

5. Marketing and Advertising for our Customers

From time to time we may contact our Customers with information about our products and services, including sending Customers marketing messages and asking for Customers’ feedback on our products and services.

6. Storing and Transferring Your Personal Data

In the event of such a transfer, we ensure that: (i) the personal data is transferred to countries recognised as offering an equivalent level of protection per GDPR Article 45; or (ii) the transfer is made pursuant to appropriate safeguards, such as the European Commission’s standard contractual clauses. You can review the agreement on the basis of approved EU standard contractual clauses per GDPR Art. 46. For more information, see here.

If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this European Privacy Notice.

7. Your Rights in Respect of Your Personal Data

In accordance with applicable privacy law, you have the following rights in respect of your personal data that we hold:

You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

You also have the right to lodge a complaint to your local data protection authority. Information about how to contact your local data protection authority is available here.

If you wish to exercise one of these rights, please contact us using the contact details at the end of this European Privacy Notice.

Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.

8. Cookies and Similar Technologies Used on Our Services

Our Services use cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together “cookies”) to distinguish you from other users of our Services. This helps us to provide you with a good experience when you browse our Services and also allows us to monitor and analyse how you use and interact with our Services so that wl.me can continue to improve our Services. It also helps us and our Customers and partners to determine advertisements, products and services that may be of interest to you. Please see our Cookie Notice for more information about these practices and your choices regarding cookies and similar technologies.

9. Our Policy Towards Children

The Services are not directed at persons under 16. We do not knowingly collect or solicit personal data from any persons under the age of 16. In the event that we learn that we have inadvertently collected personal data from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 16, please contact us using the details at the end of this European Privacy Notice.

10. Changes to This European Privacy Notice

We may update this European Privacy Notice from time to time and so you should review this page periodically. When we change this European Privacy Notice in a material way, we will update the “Effective Date” above. Changes to this European Privacy Notice are effective when they are posted on this page.

11. Contact Us

If you have any questions, comments and requests regarding this European Privacy Notice, please contact mediago-privacy@baidu.com or write us at:
Baidu (Hong Kong) Limited
Attn: Privacy Notice
1102, The Lee Gardens, 33 Hysan Avenue, Causeway Bay, Hong Kong





COOKIE NOTICE

Effective Date: February 15, 2023.

Unless otherwise expressly stated, terms in this notice have the same meaning as defined in the Privacy Notice.

1. SCOPE OF NOTICE

This Cookie Notice supplements the information contained in the Privacy Notice and explains how we and our business partners and service providers use cookies and related technologies in the course of managing and providing our online services and our communications to you. It explains what these technologies are and why we use them, as well as your rights to control our use of them.

In some cases, we may use cookies and related technologies described in this Cookie Notice to collect personal information, or to collect information that becomes personal information if we combine it with other information. For more details about how we process your personal information, please review the Privacy Notice.

2. WHAT ARE COOKIES AND RELATED TECHNOLOGIES

As is common practice among websites, our Services use cookies, which are tiny files downloaded to your computer that allow us and our third-party partners to collect certain information about your interactions with our email communications, websites and other online services, and that improve your experience. We and our third-party partners and providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”).

3. WHAT WE COLLECT WHEN USING COOKIES

We and our third-party partners and providers may use cookies to automatically collect certain types of usage information when you visit or interact with our email communications and Services. For example, we may collect log data about your device and its software, such as your IP address, operating system, browser type, date/time of your visit, and other similar information. We may collect analytics data to help us measure usage and activity trends for our online services and better understand our user base. We also may collect location data, including general geographic location based on IP address or more precise location data when a user accesses our online services through a mobile device.

We use the following types of cookies:

4. HOW WE USE INFORMATION COLLECTED VIA COOKIES

We use cookies for a variety of reasons outlined below:

Please note that we link some of the personal information we collect through cookies with the other personal information that we collect about you and for the purposes described in our Privacy Notice.

5. THIRD-PARTY DATA COLLECTION AND ONLINE ADVERTISING

General. We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on personal information and to measure the effectiveness of those ads. We permit our Customers, including third-party online advertising networks or exchanges (or other entities, such as demand-side or sell-side platforms or ad servers), measurement/attribution companies, ad fraud companies, social media companies, and other third-party services to collect information about your use of our online services so that they may display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technologies, which recognize the device you are using and collect information, including clickstream information, browser type, time and date you visited websites, mobile ad ID or other digital identifier (e.g., cookie ID, click ID, other proprietary IDs such as open source “universal IDs” or other ID solutions), geolocation, and other information. We may share a common account identifier (such as user ID) with our Customers and other third-party advertising partners to help identify you across devices. We and our Customers and third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, analytics, market research, and measurement/attribution. We may also use services provided by third parties to serve targeted ads to you and others on such platforms. Please see the “Your Choices About Online Ads” section below to learn how you can opt out of interest-based advertising.

6. YOUR CHOICES ABOUT COOKIES

If you would prefer not to accept cookies, most browsers will allow you to change the setting of cookies by adjusting the settings on your browser to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Be aware that disabling cookies may negatively affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionalities and features of the Services.

Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

7. YOUR CHOICES ABOUT ONLINE ADS

To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising (to the extent the advertising partner or other entity participates in such industry opt-out pages), you may wish to visit the Digital Advertising Alliance’s (DAA) resources or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/ and you can opt-out of receiving some interest-based advertisements on mobile apps by visiting http://www.aboutads.info/appchoices. You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at http://www.aboutads.info/appchoices.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from these self-regulatory program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs, or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under those self-regulatory programs.

You are currently: Not Opted Out Opt Out

You are currently: Opted Out Opt In

8. UPDATES TO THIS COOKIE NOTICE

We will update this Cookie Notice from time to time. When we make changes to this Cookie Notice, we will change the “Effective Date” at the beginning of this notice. If we make material changes to this notice, we will notify you by prominently posting on our Services or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

9. CONTACT US

If you have any questions or requests in connection with this Cookie Notice or other privacy-related matters, please contact us at mediago-privacy@baidu.com.





ANNEX 1 – PERSONAL DATA CUSTOMERS PROVIDE TO US

Category of Personal Data

How We May Use the Personal Data

Legal Bases for Processing

Recipients of Personal Data

Contact, inquiry and testimonial information, such as Customers’ name and email address. When Customers contact us directly, we will record Customers’ comments and opinions.

We may use this information to set up and authenticate Customers’ account on the Services.

The processing is necessary for the performance of a contract with Customers and to take steps prior to entering into a contract with Customers, namely our Terms of Use.

We may share this information with our service providers in order to provide Customers the Services and to send Customers account- and service-related communications. We may also share Customers’ personal data with our email marketing providers in order to provide Customers with the marketing communications Customers have signed up for.

We may use this information to communicate with Customers, including sending service-related communications.

The processing is necessary for the performance of a contract with you, namely our Terms of Use.

We may use this information to deal with enquiries and complaints made by or about Customers relating to the Services.

The processing is necessary for our legitimate interests, namely administering the Services, and for communicating with Customers effectively to respond to Customers’ queries or complaints.

We may use this information to improve the Services.

The processing is necessary for our legitimate interests (to develop and improve our Services).

We may use this information to send Customers marketing communications in accordance with Customers preferences.

We will only use Customers’ personal data in this way to the extent Customers have given us consent to do so.

Profile and log-in information. This is information Customers use to log-in to Customers account and information Customers choose to put in Customers’ profile such as phone number and mailing address.

We use this information to allow Customers to populate Customers’ profile with relevant information.

The processing is necessary for the performance of a contract and to take steps prior to entering into a contract, namely our Terms of Use.

 

We use this information to provide to Customers the features and functionality of the Services.

The processing is necessary for the performance of a contract and to take steps prior to entering into a contract, namely our Terms of Use.

Transaction information, such as Customers payment information, order information, payment confirmation, and other information such as date and time of Customers‘ transaction.

We may use this information to process the payments Customers make or receive through the Services.

The processing is necessary for the performance of a contract, namely our Terms of Use.

 

We may use this information to verify Customers’ identity in connection with the detection and prevention of fraud or financial crime.

The processing is necessary for our and third partiers’ legitimate interests, namely the detection and prevention of fraud and financial crime.

Information about Customers’ activity on the Services, such as information about any products and services Customers have considered or purchased.

We use this information to provide to Customers the features and functionality of the Services.

The processing is necessary for the performance of a contract and to take steps prior to entering into a contract, namely our Terms of Use.

We may share this information with our payment processors and our service providers for the purpose of facilitating the Services and transactions Customers have requested.

Customers’ preferences, such as preferences set for notifications, marketing communications, how the Services are displayed and the active functionalities on the Services.

We use this information to provide notifications, send news, alerts and marketing communications and provide the Services in accordance with Customers choices.

The processing is necessary for our legitimate interest, namely ensuring the user receives the correct marketing and other communications, and that this is displayed in accordance with the user’s preferences.

We may share this information with our service providers and marketing partners in order to set Customers’ preferences.

We use this information to ensure that we comply with our legal obligation to send only those marketing communications to which Customers have consented.

The processing is necessary for compliance with a legal obligation to which we are subject.

Inferences about Customers’ interests, such as Customers’ hobbies and characteristics.

We may use this information to serve Customers relevant and personalized advertisements, to improve the Services, and to provide Customers with the features and functionality of the Services.

 

We may share this information with our service providers, our Customers, and our partners in order to serve Customers relevant and personalized advertisements, to improve the Services, and to provide Customers, our Customers and our partners with the features and functionality of the Services.

Where required, we will only use Customers’ personal data in this way to the extent Customers have given consent to do so.

All personal data set out above.

We may use all the personal data we collect to operate, maintain and provide to you, our Customers, and our partners the features and functionality of the Services, to communicate with our Customers, to monitor and improve the Services and business, and to help us develop new products and services.

The processing is necessary for our legitimate interests, namely, to administer and improve the Services.

We may share this information with our service providers, our Customers, and our partners in order to serve you relevant and personalized advertisements, to improve the Services, and to provide you, our Customers and our partners with the features and functionality of the Services.

ANNEX 2 – PERSONAL DATA AUTOMATICALLY COLLECTED

Category of Personal Data

How We May Use It

Legal Basis for the Processing

Recipients of Personal Data

Approximate location information. For example, your device’s IP address may however help us determine your location.

We may use information you provide to us about your location to monitor and detect fraud or suspicious activity in relation to your account.

The processing is necessary for our legitimate interests, namely, to protect our business and your account from fraud and other illegal activities.

We may share this information with our service providers, our Customers, and our partners for purposes such as: to serve you relevant and personalized advertisements, to improve the Services, and to provide you, our Customers and our partners with the features and functionality of the Services.

We may use this information to tailor how the Services are displayed to you (such as the language in which it is provided to you).

The processing is necessary for our legitimate interest, namely tailoring our Services so that they are more relevant to our users.

Information about how you access, interact with, and use the Services. For example, how frequently you access or interact with the Services, the time you access or interact with the Services and how long you use them for, the approximate location that you access the Services from, the site from which you came and the site to which you are going when you leave our Services, the website pages you visit, the links you click, whether you access the Services from multiple devices, and other actions you take on the Services.

We may use information about how you use and connect to the Services to present the Services to you on your device.

The processing is necessary for our legitimate interests, namely, to tailor the Services to the user.

We may use this information to determine products and services that may be of interest to you for marketing purposes.

The processing is necessary for our legitimate interests, namely, to inform our direct marketing.

We may use this information to monitor and improve the Services and business, resolve issues and to inform the development of new products and services.

The processing is necessary for our legitimate interests, namely, to monitor and resolve issues with the Services and to improve the Services generally.

Log files and information about your device. We also collect information about the tablet, smartphone or other electronic device you use to connect to the Services and when you interact with the Services through mobile applications and/or websites that have integrated with MediaGo’s advertising platform either directly or via an advertising exchange. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Services through the device, your mobile network, your IP address and your device’s telephone number (if it has one).

We may use information about how you use and connect to the Services to present the Services to you on your device.

The processing is necessary for our legitimate interests, namely, to administer and improve the Services and to tailor the Services to the user.

We may use this information to monitor and improve the Services and business, resolve issues and to inform the development of new products and services.

The processing is necessary for our legitimate interests, namely, to monitor and resolve issues with the Services and to improve the Services generally.

We may use this information to serve you relevant and personalized advertisements, to improve the Services, and to provide you with the features and functionality of the Services.

Where required, we will only use your personal data in this way to the extent you have given us consent to do so.

 

ANNEX 3 – COOKIES

Cookie Name

Type of cookie

When is the cookie set?

How long does the cookie stay on my device?

Purpose of the cookie

Mediago uid

Functional Cookies

Users view or click Mediago ads

365 days

Holds the anonymous user’s ID. Used for tracking user actions, such as clicks on the recommendations.

Partner uid

Partner Targeting Cookies

Set by partner

365 days

Cookie syncing and/or digital advertising targeting partner