PRIVACY

Last Updated: April 2024

OpsCo LLC ("OpsCo", "we", "us", "our") is committed to protecting your personal information and your right to privacy. This privacy policy governs the privacy practices of our digital services.

If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at privacy@ops.co.

This policy describes what OpsCo does, how it processes data on behalf of its advertising and publishing partners, how it keeps data safe, and data sharing options you may have with regard to your personal data. This policy applies to all information through our services.
Please read this privacy notice carefully as it will help you understand how your personal information is processed by OpsCo.

Our privacy policy is organized into the following sections:

• Who We Are and What We Do
• How and Why We Process Personal Data
• Types of Data We Process
• Data Sharing Choices
• How We Keep Your Data Safe
• Other Important Information

1.0 WHO WE ARE AND WHAT WE DO

OpsCo helps publishers make money through advertising.
OpsCo connects publishers seeking to sell ad space with advertisers seeking to buy it.
OpsCo helps demand side platforms, advertising agencies and brands ("Demand Partners") buy digital ad space and helps ad networks, website and app publishers ("Publishers") generate revenue by selling available ad space.
OpsCo is a Google Certified Publishing Partner, and a Google-authorized reseller and support team for Google Ad Manager 360. The entities that work with OpsCo may have their own policies that govern how they collect, use, and share data, and may differ from OpsCo's policies. Below, we've listed the entities we work with (with links to their privacy policies) as of the date indicated at the top of this notice.

Please review the privacy policies of the websites and apps you visit and use to become familiar with their data practices and to learn about any data collection, sharing and use choices that you may have.

2.0 HOW AND WHY WE PROCESS PERSONAL DATA

We pass along information for advertising purposes.
If you visit a Publisher that works with OpsCp, and the Publisher sends out a request to show an ad, we pass along that request to Demand Partners. The request typically includes information about the ad environment that helps Demand Partners decide whether or not to serve an ad.
Some of this information (for example, your IP address) may identify a particular computer or device and may be considered personal information under some data privacy laws, including the Canadian Personal Information Protection and Electronic Documents Act ("PIPEDA"), the California Consumer Privacy Act ("CCPA"), and the European Union's General Data Protection Regulation ("GDPR").

OpsCo uses and discloses information for our commercial and business purposes, as identified in the CCPA, which include:

• Providing our services, including enabling Publishers and Demand Partners to sell and buy digital and mobile advertising inventory.
• Other business purposes, including:
  • Providing advertising or marketing services
  • Auditing related to our interactions with you
  • Legal compliance
  • Detecting and protecting against security incidents, fraud, and illegal activity
  • Debugging
  • Performing services (for us or our service providers) such as account servicing and analytics
  • Internal operations
  • Activities to maintain and improve our services
• Other one-time uses

OpsCo does not retain any personal information.

We facilitate the exchange of information for ad buying and placement purposes.
OpsCo does not build user profiles of any kind.

We process your data based under the following legal bases under the General Data Protection Regulation (GDPR):

• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests, which are to facilitate data exchange for advertising purposes.
• Performance of a Contract: Where we have entered into a contract with a partner, we may process personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

2.1 Pixels

When you visit a Publisher that works with OpsCo, we may place a tracking pixel on your browser in order to monitor the performance of an ad. We do not monitor you or your behavior using this pixel.

• A pixel is a small bit of HTML code which is loaded when a user visits a website or opens an email. With a tracking pixel, we enable our Demand Partners to access information about whether an ad was viewed or clicked on.

3.0 TYPES OF DATA WE PROCESS

OpsCo facilitates information exchange.
To sell ad space, Publishers may pass information to Demand Partners and other entities through OpsCo's technology. For example, when you visit a website or app and a Publisher working with OpsCo sends us a request to show you an ad, we pass along certain information about the ad space, you and your device to Demand Partners to help inform their decision to serve an ad.

OpsCo does not retain personal information or apply automated decision-making tools to this information, which typically includes:

• Bid Request Data (or “bidstream data”), advertising bid request in a specified format, such as oRTB (e.g., adID, DealID, cookie ID, geolocation, website/app, user agent string, device type, carrier name, campaign ID).
• User Session Data (or “clickstream data”): The end-user's 'journey' on a website or app collected by a server (e.g., IP address, referring URL, exit URL, actions taken, cookie preferences, device information).

Data passed through, not accessed by, OpsCo from its partners may also include:

• Cross-Device Data (or “Device Graph Data”): Data that displays the relationship between various device identifiers to an individual or household, often used for better retargeting and frequency capping.
• Unique online identifiers (e.g. IP address, cookies, mobile advertising identifiers such as Apple IDFA and Android Advertising ID)
• Information about your browsing behavior on a Publisher's website or app (e.g. domain or app store URL or bundle ID, category code associated with website or app, referring website address, date/time of visit, 'click through' data)
• Ad reporting or delivery data (e.g. size/type of ad, ad impressions, location/format of ad, data about interactions with the ad)
• Precise location data (if you have enabled location services on your device)
• Interest segments (i.e. inferred information on the behavior or likely interests associated with you)
• Retargeting data (i.e. data indicating previous interest in a product or website)
• Information that may be anonymized or pseudonymized includes, but is not limited to, clickstream data, search history, analytics, hardware/software type, page views, serving domains, internet service provider, and demographic information.
• Other data that can be passed in the request from Publisher to Demand Partner to inform the ad-buying decision (which can include health or financial-related information).Browser and Device information, such as the device type and model, manufacturer, operating system type and version (e.g. iOS or Android), web browser type and version (e.g., Chrome or Safari), user-agent, carrier name, time zone, network connection type (e.g., Wi-Fi or cellular), anonymized IP address (in certain cases), general location inferred from IP address, information about apps and versions currently active on a device (but not any other apps), and identifiers assigned to a device, such as its iOS Identifier for Advertisers (IDFA), Android/Google Advertising ID (AAID or GAID).
• Information about an end user’s activities on digital properties of our Publishers. Information about the session durations, page impressions, ads viewed or clicked on, domain, URLs, keywords, session start/stop time, geolocation, click data and types of advertisements viewed.
• Bid Request Data (or “bidstream data”), advertising bid request in a specified format, such as oRTB (e.g., adID, DealID, cookie ID, geolocation, website/app, user agent string, device type, carrier name, campaign ID).
• Name, address, contact information, login, passwords and security data, and payment information.
• Unique online identifiers (e.g. IP address, cookies, mobile advertising identifiers such as Apple IDFA and Android Advertising ID)
• Ad reporting or delivery data (e.g. size/type of ad, ad impressions, location/format of ad, data about interactions with the ad)
• Interest segments (i.e. inferred information on the behavior or likely interests associated with you)
• Retargeting data (i.e. data indicating previous interest in a product or website)
• Information that may be anonymized or pseudonymized includes, but is not limited to, clickstream data, search history, analytics, hardware/software type, page views, serving domains, internet service provider, and demographic information.

Children

OpsCo does not knowingly pass to other entities information about individuals under the age of 15, or engage in activities that require parental notice or consent under the United States' Children's Online Privacy Protection Act (COPPA). If you believe that OpsCo has inadvertently collected information from a person under the age of 15, please contact us at privacy@ops.co.

4.0 DATA SHARING CHOICES

You can opt-out of some data sharing.
We believe you should be aware of the choices you have with respect to the collection, sharing and use of your data.
Global Privacy Control

You might have noticed “Do Not Sell” and “Object To Processing” links around the web from companies complying with privacy regulations. Rather than having to click on each of these links individually across many websites, you can exercise your rights in one step via the Global Privacy Control signal.
Click here to learn more and download the Global Privacy Control privacy tool
Do Not Track

The DNT header is a universal signal that you can use to opt out of the tracking and targeting associated with audience segmentation in digital advertising. This opt-out mechanism does not rely on the opt-out cookie; rather, it relies on a privacy setting within your web browser. The location of the DNT setting varies between web browsers. For example, Mozilla Firefox users can access the DNT setting through the Firefox › Preferences menu (the Privacy tab).
Click here to learn more about Do Not Track

Opt-outs

You can opt out of interest-based advertising (by participating companies) by visiting the following links:

• Network Advertising Initiative (NAI)
• Digital Advertising Alliance (DAA)
• Digital Advertising Alliance Canada (DAAC)
• Digital Advertising Alliance EU (EDAA)
• DAA AppChoices page

Turning off location tracking or personalized ads on devices:
If you want to make your location private, you can turn the geo-location feature off within the location settings of your device. In addition to this, you can disable ad tracking on your device. The following instructions explain how to turn off ad tracking for Apple and Android devices (these may change with device updates):

Location

• iOS 7 or higher: Choose Settings › Privacy › Location Services › Turn off “Location Services” to disable location tracking for all apps or choose settings app by app
• Android: Choose Google Settings › Apps › App Permissions › Location › Turn off "Use Location" to disable location tracking for all apps or choose setting app by app

Personalized Ads

• iOS 7 or higher: Choose Settings › Privacy › Apple Advertising › Turn off "Personalized Ads"
• Android: Choose Settings › Google › Ads › Turn on "Opt Out of Ads Personalization"'

5.0 HOW WE KEEP YOUR DATA SAFE

We use appropriate safeguards to protect your data.
OpsCo takes appropriate security measures to prevent unauthorized access, disclosure, modification, and unauthorized destruction of personal information. Some data may be accessible to individuals, with access authorization, involved in OpsCo’s operations, including administration, marketing, sales, legal, and system administration, or to external parties such as third-party technical service providers, hosting providers, IT companies, developers and accounting/financial firms.

Below are links to the security policies and protocols of companies that we use for administrative and technology purposes.

General Administrative:  Google Enterprise
Advertising Technology:  Google Ad Manager
Data Reporting Partner:  STAQ

OpsCo's Demand Partners and Publishers have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. Data Retention

We do not retain any personal information and we do not process your data any longer than we have a legitimate business need or business purpose to do so.

6.0 OTHER IMPORTANT INFORMATION

We'll make it clear when we update our policies.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. We encourage you to review this privacy notice in full and to check back in periodically to be informed of how we are processing and protecting your information.

6.1 Contact Us

Have an issue? Let us know and we'll do our best to fix it. Our Data Protection Officer is James Byrd. He can be reached at privacy@ops.co or by mail at: