Kargo is committed to transparency concerning its data practices. Our goal is to provide you with clear and meaningful information on the data we collect, use and share and make sure you understand and can exercise your rights concerning your personal data.
As part of its commitment to consumer privacy, Kargo is a member of the Network Advertising Initiative (NAI) and adheres to the NAI Code of Conduct. Kargo also adheres to the Digital Advertising Alliance (DAA) Self-Regulatory Principles. In addition, Kargo has implemented and follows the specifications and policies of the IAB EU Transparency & Consent Framework (TCF) as part of our compliance with EU data protection law. See https://iabeurope.eu/tcf-2-0/ for more information. Kargo’s vendor identification number within the TCF is 972.
2. Introduction to Kargo
Through its Services, Kargo facilitates the buying and selling of digital ads for our business partners, which include advertising partners, brands, advertising agencies, marketing companies, and online publishers (“publisher partners”). The collection, use and sharing of data may enable these partners, using the Services, to conduct interest-based advertising. Interest-based advertising involves showing you ads on the websites you visit that may be of interest to you based on your browsing history. Ads will appear on the websites you visit whether or not the ads are interest-based. Digital publishers of all sizes, from bloggers to international news organizations, rely on advertiser revenue to support their content. Click here to learn more about interest-based advertising.
3. Information We Collect
Our goal is to provide you with relevant, engaging advertising content in a way that respects your right to privacy. As described below, we deliver the Services using device data and browsing history. We do not collect or know your name, address, email, date of birth, phone number, or other personal identifying information unless you choose to provide it to us (e.g., if you contact us with an inquiry).
Through the Services, we collect information that allows us to make inferences about your interests for advertising purposes. This data may constitute personal information or personal data protected by applicable laws. Collecting the types of information described below allows us to work with our business partners to show you interest-based advertisements and to measure the success of those advertisements.
Technical Identifiers We use certain types of technical identifiers to identify your device, including:
● Kargo-developed proprietary identifiers
● Cookies (small text files)
● Mobile advertising identifiers (such as Apple IDFA and Google AAID)
● IP address
● Non-personal data inferred from an IP address or other technical identifier, such as non-precise geo-location data, which may include inferred longitude/latitude.
● Device-related data such as phone-type, browser, operating system, connection type.
Online Behavioral Information We collect information about your online browsing activity to determine what types of activities and products you may be interested in. This includes:
● Websites and content viewed
● Mobile applications used
● Dates and times of visits to partner websites
● Engagement with advertisements (e.g. views, clicks, whether a full video was viewed)
Client and Partner IDs Our clients and business partners sometimes create technical identifiers for their own purposes. We may use information from different sources to associate these identifiers with additional information.
Location Information We may collect and process information about your general location. The information we collect may tell us which country, city or zip code you are in, but it does not tell us your precise location.
De-Identified Information Kargo may use de-identified information to support our interest-based advertising activities. We do not retain any personal information connected with the de-identified information.
You do not have to provide any personal information to Kargo, and if you previously consented to providing the data, you can manage your data choices as set out in Section 8 below.
If you opt-out of providing personal data, you will still see advertising on webpages you visit. Without the use of your data, any advertising delivered on our Services may be less relevant to your interests.
4. How We Collect Information
You can find out more information about cookies at https://www.allaboutcookies.org/
In addition to cookies, we use local web storage on the browser that is used to access our publisher partners’ websites. Local storage, like cookies, is contained on the browser you are using when you see a Kargo advertisement on our publisher partners’ websites. Like cookies, the browser or window type (e.g., private browsing) you utilize on your device may restrict the data that can be stored and the length of time it persists.
5. How We Use the Information We Collect
We may use the information we collect to:
deliver or enable our advertising partners to deliver personalized messages that match your interests, including interest-based advertisements;
understand the interests of our publisher partners’ users;
customize user experiences when they use our advertising partners’ services;
generate and analyze reports and statistics about the performance of advertising campaigns, and improve performance over time, for our business partners and for our own use;
fulfill the purposes described to you at the point of collection or in accordance with your consent.
We may combine or aggregate any of the information we collect through our Services for any of these purposes.
6. Information of EU Area Users
If you are located in the European Union, European Economic Area, Switzerland or the UK (referred to in this policy as the “EU area”), and your information is subject to applicable EU area laws. Kargo’s legal basis for processing your personal data depends upon the specific context in which we collect or use it. For EU area users, Kargo uses the IAB Europe Transparency and Consent Framework (TCF) as one mechanism for establishing our legal basis. The TCF is designed to allow a publisher to present information and choices to users about third-party vendors, like Kargo, that process data based on you accessing the publisher’s content. The TCF will display information about the purposes for which Kargo processes data and allow you to make choices with respect to those purposes. You can change your preferences at any time as set out in Section 8 below.
Kargo may act as a “controller” as defined under applicable law when processing your personal data. We may also act as a “processor” as defined under applicable law to the extent that we process your personal data on behalf of and at the instruction of another party, for example a publisher or an advertiser.
7. How We Share the Information We Collect
We may share information we collect in connection with the provision of our Services for purposes that include but are not limited to the following:
with our advertising partners and technical service providers to enable our advertising partners to deliver personalized messages that match your interests, including interest-based advertisements. These include:
providers of IT-related services (e.g. data storage, hosting, management, or maintenance)
data analytics providers (e.g. measuring which advertisements receive the most views, clicks or sales, or categorizing data into interest groups)
advertising technology companies (e.g. data management platforms, demand side platforms, or ad-servers);
with our affiliates, representatives and advisors around the world who are involved in the provision of the Services and performing and enforcing our contracts and terms of service;
with our business partners, such as web publishers, advertisers or advertising agencies, for the purposes described in this Policy;
as required by law, such as to comply with a subpoena or other legal, regulatory or law enforcement process, or to comply with government reporting obligations;
with affiliates, service providers, advisors, and other third parties to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, or sale of all or a portion of our assets.
For users in the EU area, your information will be stored in the United States, and our affiliates and technical service providers outside the EU area may have access to information in order to assist us in providing our Services. In each case, we have in place safeguards that enable these transfers to happen in a way that ensures that the information is handled in accordance with our instructions and using similar standards to those applicable in the EU area. These safeguards may include standard contractual clauses for data exports as approved by the European Commission or other supervisory authorities. A copy of these documents may be made available if we receive a valid request.
Subsequent to the exit of the United Kingdom (“UK) from the European Union (“EU”), we intend to continue to transfer personal data from the UK to the EU and the European Economic Area (“EEA”). For transfers from the EU or the EEA to the UK, we will rely on the Standard Contractual Clauses. When our services involve the storage and/or processing of personal data involving transfers of personal data out of the EEA or the UK to a jurisdiction that is not the object of an EU“adequacy” decision, then we will also rely on the Standard Contractual Clauses.
In order to operate our business efficiently, we have to store and process transferred personal data in the United States, the UK, the EU and/or any other country where our partners, processors or subprocessors maintain facilities. We will only do so as long as those partners, processors and subprocessors transfer data via a valid legal mechanism such as the European Commission Standard Contractual Clauses which commit them to similar data protection standards as in the EU and the UK.
8. Your Choices About the Information We Collect
You are able to exercise control over the use of information collected by Kargo to serve you interest-based advertisements. These tools are browser-specific, so you should repeat this process for each browser that you use.
You may opt out of or withdraw your consent for our use of information collected for interest-based advertising purposes by using one of the “opt out” procedures described below:
Even if you opt out, you will still see advertising on the web pages you visit. However, such advertising may be less relevant to your interests.
You also may opt out of or withdraw your consent for our use of information collected for interest-based advertising purposes on mobile websites and have an opt-out cookie placed on your device if your device accepts such cookies by visiting either one of the following industry-developed sites and selecting Kargo:
Digital Advertising Alliance Consumer Choice Page: www.aboutads.info/choices.
Network Advertising Initiative Consumer Choice Page: www.networkadvertising.org/choices.
App Opt-Out: You may select a system level advertising preference feature on your device and Kargo will honor this preference to opt out your device from interest-based advertising in apps. On Apple iOS devices, this system level advertising preference may be accessed via Settings – Privacy – Advertising – Limit Ad Tracking. On Android devices, open the Google Settings app from your app drawer or from your operating system’s settings menu, tap Ads, and select “Opt-out of Interest-based ads.”
9. California Privacy Notice
The California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.) applies to the collection, use, and disclosure of “personal information” collected from California residents (as those terms are defined by the CCPA). The CCPA requires us to disclose to California consumers the categories of personal information (as defined in the CCPA) we collect, our business and commercial purposes for collecting, using, or selling such personal information, the categories of sources from which we collect personal information, the categories of personal information we have disclosed or sold for a business or commercial purpose in the preceding 12 months, and the categories third parties with whom we share personal information. We have provided these disclosures in this policy. Kargo will not “sell” (as such term is defined in the CCPA) the personal information we collect without providing a right to opt out. We do use third-party cookies for our advertising purposes.
Subject to certain limitations, the CCPA provides California residents and those with similar rights in their jurisdiction the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete the personal information that we have collected, to opt out of any “sales” (as defined in the CCPA) of their personal data by Kargo, and to not be discriminated against for exercising these rights.
For more information about how to exercise these rights with respect to Kargo and data we process, please refer to our California Privacy Notice.
10. Your EU Area Rights
If you are an EU area user and your information is subject to applicable EU area laws, you have additional rights in relation to information that we process about you. These rights include:
to ask for access to the data
to ask for errors in the data to be corrected
to ask for the data to be erased (the “right to be forgotten”)
if not erased, then to ask us to restrict processing of the data
to object to its processing for specific purposes
to ask for a copy of the data to take to another service provider (“data portability”)
Where we process any information based on consent that you have previously given, you are permitted to withdraw your consent at any time (though the processing that took place before withdrawal will still be legal). You may withdraw consent by (1) managing online choices as set out above; or (2) visiting the websites where you have previously indicated your consent.
As indicated above, Kargo does not process contact or ID information such as names or emails. Therefore, unless you provide us with a relevant technical ID from your device, while we will always investigate any request thoroughly, it may be impossible for us to know whether or not we are processing any information relating to you. In these cases, we normally take the approach that it is more protective for you to use the systems referred to above that enable you to directly manage your online choices and cookie settings, and not to ask you for (and then to process) additional information about you in order to investigate such a request.
We are always available through the contacts in Section 15 below to help resolve any issues or questions in relation to processing of your information. If you believe that your rights have not been respected then you are also entitled to make a complaint to the Supervisory Authority or Personal Data Protection Authority in your country to ask them for a resolution.
11. Users Under 16 Years Old
Kargo does not knowingly collect personal information from users under 16 years old. If you become aware that Kargo may have collected information from a user under 16 through the Services, please contact us (see Section 15) and we will take steps to delete such information.
We strive to maintain reasonable administrative, technical, and physical safeguards designed to safeguard the information we collect from unauthorized access, corruption or loss. In general, information is kept in pseudonymous form (i.e. you cannot be personally identified from it without additional data) and we apply security measures such as password protection and Transport Layer Security technology (TLS). However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information.
13. Information Retention
We retain information collected for interest-based advertising purposes for up to eighteen months from the date of its collection, unless you reset your device or clear your cache or cookies as referred to above.
If we need to keep your information longer than eighteen months for reporting, accounting, regulatory or legal reasons, then we will retain it only for as long as necessary under the applicable laws, policies or agreement and will use the information only for the purpose for which it was retained..
14. Request for Information Disclosures
Reporting period Jan. 1 2020 - Dec. 31 2020
From Jan. 1 2020 - Dec. 31 2020, Kargo Global Inc. received a total of four (4) requests via the contact information listed in section 15. These requests can be categorized as deletion requests or information requests. Two (2) requests can be categorized as deletion. Two (2) requests can be categorized as information. While no specific requests were made to opt out via direct contact, Kargo provides an opt out link on this page and via the NAI as mentioned in section 1. In the cases of all requests in 2020, we issued a response to the data subject within an average of 6 days (median of 5 days). A member of the team responded to these requests either in the context of requesting more information to verify the identity of the data subject, or providing the data subject a link to an online portal where they could view additional information within their browsers which may be utilized by Kargo technologies. In all cases of the requests in 2020, Kargo did not receive a further reply after our initial response from the data subject.
15. Changes to This Policy
We may update this Policy from time to time to address changes in the Services, changes in the laws or regulations, or for other reasons. If we update this Policy, we will notify you by posting a new Policy on this page. If we make a change that materially affects the way in which we use or share the information previously collected from you through our Services, we will not apply that change to information collected prior to the date of the change.
16. Contact Us
If you have any questions about this Policy or our use of your information, please contact us by email at email@example.com, or by mail at Kargo Global, Inc., 826 Broadway, 4th Floor, New York, NY 10003, Attn: Legal. We welcome your questions and feedback.
This Policy was last updated on August 4, 2021.