Last Updated: June 12, 2017

Cookie Trust Working Group, Inc. dba DigiTrust (“DigiTrust”) is a non-profit, industry-wide collaboration of companies building technology solutions designed to improve the digital experience for consumer, publishers, advertisers and third-parties. DigiTrust provides an identifier used by participating companies for advertising purposes (“DigiTrust Technology”).

This Privacy Policy explains how DigiTrust may collect, use, and share data with respect to the DigiTrust Technology. This privacy policy also governs the collection, use, and sharing of data related to our website (http://www.digitru.st).

DigiTrust Technology
When you visit a website that uses DigiTrust Technology, our technology generates a proprietary identifier for your device (the “DigiTrust ID”). The DigiTrust ID is stored on your browser in the form of either a third party or first party “cookie,” which is a small text file that includes the DigiTrust ID. For more information about cookies, please visit http://www.allaboutcookies.org. Participating companies use the DigiTrust ID for advertising and other purposes, and these companies maintain their own privacy policies and processes. We are not responsible for the privacy practices of companies that use our technology.

Information Collection
DigiTrust Collection. When you visit the DigiTrust website, we may collect information about your visit and use of the website. This User Information may include the type of device or browser you use to visit our website, how you use our website, the web pages you visit, and the IP address of the device you used to access our website. Additionally, if you register with us, or request more information, we may collect your name, email address, company name, and other similar contact information (collectively, “User Information”). Through the DigiTrust Technology, we may collect limited information about the websites you visit where our technology is integrated, in order to operate the service. This information will include your DigiTrust ID, the participating company ID, the domain/URL, your user agent, timestamp, etc. DigiTrust does not use this information for interest-based advertising (“IBA”) purposes or transfer such data to other parties for IBA purposes.

Companies using DigiTrust Technology. Companies who use the DigiTrust Technology may use the DigiTrust ID to engage in their IBA, analytics, identifier syncing, and other advertising related processes. IBA is advertising that involves the collection of web viewing data across non-affiliated websites over time. This data is used to infer interests and deliver advertising relevant to those inferred interests. These companies may also use their own cookies or other similar technologies within their advertisements or on certain websites. Note that these companies maintain their own privacy policies and processes. We are not responsible for the privacy practices of companies that use our technology.

Use of Information
DigiTrust Use. We may use User Information to contact you, including regarding use of the DigiTrust Technology. We also may use this information to generate analytics about usage of our website, to allow us to operate and improve our site, perform research, identify potential security issues related to our website, to prepare reports that summarize visitor activity, and for any other purpose specified at the time of collection. We will not use this information for IBA purposes. We may use data collected through the DigiTrust Technology. We keep this information for a maximum of 7 days for operational purposes — to ascertain appropriate company deployments, identify bugs or malicious behavior, and improve our services. After 7 days, all DigiTrust IDs are removed from the data and the remaining data is aggregated for operational and reporting purposes.

Companies using DigiTrust Technology. DigiTrust generates the DigiTrust ID for the purpose of providing it to participating companies. Such companies may use the DigiTrust ID for a number of purposes, including to provide you with IBA (providing advertising relevant to inferences derived from web viewing data collected across non-affiliated websites over time), identifier syncing, and to generate analytics. For more information about how IBA works, you can visit the Digital Advertising Alliance (“DAA”) at www.youradchoices.com to learn more.

Sharing of Information
We make the DigiTrust ID available to participating companies for advertising purposes. Such companies include advertisers, advertising agencies, ad networks, website and app publishers, and other advertising related companies.

We may share User Information for a variety of reasons. For example:
• We may share User Information for legal, protection, security, and safety purposes, including: to comply with laws or regulatory requirements and to respond to lawful requests and legal process; to protect the rights and property of DigiTrust, our agents, participating companies, and others, including enforcing our agreements, policies, and terms of use and protecting our network and physical assets; and/or in an emergency, including protecting the safety of our employees and agents, our customers, or any person.
• We may share User Information with parties who may use that information to provide us with services or do work for us, such as bookkeeping.
• We may share User Information as part of a transfer of ownership of DigiTrust, including at bankruptcy.
• We may share User Information to conduct research and analytics, operate and improve our website, and for any other purpose specified at the time of collection.

Your Choices
You may make choices about the use of DigiTrust Technology to generate and transmit the DigiTrust ID via the WebChoices tool administered by the DAA located at http://www.aboutads.info/choices. Through this tool, you may opt out directly from DigiTrust.

If you exercise choice, the next time you visit a website using DigiTrust technology, DigiTrust participating companies will no longer receive your previous DigiTrust ID. Please note that when you make a choice, we place a cookie on your device that is unique to the browser from which your choice is made. If you change browsers or devices, or delete the cookies on your computer, you will need to make choices again on that browser or device. If you elect to opt out, you may still receive ads, but those ads may be less relevant to your interests. In addition, we may still collect information for other purposes, including analytics. Companies using the DigiTrust ID may also use their own cookies or other similar technologies within their advertisements or on certain websites. Opting out from DigiTrust does not apply to participating companies’ use of their own cookies or technology for IBA or other purposes. You can visit www.aboutads.info/choices to make choices regarding companies that participate in the DAA WebChoices tool. DigiTrust adheres to the DAA Self-Regulatory Principles.

EU-U.S. Privacy Shield
DigiTrust complies with the EU-U.S. Privacy Shield Framework as set for by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union or European Economic Area to the United States. To learn more, please view our EU-U.S. Privacy Shield Policy at http://www.digitru.st/privacy-shield-statement/.

Children
DigiTrust does not knowingly collect personal information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided personal information to DigiTrust, please contact us.

Security
We use reasonable measures to help protect information transmitted over or stored on our systems.

Changes
We may update this privacy policy from time to time. We will provide notice of such changes by posting the revised policy on this website.

Contact Us
For more information about our privacy practices, please contact DigiTrust by e-mail at privacy@digitru.st or by post using the details provided below:

Cookie Trust Working Group, Inc, (dba DigiTrust)
c/o Larson Gross PLLC
Attn: Privacy Officer
2211 Rimland Dr Ste 422
Bellingham, WA 98226