California Privacy Notice

Last Updated: [12/18/2019]

The information provided in this “California Privacy Notice” only applies to California residents as defined in the California Consumer Privacy Act of 2018 (CCPA). The notices below describe LiveRamp’s collection, use, disclosure, and sale of your personal information, as well as your rights with respect to that personal information. This California Privacy Notice is effective as of January 1, 2020. 

For the California Privacy Notice that pertains to and supplements LiveRamp’s Services Privacy Policy, please click here.

For the California Privacy Notice that pertains to and supplements LiveRamp’s Website Privacy Policy, please click here.

 

California Privacy Notice Pertaining to LiveRamp’s Services

This Notice for California Residents supplements the information contained in LiveRamp’s Services Privacy Policy and applies solely to California residents as defined in the California Consumer Privacy Act of 2018 (CCPA). 

In the below tables and sections, we describe (as required by the CCPA):

  1. Our Collection of Personal Information – the types of personal information (which the CCPA defines broadly) that we collect, the types of sources we collect it from.
  2. Our Disclosure and Sale of Personal Information – the types of recipients to whom we disclose or sell personal information.
  3. Our Business Purposes – our business purposes for (a) collecting and (b) sharing personal information, which are generally the same.
  4. Your California Privacy Rights and Choices – what rights you have under the CCPA, for instance, to request that we do not sell your personal information.
  5. Exercising Your Rights – how to exercise your right to opt out of sale, right to request access, and right to request deletion.
  6. Authorized Agent – how to designate an authorized agent to make requests, on your behalf, to exercise your rights under CCPA. 
  7. When We Act as a Service Provider – how your rights may differ in regards to the personal information we process as a service provider.
  8. Contact – how you may contact us.

The following sets forth the categories of information we collect and purposes for which we may use California residents’ personal information:

1. Personal Information We Collect

LiveRamp collects certain categories of personal information in connection with our Connectivity Offerings. Personal information is broadly defined under California law as information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. 

LiveRamp may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.

Category Categories of Sources  Purpose for Collecting (Please refer to Section 3 for more detail)
Identifiers: real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, or other similar identifiers  Offline and Online Database providers, consumer data resellers, ad networks, websites Data marketing,

Online targeting and measurement,

Operating (and marketing) our Services,

Other operational purposes

Categories from CA Civil Code 1798.80: name, social security number, address, telephone number, driver’s license or state identification card number Offline Database providers, consumer data resellers Data marketing,

Online targeting and measurement,

Operating (and marketing) our Services,

Other operational purposes

Internet or electronic network activity information: information regarding a consumer’s interaction with a website, application, or ad Online Database providers, consumer data resellers, ad networks, websites Data marketing,

Online targeting and measurement,

Operating (and marketing) our Services,

Other operational purposes

Geolocation data Online Database providers Data marketing,

Online targeting and measurement,

Operating (and marketing) our Services,

Other operational purposes

Professional or employment-related information Offline Database providers Data marketing,

Online targeting and measurement,

Operating (and marketing) our Services,

Other operational purposes

2. Disclosure and Sale of Personal Information

We will share the information collected about you as discussed above for various business purposes, with service providers and with third parties, including our customers. The chart below describes how and with whom we share or disclose personal information, and whether (based on the CCPA’s broad definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.

Category Categories of Third Parties We Share With  Whether We “Sold” This Category of Personal Information in the Last 12 Months
Identifiers: unique personal identifier, online identifier, IP address, email address, or other similar identifiers  Advertising networks, data analytics providers, media platforms, brands, social networks, consumer data resellers, distribution partners Yes
Internet or electronic network activity information: information regarding a consumer’s interaction with a website, application Advertising networks, data analytics providers, media platforms, brands, social networks, consumer data resellers, distribution partners Yes

We also may share any of the personal information we collect as follows: 

Sharing for Legal Purposes: In addition, we may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes. 

Sharing In Event of a Corporate Transaction: We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction. 

Sharing With Service Providers: We may share personal information with our service providers who process it on our behalf and in accordance with our instructions. Service providers are contractually prohibited from using the personal information for purposes outside of our instruction. This may include, for instance, providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.

3. Our Business Purposes for Collecting and Sharing Personal Information

Generally speaking, we collect and share the Personal Information that we collect to recognize consumers across different channels and platforms over time for the purposes of facilitating online advertising, analytics, attribution, fraud detection, and reporting. This includes:

Data marketing, for example:

  • Generally, creating data marketing tools and products for our clients, as more fully described in our Privacy Policy (and on our websites). This includes our provision of datasets, data “appends” (connecting data across datasets), and data hygiene services (helping customers to evaluate, validate and correct personal information they hold).
  • Assisting our clients through our Services to provide their current and prospective customers with better service, improved offerings, and special promotions, for instance, advising on which current or prospective customers are most likely to be interested (or disinterested) in certain offers.
  • For creating modelled audiences to which our clients can market their products and services. For example, a sports clothing company is looking for new potential customers who are likely to be interested in sports clothing. The sports clothing company can use our services and products to look for key characteristics between consumers with similar characteristics that have shown an interest by their online activities in shopping for sports clothing and other consumers with some of the same similar characteristics. A similar interest can be inferred or anticipated based on these similar characteristics, such as from browsing for sports shoes.
  • For enabling our clients to associate information they have collected about you with certain identifiers or data made available as part of our products and services to facilitate the delivery of our clients’ marketing and advertisements to you. For example, a sports clothing company has its own lists of names, emails, and/or addresses of customers who have previously purchased sports clothing from them. The sports clothing company wants to reach out to these customers with online advertising for a discount offer on online purchases. The sports clothing company can use our products and services to convert the company’s lists from directly identifiable information (e.g. names, emails, and/or addresses) to non-directly identifiable information (e.g. cookie and device IDs).
Online targeting and measurement, for example: 

  • For enabling our clients and partners to connect your online behavioral preferences across the various browsers and/or devices you use to more accurately market to you. For example, you are logged into multiple devices (such as your desktop, your smartphone, and your tablet) using the same login and have clicked on a sports clothing company’s online advertisement on at least one of those devices. Where we determine that you are most likely the same user logged in on those different devices, we will communicate that information to the partner. The sports clothing company can thus display more consistent offers to you via automated technologies (such as a non-directly identifiable cookie ID) on your different devices.
  • For online interest-based advertising displayed to you by our Distribution Partners at the direction of our clients. For example, if you have visited a clothing-related website and browsed through or purchased sports clothing, you may then see advertisements for sports clothing on other websites. This is due to a cookie being placed on your device that has associated you with the advertiser’s audience of consumers interested in sports clothing, which is then used by the advertiser through our services and products.
  • For use in the measurement and performance of analytics of the effectiveness of our clients’ advertising campaigns. For example, a sports clothing company wants to better understand if its website advertisements for a new line of sports clothing contributed to an increase in sales. Our services and products can be used by the advertiser to see how many ads were viewed and actually clicked on, and if the consumer purchased any of the advertiser’s sports clothing.
  • For enabling our clients and partners to personalize their products and services to you, such as through website and email personalization or dynamic marketing and advertising optimization. For example, if you have previously indicated an interest in sports clothing and then visit a sports clothing company’s website, that company can display offers for sports clothing tailored for you on their website.
Operating (and marketing) our Services, for example: 

  • Improving, testing, updating and verifying our own database.
  • Developing new products.
  • Operating, analyzing, improving, and securing our Services.
  • We also may use email addresses and other personal information we receive in our corporate capacity to communicate with or market to organizations that we believe may benefit from our Services.
Other operational purposes, for example:

  • Auditing
  • Detecting security incidents
  • Debugging
  • Short-term and transient use
  • Performing services 
  • Internal research
  • Quality control
  • Legal compliance

4. Your California Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. You may only make a verifiable consumer request for access or deletion twice within a 12-month period. 

Right to Access

California residents have the right to request that we disclose what categories of personal information we collect, use, disclose or sell. You may also request the specific pieces of personal information that we have collected about you. If we are able to verify your identity and provide back personal information as requested, we may withhold some personal information where the risk to you or our business is too great to disclose the information. If we are unable to verify your identity, we will inform you that we cannot verify your identity and we will not disclose any specific pieces of personal information to you. 

Right to Opt Out of the Sale of Personal Information

California residents may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” – including making available a wide variety of information in exchange for “valuable consideration,” which is not limited to “monetary consideration.”

Depending on what information we have about you, and whether we have included any of it in our products and services, we may have sold (as defined by California law) certain categories of information about you in the last 12 months, as described in the above table in “Our Disclosure and Sale of Personal Information.”

If you would like to opt out of the sale of your personal information, you may do so as outlined on the following page: Do Not Sell My Personal Information

Right to Deletion 

California residents have the right to request LiveRamp to delete personal information we have collected from you and retained. Please note that this is different from your right to “opt out” of us selling your personal information, which is described above. Also note that we do not generally collect personal information directly from consumers.

Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or (g) to comply with legal obligations.

Right to Non-Discrimination for Exercise of Your Consumer Rights

You have the right not to receive discriminatory treatment by LiveRamp for the exercise of your privacy rights under CCPA.

5. Exercising Your Rights

California residents may exercise their California privacy rights by:

  • Submitting a request via your-rights.liveramp.com
  • Contacting us at 866-467-8688 and entering the following service codes:
    • Access: 320
    • Opt-Out of Sale: 321
    • Deletion: 322

For security purposes (and as required under California law), we will verify your identity – in part by requesting certain information from you – when you request to exercise your right to access or deletion. For instance, if you request categories or specific pieces of personal information we have received about you, you will need to provide certain identifiers to verify your California residency and verify your identity. These identifiers may include your prefix, suffix, full name, email address, phone number, postal address, government issued ID, and a ‘selfie’ holding your license. You may also need to go through challenge questions for knowledge-based authentication. This information will only be used for verification purposes. We will delete this information as soon as practical after processing your request, except as required to comply with CCPA.

We may need to contact you in order to clarify your request, confirm your identity, or collect more information in order to verify and respond to your request.

Once we have verified your identity, we will respond to your request as appropriate:

  • Where you have requested the categories of personal information that we have collected about you, we will provide a list of those categories.
  • Where you have requested specific pieces of personal information, we will provide the information you have requested, to the extent required under the CCPA and provided we do not believe there is an overriding privacy or security concern to doing so.
  • Where you have requested that we delete personal information that we have collected from you, we will seek to confirm whether your request is for an “opt out of sale” or a “deletion”. This is because “opt out of sale” rights enable us to maintain your information for “suppression” purposes – i.e., to prevent us from selling information about you in the future. This is what many consumers requesting “deletion” actually desire to occur. We explain this in order to ensure we are meeting consumers’ preferences. In addition, “deletion” rights only apply to information that we have collected “from” consumers – which does not apply to much of the information in our databases. 
  • Upon completion of the above process, we will send you a notice that explains the categories of personal information we were able to locate about you, and whether we (1) deleted, (2) de-identified, or (3) retained the information we collected from you. Certain information may be exempt from such requests under applicable law. 

If we are unable to complete your requests fully for any of the reasons above, we will provide you with additional information about the reasons that we could not comply with your request.

6. Authorized Agent

You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps to verify your identity (as the consumer), your agent’s identity, and that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney. We cannot provide you or your agent with personal information if we cannot verify your identity (as the consumer), your agent’s identity, or your agent’s authority to make the request and confirm the personal information relates to you.

Either you or an authorized agent (i.e. a person registered with the California Secretary of State that you authorize to act on your behalf) may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or deletion twice within a 12-month period.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request for verification and record-keeping purposes, as required under the CCPA.

7. When We Act as a Service Provider

We may receive, handle and process personal information on behalf of our clients, in order to provide services to those clients. This may include, for instance, information about our clients’ customers or prospective customers, or about other consumers our clients have interacted with. Under the CCPA, this is information we access as a “service provider” and thus is not subject to the processes described in “Your California Rights and Choices.” To exercise your rights with respect to that information, you must contact whichever company or organization is the “business” that holds it. 

8. Contact for More Information

If you have any questions or comments about LiveRamp’s privacy policies and practices or your choices and rights regarding such use, please do not hesitate to contact us at:

Website: your-rights.liveramp.com

Email: consumercare@liveramp.com

Phone: 866-467-8688 and enter the following service codes:

  • Access – 320
  • Opt-Out of Sale – 321
  • Deletion – 322

Postal Address: 225 Bush Street, 17th Floor, San Francisco, CA. 94104.

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California Privacy Notice Pertaining to LiveRamp’s Website(s)

This Notice for California Residents supplements the information contained in LiveRamp’s Website Privacy Policy and applies solely to California consumers as defined in the California Consumer Privacy Act of 2018 (CCPA). 

In the below tables and sections, we describe (as required by the CCPA):

  1. Our Collection of Personal Information – the types of personal information (which the CCPA defines broadly) that we collect, the types of sources we collect it from.
  2. Our Disclosure and Sale of Personal Information – the types of recipients to whom we disclose or sell personal information.
  3. Our Business Purposes – our business purposes for (a) collecting and (b) sharing personal information, which are generally the same.
  4. Your California Privacy Rights and Choices – what rights you have under the CCPA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights).
  5. Contact – how you may contact us.

The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information:

1. Personal Information We Collect

LiveRamp collects certain categories of personal information in connection with websites we own. Personal information is broadly defined as information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. 

LiveRamp may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.

Category Categories of Sources Purpose for Collecting
(Please refer to Section 3 for more detail)
Identifiers: real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, or other similar identifiers  Directly from Customer, Directly from Consumer, Inquiries About Products or Services, LiveRamp website(s), Marketing Partners, and Sponsors Operating our Website(s), To market our products and services to you, Other operational purposes
Categories from CA Civil Code 1798.80: name, address, telephone number, employment, credit card number, debit card number, or any other financial information Directly from Customer, Directly from Consumer, Inquiries About Products or Services, LiveRamp website(s), Marketing Partners, and Sponsors To market our products and services to you, Other operational purposes
Commercial information: products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies Directly from Customer, Inquiries About Products or Services, LiveRamp website(s) To market our products and services to you, Other operational purposes
Internet or electronic network activity information: information regarding a consumer’s interaction with a website LiveRamp website(s), Marketing Partners, and Sponsors

 

Operating our Website(s), To market our products and services to you, Other operational purposes
Professional or employment-related information Directly from Customer, Marketing Partners, and Sponsors To market our products and services to you, Other operational purposes
Inferences drawn from any information above to create a profile about a consumer reflecting consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes LiveRamp website(s), and Marketing Partners To market our products and services to you, Other operational purposes

2. Disclosure and Sale of Personal Information

We will share or disclose the information collected about you as discussed above for various business and commercial purposes, with service providers and with third parties, including our customers. The chart below describes how and with whom we share or disclose personal information, and whether (based on the CCPA’s broad definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.

Category Categories of Third Parties We Share With  Whether We “Sold” This Category of Personal Information in the Last 12 Months
Identifiers: real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, or other similar identifiers  Marketing Partners, Sponsors, Insurers  Yes 
Categories from CA Civil Code 1798.80: name, address, telephone number, employment, credit card number, debit card number, or any other financial information Marketing Partners, Sponsors, Insurers Yes (except for credit card number, debit card number, or any other financial information)
Professional or employment-related information Marketing Partners, Sponsors, Insurers Yes

We generally do not ‘sell’ the personal information we collect from you from your interaction with our website(s). However, given the broad definition of ‘sale’, our sharing of your personal information with our sponsors may be considered a sale under CCPA. For example, when you provide personal information to us to access sponsored content (e.g. white paper), we may share your name, email, and professional or employment-related information with our sponsor. You can opt out of this sharing within Section 4: Your Rights and Choices below.

We also may share any of the personal information we collect as follows: 

Sharing for Legal Purposes: In addition, we may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes. 

Sharing In Event of a Corporate Transaction: We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction. 

Sharing With Service Providers: We may share personal information with our service providers to help deliver services accessed through our website(s) and to deliver content and fulfill requests made on our website(s). Service providers are contractually prohibited from using the personal information for purposes outside of providing specific services to us.

3. Our Business Purposes for Collecting and Sharing Personal Information

Generally, we collect and share the Personal Information that we collect from our website(s) for the following purposes:

Operating our Website(s), for example:

  • To track your use of our websites and tailor your web experience.
  • To monitor and improve our website and services.
To market our products and services to you, for example:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and business contact information to inquire about our products or services, we will use that personal information to respond to your inquiry. We may also share this personal information with our marketing partners (i.e. lead generation).
  • To register for and/or allow you to subscribe to our special offers, demonstrations of our products and services, or seminars and events, such as LiveRamp’s annual RampUp conference.
  • To sign you up to participate in surveys or even contests that we might provide.
  • To allow you to download different papers and/or articles that we write, produce, or otherwise make available.
  • To actually provide you with access to our “Software as a Service” products, such as our Connect platform.
Other operational purposes, for example:

  • Auditing
  • Detecting security incidents
  • Debugging
  • Short-term and transient use
  • Performing services 
  • Internal research
  • Quality control
  • Legal compliance

4. Your Rights and Choices

While the CCPA provides California consumers with specific rights regarding their personal information, including the right to opt out of sale, the right to access and the right to deletion, the personal information we collect, use, and disclose from your interaction with our websites is largely used for business-to-business purposes. For example, when you are acting as a representative of your company and inquiring about our products or services.

You can manage your email marketing preferences with us by clicking here: https://lp.liveramp.com/subscription-management.html. This will opt you out of LiveRamp and RampUp Sponsor email marketing. 

If you would like to learn more about cookies and opt out of cookie placement, you can learn more here: https://liveramp.com/cookies-101/.

5. Contact for More Information

If you have additional questions about LiveRamp Marketing, please email info@liveramp.com.