California Privacy Notice

Last Updated: [03/24/2021]

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.

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.

To find out more about making an access, deletion or opt-out request, visit our page on Your Rights.

California Privacy Notice Pertaining to LiveRamp’s Products & 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:

  1. Our Collection of Personal Information – the types of personal information that we collect, and 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

When we act as a “business” under the CCPA, we may collect the following categories of information about you and use them for a permitted business purpose, as summarized in the table below.

 

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, state identification number, or other similar identifiers (includes categories from CA Civil Code 1798.80)
Offline and online Database providers, consumer data resellers, ad networks, websites and internet connected devices 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 and internet connected devices 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 and commercial purposes as stated above, 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 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 (and their service providers), social networks, consumer data resellers, distribution partners Yes
Internet or electronic network activity information: information regarding a consumer’s interaction with a website, application, or other internet connected device Advertising networks, data analytics providers, media platforms, brands (and their service providers), social networks, consumer data resellers, distribution partners Yes

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

Sharing for Legal Purposes: We may share personal information with third parties in order to: (a) comply in good faith 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. 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 personal information 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. 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 modeled audiences to which our clients can market their products and services. For example, a sports clothing company may be looking for new or 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).
  • For enabling client collaboration on joint audience marketing strategies, analytics, and activation. For example, an airline company wants to understand if there is a relationship between members of its frequent flier club and people who purchase a specific soft drink. The airline company and soft drink supplier can use our services to collaborate on their independently owned datasets. They can use our analytic tools to understand if there is a relationship between frequent flier members and soft drink purchasers. They can then model the resulting audience and use it to reach new customers interested in a frequent flier membership.

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.
  • For enabling clients to process personal information, such as your email (in hashed form) or phone number, into an online advertising identifier to be stored in a first-party cookie to use in online and cross-channel advertising and it may be shared with advertising companies to enable interest-based and targeted advertising. For example, when you log into a website, the site may work with LiveRamp to create an online advertising identifier. The website may then share the identifier with advertising partners, giving them the opportunity to advertise to you on the website. Those advertising partners might also have a similar relationship with LiveRamp to create advertising identifiers and use those to communicate to the website that they do, in fact, want to advertise to you.

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.

Right to Access

As a California resident, you have the right to request that we disclose what categories of personal information we collect, use, disclose or sell about you. That information is described in this California Privacy Notice. You may also request specific pieces of personal information we have collected about you through an access request. You may also make an access request on behalf of your minor child or via an Authorized Agent. To submit an access request, you will have to provide proof of your California residency as well as verify your identity (for security and safety purposes) by providing a copy of your driver’s license, take a selfie, and complete knowledge based verification questions. This information is being gathered to verify your identity and your California residency. This information will only be used for verification purposes. This information will be processed by our third-party ID verification providers and this information will be deleted as soon as practical after processing your request, except as permitted by applicable laws. Additionally, this information will not be used for any other purposes or shared with anyone else. We may withhold some personal information where the risk to you or our business is too great to disclose the information, or as permitted by applicable law. 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, but may return category information, upon request. We will respond to verifiable consumer requests for access not more than twice within a 12-month period, or as required by law.

Make an Access Request here:
As a consumer >
As a parent/guardian >
As an authorized agent >

Learn more about the types of requests and read our FAQ >

Right to Opt Out of the Sale of Personal Information

As a California resident, you have the right to opt-out of the sale of your personal information. We may have sold 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.”

To opt out of the sale of your personal information, you may do so here:

As a consumer >
As a parent/guardian >
As an authorized agent >

Learn more about opt out requests and read our FAQ >

Right to Deletion 

As a California resident, you have the right to request us to delete personal information we have collected from you. Please note that this is different from your right to “opt out” of us selling your personal information, which is described above. To submit a deletion request, you will have to provide proof of your California residency as well as verify your identity (for security and safety purposes). This information will only be used for verification purposes. We will delete this information as soon as practical after processing your request, except as permitted by applicable laws.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 otherwise permitted by applicable laws. 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.

Make an Deletion Request here:
As a consumer >
As a parent/guardian >
As an authorized agent >

Learn more about the types of requests and read our FAQ >

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

As a California resident, you have two methods through which you may exercise your privacy rights: either online or by phone:

  • To submit a request online, visit this link. For more details on your options, please visit our page on Your Rights
  • To contact us by phone please follow the two steps below:
    Step 1: Call (844) 678-0045
    Step 2: Enter the applicable service code:
    Opt-out: 1
    Access: 2
    Category Access: 3
    Deletion: 4
  • If you are experiencing any issues submitting a request online or by phone, or have any questions about your privacy rights not addressed by this notice, please email us at consumercare@liveramp.com.

For security purposes (and as required under California law), we will attempt to 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 access of the 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 include your prefix, suffix, full name, email address, postal address, government issued ID, and a ‘selfie’. You will 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 permitted by applicable laws.

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 within 45 days. If we find that we may need more time to respond to your request, we will inform you within 45 days of when your request was submitted, and the reasons why. If we find that we will not be processing your request as permitted by applicable law, we will inform you within 45 days of the reasons why, as well as information about an appeal process. 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. 

6. Authorized Agent

An Authorized Agent may also make an access, opt-out or deletion request on your behalf. We will take steps to verify your identity as the consumer, your agent’s identity, and proof that your agent has your permission to submit the request. 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.

To submit a request on behalf of a consumer, the Authorized Agent will have to provide a copy of their driver’s license, take a selfie, and complete knowledge based verification questions so that we know the CCPA applies and that you are who you purport yourself to be.

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, or as otherwise permitted by applicable laws.

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. We process such personal information under the direction and instruction of our clients. This may include, for instance, information about our clients’ customers or prospective customers, or about other consumers our clients have interacted with. To learn more about their privacy practices and to exercise your rights with respect to that information, you will have to visit their website and review their privacy notice.

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:

Email: consumercare@liveramp.com

Phone: To contact us by phone please follow the two steps below:

Step 1: Call (844) 678-004

Step 2: Enter the applicable service code:
Opt-out: 1
Access: 2
Category Access: 3
Deletion: 4

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. Consumer rights to make requests under the CCPA generally do not apply in a business-to-business context, 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: 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: liveramp.com/cookies-101.

5. Contact for More Information

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