Revised: November 6, 2018
LiveRamp provides Connectivity Services designed to enable our clients to reach consumers with greater efficiency and more relevant messages across various digital channels, including online, mobile, email, and addressable TV.
General Data Protection Regulation (GDPR)
The European Union has promulgated a new privacy and security framework called the General Data Protection Regulation (“GDPR”). It imposes a number of obligations on data controllers and data processors and affords data subjects a number of important rights. This document is intended to provide transparency regarding LiveRamp operations in the United States (“LiveRamp”) as required under Articles 13 and 14 of the GDPR.
LiveRamp acts as both a “Data Controller” and a “Data Processor” under the GDPR. LiveRamp acts as a data controller with respect to personal data about its employees in the EU (i.e., human resource data), personal data it collects from its clients and prospective clients (i.e., its own customer relationship management data), and personal data about EU citizens it licenses from others (i.e., EU personal data LiveRamp licenses to its clients).
LiveRamp acts as a data processor under GDPR to the extent it processes personal data about EU citizens on behalf of its clients. In this instance, our clients are considered data controllers. LiveRamp processes the personal data according to contract and written instructions from the data controller.
This service privacy notice focuses on the personal data that LiveRamp collects and processes that is used for services. Employees of LiveRamp subsidiaries in the European Union should refer to their employee handbook for information regarding LiveRamp’s privacy policies.
LiveRamp complies with the EU-U.S. Privacy Shield Principles and Swiss-U.S. Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about how we collect, use, and retain your personal information when you use our Services in the European Union or member countries, please read our Privacy Shield Policy.
LiveRamp connectivity services
The LiveRamp Connectivity Services include data onboarding, linking, and distribution to many of the players in the digital advertising industry to enable smarter targeting with more relevant messages and more accurate measurement. Onboarding is a service that loads data collected offline into the digital ecosystem, so it can be used for digital advertising purposes. The players include advertisers wishing to reach consumers, advertising supported websites, advertising supported apps, email marketing services, and addressable TV channels.
Today consumers interact with advertisers and brands through a variety of channels – offline and digital. This cross channel interaction is known as “omni channel.” LiveRamp services are used to support these interactions for several types of entities in the digital advertising industry, including:
Marketing Platform Partners: LiveRamp has established partnerships for distribution with hundreds of media and technology providers in the online, app, email, and addressable TV ecosystem. With these partners, LiveRamp enables advertisers to display relevant ads to specific individuals through websites, mobile apps, email, and addressable TVs.
Third Party Data Providers: LiveRamp also offers services that allow third-party data providers, to onboard their offline marketing data and sync their digital data in such a way that it can be used by advertisers to display more relevant ads and email marketing to consumers.
Brands: LiveRamp offers connectivity services to digital marketers that advertise to consumers:
* Brands can onboard their proprietary offline and digital data for their own use to target advertising messages on their own website and/or their own mobile apps, and in email.
* Brands can use their own onboarded proprietary data along with third party onboarded data to offer more relevant ads and email marketing through LiveRamp partners.
* Brands can also connect performance information about their omni-channel ad and email marketing campaigns to understand how to improve the effectiveness of future campaigns. Performance information includes data about who viewed the ad, who clicked on the ad, as well as who actually responded in some way to the offer.
Other Digital Partners:
There are other players in the digital advertising industry that LiveRamp partners with to enable our Connectivity Services. These include cookie, mobile and addressable TV match partners that allow LiveRamp to recognize an individual across various channels. In addition, LiveRamp sells Connectivity Services to other third party advertising service providers to help facilitate their offerings.
Connectivity services work across channels
Due to technical differences across the channels, LiveRamp uses different approaches tailored specifically to each channel to provide our Connectivity Services. The common basis of these services is an ID that LiveRamp assigns to an individual. The ID may be used in a personally identifiable state or in a manner that is not used to identify the individual, depending on the channel and the use.
LiveRamp collects certain types of information in connection with our Connectivity Services. This includes personal data such as name, postal address, email address, and phone number if permitted by our partners and clients through policy notices they have provided to consumers. We also collect other data such as IP address, mobile device ID, and browser and operating system type and version. In addition, we handle, process, and share this data with our marketing platform partners in the course of performing our services; however we do not retain or use this data for our own internal business purposes unless permitted by our clients.
LiveRamp Cookie-based Connectivity Services
Connectivity Services for cookie-based integrations are based on a LiveRamp ID and a LiveRamp cookie that together identify a browser. The cookie containing the ID is set when a consumer visits the website of one of our cookie match partners as a registered user, or when a consumer opens certain emails from a cookie match partner. Because match partners know the consumer, they enable LiveRamp to recognize the consumer as well and set the LiveRamp cookie containing the appropriate ID.
For example, our match partners may enable us to place or recognize a cookie on your computer or device, and our match partners may share personal data with us, such as your name, postal address, or email address. LiveRamp uses the personal data to link an ID to information stored in your browser or device. We also may collect information such as the device’s IP address and browser or operating systems type and version. We use this information to recognize consumers across different channels and platforms over time for the purposes of facilitating online advertising, analytics, attribution, fraud detection, and reporting purposes.
For cookie-based integrations, three types of connections are maintained. The first is the connection between LiveRamp cookies and marketing platform partner cookies, a sync that enables LiveRamp to distribute advertising data to partners on behalf of our clients. In this case, the LiveRamp cookies containing LiveRamp IDs are synced with cookies set by our marketing platform partners.
The second connection is between LiveRamp cookies and third-party data providers. In this case, third party data providers onboard their data and LiveRamp matches it to the appropriate LiveRamp IDs, thereby connecting the data to the correct LiveRamp cookie.
Finally, the third connection is between a brand’s data and the LiveRamp cookie. When marketers onboard their data, LiveRamp associates the brand’s data with the LiveRamp ID, thus connecting this data to the LiveRamp cookies.
Once all these connections are made, a marketer can use them to understand how ad or email marketing campaigns perform and deliver ads or offline marketing to specific individuals when they visit a website with ad inventory. For example, we may facilitate the delivery of an ad to an individual in his or her web browser based on a purchase he or she made in a physical retail store, or we may enable a brand to send a personalized marketing email to that individual based on the fact that he or she visited a particular website.
LiveRamp cookies are set with an RLCDN.com name and expire from LiveRamp’s system after 90 days unless they are renewed or refreshed. Unlike web “tracking” cookies, LiveRamp cookies do not “track” users’ behavior across websites. Instead, LiveRamp cookies are used to recognize an individual so that relevant ads and email marketing can be delivered to the intended recipient.
LiveRamp Mobile Connectivity Services
Connectivity Services for mobile ID integrations are similar to cookie integrations except they use the mobile advertising ID assigned to the device instead of a cookie – namely the Apple ID for Advertising (IDFA) and the Android Advertising ID (AAID). We associate the LiveRamp ID with the mobile ID just like we would associate the cookie. LiveRamp links marketing platform partners, third party data providers, and data from a brand to mobile devices through the LiveRamp ID.
Mobile advertising IDs do not expire like cookies. Instead the device gives the user the ability to change the ID at any time, thus breaking the connection between the old ID and the device. Consistent with our online policy, LiveRamp IDs are used to recognize individuals so relevant ads and offline marketing can be delivered and campaigns can be measured.
LiveRamp Addressable TV Connectivity Services:
Connectivity Services for addressable TV integrations are similar to online and mobile services except they use the subscriber ID assigned by the carrier to the set-top box instead of a cookie or a mobile ID. We associate the LiveRamp ID with the subscriber ID just like we would associate the cookie or mobile ID. LiveRamp links marketing platform partners, third party data providers, and data from a brand to subscriber IDs through the LiveRamp ID.
Addressable TV subscriber IDs do not expire like cookies. Instead the carrier gives the user the ability to determine if they wish to see targeted advertising on their TV. Consistent with our online and mobile policy, LiveRamp IDs are used only to recognize individuals so relevant ads can be delivered and campaigns can be measured.
Personal Data versus Anonymous Connectivity:
LiveRamp may recognize an online, mobile or addressable TV user in two ways. First when our match partner shares personal data with us, or second when they share other information with us that is not used to identify individuals. When they share personal data, we can recognize a consumer on an identifiable basis. However, to preserve user privacy, we create a unique LiveRamp ID when we combine it with other anonymous data.
LiveRamp values the preservation of consumer privacy, designing its systems and services to treat personal data and other information that is not used to identify individuals with utmost care. LiveRamp chooses the appropriate LiveRamp ID, either personal data or de-identified, based on the services it has been asked to perform; it does not mingle the two in any way that compromises user protections or choice.
Legal Basis of Processing
In terms of how we work with our partners and clients under GDPR, our processing of personal data will be legitimized as follows:
(i) Whenever we require consent for the processing of personal data such processing will be justified pursuant to Article 6(1) lit. (a) of GDPR. This article in the GDPR describes when processing can be done lawfully;
(ii) And where the processing is necessary for the purpose of LiveRamp’s legitimate interest, such processing will be made in accordance with GDPR Article 6(1) lit. (f).
The data we hold is non-sensitive personal data and not subject to any sector specific data retention requirements. We retain data collected for our data products for as long as it is useful in our products, either as an actual variable or in order to derive other variables. Personal data not used for any purpose is deleted. If someone objects to us processing their data, we will remove it from our data products, and then from our environment in accordance with our data deletion cycle unless we have a valid justification to hold on to it such as to resolve disputes or comply with our legal obligations.
Your choices and how to contact us about LiveRamp data connectivity services
Opting-out of LiveRamp connectivity services
LiveRamp gives consumers the opportunity to opt-out of all our Connectivity Services. Click here to learn about permanent email-based opt-out features and to access our cookie-based opt-out. We also offer a mobile device ID opt-out here.
LiveRamp is a member of the Digital Advertising Alliance (DAA) and Digital Advertising Alliance Canada (DAAC) and adheres to the DAA Principles for Online Behavioral Advertising and Multi-Site Data, as well as related guidance. LiveRamp subscribes to the DAA’s industry-wide cookie opt-out mechanism that can be found here and its mobile device ID opt out available through its AppChoices app. Consumers who choose to opt out through these DAA mechanisms do not need to opt out of the equivalent mechanism with LiveRamp.
Keep in mind that opting out of LiveRamp through our opt-out channels or through the DAA does not disable advertisements altogether. Instead, opting out means that LiveRamp services will no longer be used to facilitate targeted advertising to your browser, device, or email address. In other words, you will still see advertisements and receive email marketing, but they will be less relevant to you.
If you create a new email address, reset the mobile advertising ID on your device, or use a new browser, you will need to apply the appropriate opt out to that new email address, new device ID, and/or new browser as opt-outs are not necessarily transferred between email addresses, browsers, or devices.
Opting-out of LiveRamp connectivity services
LiveRamp requires that our partners meet the same high standards we have. We contractually require that our match partners employ notice and choice mechanisms, and we work with other information service providers and our partners to assist them in following their respective industry standards.
Where business needs exist, LiveRamp intends to transfer personal data to entities outside the US and EU. However, your personal data will not be transferred unless a valid transfer mechanism is in place legitimizing such a transfer. In the case referred to in Article 46,47, or the second paragraph of Article 49(1), this will typically involve EU model clauses or the EU-US Privacy Shield Framework. Safeguards afforded by the EU model clauses may be accessed here.
How to contact us
If you wish to contact our privacy team about LiveRamp Connectivity Services, please send an email to firstname.lastname@example.org. Our principle place of business is 225 Bush Street, 17th Floor, San Francisco, CA. 94104.
If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.