LiveRamp Product and Service Privacy Notice

LiveRamp is a data connectivity platform leveraged by companies, such as brands and their partners, to deliver relevant advertising and marketing. Our business provides the technology to move data safely and securely between the advertisers, platforms, and other parties that select and host ads. 

LiveRamp allows companies to enhance and activate their data across online and offline channels, primarily for marketing purposes. For instance, a sports clothing store might receive email addresses from its shoppers. This enables the store to send emails to its shoppers regarding offers or updates, but doesn’t enable it to communicate tailored offerings to its shoppers through different channels, or enable the store to understand the effectiveness of its online marketing.

LiveRamp enables the sports clothing store to transform the information provided directly by its customers into other identifiers, such as the advertising IDs at platforms that engage in online advertising. This enables the store to use (and sometimes to share) its data much more flexibly, such as serving digital advertisements on their customers’ devices, understanding how those digital advertising campaigns impact in-store sales, or discovering additional customer traits (for instance “interest in outdoors”) by appending 2nd- and 3rd-party data sets to its customer list.

Though the information in this notice is accurate regardless of where you reside, more specific information and access to some data rights described in geographically-defined regulations, such as state-specific privacy rights or the European Union’s General Data Protection Regulation (GDPR), may be available depending on your jurisdiction.

This privacy notice applies to the products and services that we offer and databases we manage when we operate as a “business” or “controller.”  If you have questions about our practices on the liveramp.com website or if you have questions on how we manage personal information that we collect from you at corporate activities and events, please consult our Web and Business Representative Privacy Notice.  

For the purposes of this notice, “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 with a particular consumer or device. This definition includes, without limitation, offline identifiers such as a name, postal address, phone numbers, and social security number, information that has traditionally been considered personally identifiable information (PII), and online identifiers associated with devices (i.e., a browser cookie or mobile advertising ID).

An overview of how we process personal information 

LiveRamp processes personal information in two main ways. 

First, we collect and maintain personal information to enable the data connectivity that we provide to our customers. We collect personal information for this purpose from several different types of sources, and we use it to generate and translate the identifiers that our customers – such as the sports clothing store described above – use for their own marketing campaigns and related purposes. The personal information that enables this connectivity forms LiveRamp’s core data assets.

Second, LiveRamp provides its customers with online identifiers and helps customers map identifiers to one another for their own purposes. In many cases, customers use identifiers for digital advertising campaigns. Although LiveRamp limits the types of personal information that its customers can associate with our identifiers as well as the purposes for which customers can use them, our customers – not LiveRamp – determine how they will use and disclose their data. 

Here’s an example to help make LiveRamp’s role in online data connectivity clearer. Cookies – small text files stored in your browser – very often store identifiers. Cookie identifiers can be used for site functionality and security as well as advertising, analytics, and other commercial purposes which span multiple sites. 1st-party cookies are cookies set by the website owner; 3rd-party cookies are cookies set by parties other than the website owner. In its products, LiveRamp both places 3rd-party cookies and leverages its partners’ 1st-party cookies.

On web browsers, LiveRamp may collect and store one or more identifiers and data using 3rd-party cookies that it places.

When you are logged in to one of our partner websites (or sometimes, if you open emails from them), that partner may set 1st-party cookies and disclose personal information collected from you, such as your email, cookies set on your browser, IP address, or information about your browser or operating system, to LiveRamp. LiveRamp uses this personal information to create an online identifier associated with you or your device. Our partner may then store this online identifier in its 1st-party cookie and use it in targeted advertising campaigns, to connect demographic or interest-based data about you, or to connect data about your browsing on unrelated sites.

The critical point is that LiveRamp’s partner makes its own decision about how to use online identifiers and any data linked to them – including for targeted advertising. LiveRamp itself does not provide the service of targeted advertising or cross-context behavioral advertising. Instead, LiveRamp processes and transfers data to an advertiser’s advertising platform so that platform can provide targeted advertising services. 

LiveRamp gives you choices about whether we use your personal information for the purposes described in this Notice.:

• You may opt out of the sale of your personal information by following the prompts at the Your Privacy Choices page, or by enabling the Global Privacy Control signal on a compatible browser. The Global Privacy Control opt-out is subject to limitations that are explained under “Consumer Privacy Rights and Disclosures.”
• Note: For information about state specific rights and opt-outs, please read the section titled “Consumer Privacy Rights and Disclosures” in this privacy notice. To go directly to instructions for exercising rights offered by certain states, please visit Your Privacy Choices .

We collect the categories of personal information identified in the chart below from the categories of data sources identified in the chart below when we operate as a “business” or “controller.”  We collect each category of personal information for data marketing, online targeting and measurement, and operating our products and services, as further described in this privacy notice.  

Sensitive Personal Information We Collect

As detailed in the chart above, LiveRamp collects social security numbers and driver’s license numbers, which constitute “sensitive personal information” under certain state privacy laws.  LiveRamp uses this sensitive personal information strictly for identity resolution and does not infer characteristics about consumers based on such sensitive personal information.

Generally speaking, we collect, use, disclose, and may sell personal information for the purposes of building products and providing services for advertisers (and ad and data platforms that service advertisers) related to facilitating marketing, advertising, analytics, attribution, fraud detection, and reporting. This includes:

• Generally, creating marketing and advertising tools and products for our clients, as more fully described in our websites. This includes our provision of online or other “connected” datasets, campaign measurement reports and tools, data “appends” (connecting data across partner data sets and marketing channels), and data hygiene services (helping customers to evaluate, organize, validate and correct personal information they hold).
• Assisting our clients through our services to provide their current and prospective customers with better communications, 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 might be looking for new potential customers who are likely to be interested in athletic wear. The sports clothing company can use our services and products to analyze characteristics (i.e., demographics, expressed interests) about their customers and identify other customers that share similar characteristics.
• To facilitate the delivery of our clients’ marketing and advertisements to current and prospective customers. For example, a sports clothing company may have its own lists of email addresses, cookies or other identifiers associated with customers who have previously purchased sports clothing from them. The sports clothing company may wish to send a discount offer to these customers. The sports clothing company can use our products and services to deliver the company’s lists of customers/prospects to their advertising platform partners, matched to that platform’s own digital identifiers. Note that LiveRamp does not itself provide the service of targeted advertising but, rather, processes and transfers data to an advertiser’s advertising platform so that platform can provide targeted advertising services.
• For supporting clients and partners to connect your preferences across the various browsers and/or devices you use to more accurately market to you. For example, you are logged in to 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. The sports clothing company can thus display more consistent offers to you via automated technologies (such as a cookie ID or a publisher’s advertising ID) on your different devices or marketing channels. 
• We enable advertisers to track your visits to websites and your exposure to ads online. For example, when you visit a website or see an ad, this activity can be tracked using device identifiers like cookies. If you log in to one of our partner sites, these cookies can be linked to your email address. By connecting the cookies on your device with your email address, advertisers can recognize that you visited a certain website or saw a particular ad even when you are not logged in at the time. This helps them measure how effective their ads are and allows them to deliver more personalized ads to you, both online and offline.
• For use in the analytics and measurement of performance 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 help the advertiser to analyze how many ads were viewed and clicked, and if the consumer purchased any of the advertiser’s sports clothing.
• To provide a platform for advertisers to find data partners that help the advertiser to personalize advertisements 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 to a data partner, we provide a platform for the data partner to provide this information to the advertiser. The advertiser then uses this information to personalize ads to you when you visit their website.
• To sell personal information to unaffiliated third parties for their own commercial use, including to build marketing-related products and services similar to those described above and specifically including:
  • Online Interest-Based Advertising: To enable third parties to deliver audiences for online advertising.
  • Measurement: To enable third parties to conduct offline and online campaign measurement, analytics, and development of marketing insights.
  • Personalization: To enable third parties to personalize their products and services, including website optimization, email personalization and dynamic marketing and advertising optimization.
  • Linkage: To enable third parties to link profiles and segments across the various browsers and/or devices.
  • Modeling: To enable third parties to create modeled online and offline audiences for marketing.
  • Onboarding: To enable third parties to associate 1st-party data to certain third-party identifiers in order to deliver marketing and advertising services.
• Where permitted by our customer agreements, for internal use, research, fraud prevention and detection, data enhancement, product development, and internal auditing.
• To monitor, protect, and maintain the security and integrity of our services and our business, such as protecting against and preventing fraud, unauthorized transactions, claims and other liabilities.
• To comply with applicable laws and regulations and respond to lawful requests and communications from law enforcement and other government officials.
• To carry out sales and business transactions in which information held by us is among the assets transferred or is otherwise relevant to the evaluation, negotiation, or completion of the transaction.
• To protect our rights, privacy, safety, property and/or those of others.
• To fulfill any other purpose disclosed at the point of information collection.

We may “sell” your personal information as defined in applicable privacy laws.  A “sale” includes making available personal information to a third party in exchange for “valuable consideration,” which is not limited to “monetary consideration.”  

We engage in sales when we disclose identifiers (i.e., unique personal identifiers, online identifiers such as cookies, mobile IDs, other online advertising identifiers, IP addresses, email addresses, name, postal address, phone number or other similar identifiers) and internet or electronic network activity information (i.e., information regarding a consumer’s interaction with a website or application) to our customers and partners, including advertising networks, data analytics providers, media platforms, advertisers of consumer goods and services, brands, social networks, consumer data resellers, distribution partners, third party marketers and marketing partners, digital advertisers operating in ad tech sector.  For information about how to opt out of sales, please find the section titled “Consumer Privacy Rights and Disclosures” in this privacy notice. To go directly to instructions for exercising rights offered by certain states, please visit Your Privacy Choices .

We may also disclose each category of personal information that we collect to 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.

In addition, we may disclose each category of personal information that we collect as follows:  

• Legal Purposes: We may disclose personal information to third parties in order to: (a) comply with legal processes or a regulatory investigation (e.g., a subpoena or court order); (b) enforce our Terms of Service, this privacy notice, 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 personal information to other companies and organizations (including law enforcement) for fraud protection, spam/malware prevention, and similar purposes. 
• Corporate Transactions: We may also disclose 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.
• We may disclose your personal information for other reasons that we will describe at the time of personal information collection or prior to disclosing your personal information.

As a data controller, we do not directly and knowingly collect personal information about children or minors under the age of 18. In addition, our websites and systems are not designed for use by individuals under the age of 18. If we learn we have collected or obtained personal information of someone under 18 as a data controller, we will delete that information from our database. If you believe that this has occurred, please contact the U.S. Data Ethics Team.

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. This is information we access as a “processor” or “service provider”. This information is not owned by LiveRamp, and thus is not subject to this privacy notice.  For additional information or to exercise your rights, please contact whichever company or organization is the “controller” or “business” that is responsible for collection, use, or disclosure of your personal information.

LiveRamp has implemented security measures, including physical, technical and operational safeguards, designed to prevent the unauthorized access to or acquisition of personal information in our possession. However, no security measures are 100 percent effective. Thus (like other platforms and websites) we cannot guarantee such safeguards in securing all information from any such event or preventing harm that might arise.

LiveRamp will retain your personal information for as long as reasonably necessary to provide the products and services described in this privacy notice or otherwise where permitted or required in accordance with applicable law. We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. What this means in practice will vary between different types of information, and when we consider our approach we take into account ongoing business or legal needs for the information, for example in relation to tax, health and safety, and potential or actual disputes or investigations.