- Choice: We support consumer choice. We offer a persistent opt-out mechanism that enables operators to flag subscribers who have exercised a privacy choice. Network Partners then pass that choice on to Cinarra in order to ensure that data pertaining to opted out subscribers does not get processed in our systems. This action ensures that consumers who express a choice to opt out do not receive targeted advertisements from our Advertising Platform. Our Network Partners may also support additional method(s) of consumer choice which are performed entirely within Network Partners’ systems. Finally, we require that our Advertising Partners honor the choice mechanisms offered by mobile operating systems and those partners may offer additional consumer-based choice mechanisms.
- Collection Limitation: Our technology platform ensures clear roles and data flows between Network Partners and Cinarra. For example, integration and analytics functions are separated from the advertising targeting functions via separate software modules that may be hosted on separate hardware if needed. Network Partner data never leaves their systems and as such is subject to the Network Partners’ strict security and privacy requirements. Cinarra’s Advertising Platform only receives pseudonymized targeting criteria. These privacy preserving processes help ensure that Cinarra only obtains the minimum data necessary to target ads.
- De-identification: As referenced above, Cinarra utilizes de-identification techniques to ensure that no consumers’ personal information is processed, stored, or used by the Advertising Platform. Rather, the Advertising Platform operates on statistically aggregated datasets. For example, pseudonymous identifiers such as device IDs are one-way hashed, and (where feasible) aggregated to make it commercially impractical for Cinarra or a third-party (e.g., a researcher) to identify a particular individual via our systems. Network Partner customer identifiers are processed via SHA-1 one-way hash. No tracking or logging of personal information or precise location (e.g., lat/long) is performed by Cinarra.
- Security: Cinarra has implemented reasonable security measures to protect the information in our care – both during transmission and once it is received. We’ve adopted reasonable access and site controls, personnel policies and other processes to ensure that the data under our control is kept secure.
- General Data Protection Regulation (GDPR): Cinarra does not process data of consumers in any of the geographies of the European Economic Area (EEA).
Cinarra views consumer privacy as a key differentiator between our platform and other advertising platforms. As a result, we strive to ensure that our privacy principles serve Cinarra, our partners and customers and most importantly, consumers.
Updated April 17, 2018