Accretive Privacy Policy

Accretive Media LLC and its affiliate Accretive Technologies LLC (together, “Accretive”, “we”, “us”, “our”) provide an out-of-home data and technology platform used for the measurement of out-of-home advertising. Accretive also licenses mobility data from commercial data vendors and builds audience segments from it, which it makes available to advertising partners. This Privacy Policy is provided to help you understand how Accretive processes user data. It does not state the use practices or policies of our clients, our data partners, of the websites or mobile apps on which data is collected, or of other parties.

Accretive cares about how end user data is collected, used, and shared. Accretive acts in two different capacities depending on the data. For the mobility data we license from data vendors, and for the audience segments and location inferences we build from it, Accretive determines the purposes and means of processing and acts as a “controller” (in some states, a “business”). For campaign measurement and attribution that we perform using inputs supplied by an advertiser client, Accretive acts as a “processor” at that client’s direction.

The Accretive Platform and Data Pledge
The Accretive platform is used by brands and agencies to measure out-of-home advertising. Clients primarily use Accretive to assess the effectiveness of their out-of-home investments and act on those results. In some instances, supplemental targeting and optimization insights derived from out-of-home advertising measurement are provided.

Pursuant to the Accretive Data Pledge, our clients determine the data that they provide to and collect through Accretive. Clients’ use, collection, exportation, or any other use of end user data is governed by their own privacy policies and applicable laws, rules, or regulations.

What Information Does Accretive Collect?
Accretive collects and utilizes the following types of information from partners and end users to help clients measure and manage their digital out-of-home campaigns and to build audience segments:

Ad Identifiers (unique character strings associated with user devices that help monitor and measure user interactions with advertisements and apps, such as Apple’s IDFA and Google Ad ID; Ad Identifiers may be reset by the user)
Web and App actions from Pixel tags and Mobile Measurement Partners (MMPs)
IP addresses from Web and App actions
Third Party Opt-In Geographic location data derived from IP address, GPS data, and/or Wi-Fi networks
Precise Location Information derived from mobile devices
Inferred location attributes, such as a device’s approximate home and daytime areas
Area-level demographic attributes from public U.S. Census Bureau data, assigned to a device’s inferred home area
Audience segment membership derived from observed visitation to publicly accessible commercial and civic locations, and from statistical modeling
Household groupings derived from shared IP address observation

Our clients may also choose to share certain account information for both their customers and their partners on the Accretive Platform. This may include corporate and employee information necessary to maintain the services and up-to-date contact information, including: name, mailing and/or billing address, email address, company name, website url, username, password, and phone number.

Clients and data partners own the data that they provide to and collect through the Accretive Platform. When clients and data partners remove their data from the Accretive Platform, their use of data is governed by their own privacy policies and applicable laws, rules, or regulations.

Accretive does not knowingly accept, process, or sell any personal information related to minors (under 18) in all U.S. States.

What Information Does Accretive Collect on Websites from End Users?
When you visit websites, Accretive collects information about your device and use of the Websites to understand whether the client’s advertising activity drove this interaction. The type of information collected will depend on your request and interaction with the Websites. Categories of information may include specific times of day you accessed the Websites, the IP address of the device you used to access the Websites, the pages on the Websites that you viewed, and information about the device you use to access the Websites, including hardware model, operating system and version, and browser.

Accretive uses the information collected on the Websites for various purposes, including:

Advertising analytics and reporting
Audience segmentation
Providing confirmations, invoices, technical notices, updates, security alerts, and other support and administrative messages.

How Do Clients Use Accretive to Collect Information from Users?
Clients may use Accretive for pixel or server postback tracking to collect certain performance marketing information about end users. Pixel tracking methods feed back consumer information to Accretive to process on behalf of clients.

Accretive also supports server-to-server measurement for some clients. With any of the mentioned methods, when an end user is exposed to an advertisement and goes to a specific web page or mobile app action that a client chooses to measure, Accretive collects information from the user’s device, including but not limited to IP address and ad identifiers.

How Clients May Use Accretive to Process Information from End Users?

Measuring performance of ad campaigns, including creation of customized performance reports
Supplementing ad campaign targeting and optimization using data that does not personally identify users
Retargeting devices observed near an out-of-home advertisement during a campaign, through third-party demand-side platforms

Sale and Sharing of Personal Information

Accretive makes audience segment files containing mobile advertising identifiers available to third-party audience activation and data distribution partners, so that advertisers can reach those audiences in digital advertising. Under California and other state privacy laws this is a “sale” or “share” of personal information, and we disclose it as such.

We also deliver measurement feeds containing hashed device identifiers to a contracted measurement partner.

Recipients are audience data platforms, activation partners and measurement partners, operating under written agreements that impose privacy, security and permitted-use obligations and require compliance with applicable law and with consumer choice.

You have the right to opt out of the sale or sharing of your personal information. See “How to Exercise Your Rights” below.

Sensitive Personal Information
Some information we process is treated as “sensitive personal information” or “sensitive data” under California and other state privacy laws.

What we process. Precise geolocation: we license mobility data that includes precise geographic coordinates of mobile devices. Inferences about health and wellness interests and political interests: we build audience segments from observed visits to publicly accessible commercial and civic locations, and some of those segments relate to fitness and wellness activity or to political interest.

Why we process it. Precise geolocation is used to determine whether a device was within exposure distance of an out-of-home advertisement, to measure visits to advertiser business locations, and to infer a device’s approximate home area for demographic assignment and audience construction. Health and wellness and political interest segments are made available for advertising targeting through our partners.

Whether we sell or share it. Coarsened geolocation and audience segment membership are made available to advertising partners.

Safeguards. We maintain a reference list of 74 sensitive venue categories, including health facilities, reproductive health providers, places of worship, schools and childcare, correctional facilities, military installations, immigration services and LGBTQ-oriented venues.

Observations at these locations are flagged and excluded from home and daytime location inference and from audience construction. In Maryland, New Jersey, Oregon and Virginia, coordinates are maintained at two decimal places. We do not build segments about immigration status, religion, sexual orientation, criminal history, or health conditions or diagnoses.

Consent. We do not collect information directly from consumers. We license it from data vendors who represent that the necessary consents were obtained through the mobile applications in their supply chain.

Your right to limit.

California residents may direct us to limit our use and disclosure of sensitive personal information to what is necessary to provide our services. To exercise this right, email privacy@accretiveads.com and include the mobile advertising identifier of the device concerned, which is the identifier on which our records are organized.

In Which Instances Might Accretive Share End User Data with Third Parties?
Except as described in this Privacy Policy, Accretive will not share data collected on the Websites or in the Accretive Platform with other people or non-affiliated companies unless we have your consent, or under the following circumstances:

With third party service providers who work for us and need access to your information to do their work on our behalf, such as providing customer support features, processing payments, ad serving, and storing data (e.g. Amazon Web Services). All such third-party vendors have agreed to protect the confidentiality of information provided by Accretive.
To protect the rights and property of Accretive, our agents, customers, users, and others, including to enforce our agreements, policies, and terms of use.
If required to do so by law, such as to comply with a subpoena or court order, or in the good-faith belief that such action is reasonably necessary to protect our rights, protect your safety or the safety of others, prevent fraudulent, malicious, or unlawful activity, investigate fraud, or respond to a government request.
As part of any merger, acquisition, debt financing, or sale of company assets or other event in which information could be transferred to third parties as one of the business assets of the company.
To audience activation and data distribution partners, as described under “Sale and Sharing of Personal Information” above.

We may also share aggregated or pseudonymized information in a form that does not directly identify you or any end users with any third parties.

How Long Do We Keep Information?
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including any legal, accounting, or reporting requirements. Retention periods vary depending on the type of data, contractual obligations, and regulatory requirements. Once personal data is no longer needed, we securely delete or anonymize it. Consumer opt-out and deletion requests are honored on receipt regardless of any retention period.

Regulatory Considerations for Consumer Rights
At Accretive, we are committed to protecting your privacy and ensuring that your personal data is handled in compliance with applicable data privacy laws. In addition to our general privacy practices, we comply with various state-specific regulations designed to protect consumer rights regarding personal data. This section outlines your rights under these laws, particularly in states like California, which provide enhanced privacy protections.

California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
If you are a resident of California, you are granted specific rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). These rights include:

Right to Access: You have the right to request information about the personal data we collect, use, or share about you. Upon receiving a verifiable request, we will provide you with a copy of your personal information.
Right to Correct: You may request the correction of any inaccurate personal information we hold about you. We will respond to your request within the timeframe required by law.
Right to Deletion: You have the right to request the deletion of your personal information that we have collected, subject to certain exceptions, such as when the information is needed for legal obligations or business purposes.
Right to Opt Out of Sale or Sharing: We sell and share personal information as described under “Sale and Sharing of Personal Information” above. You have the right to direct us not to sell or share your personal information.
Right to Limit Use and Disclosure of Sensitive Personal Information: You have the right to direct us to limit our use and disclosure of your sensitive personal information to what is necessary to provide our services. See “Sensitive Personal Information” above.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights, including denying you services or charging you different prices or rates for using our services.

Other State-Specific Rights
In addition to the rights provided under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), residents of several other U.S. states may also be entitled to specific rights with respect to their personal data under applicable state privacy statutes. These laws vary in scope and effective dates, but they generally provide consumers with rights such as access, correction, deletion, portability of data, and the ability to opt-out of certain types of personal data processing. Some states also provide consumers with the right to appeal a decision if the business denies their privacy-related request.

How to Exercise Your Rights
To exercise your rights under applicable state laws, you may submit a request by emailing privacy@accretiveads.com. We do not hold names, email addresses or other directly identifying information, so please include the mobile advertising identifier of the device concerned, which is how our records are organized. A request with only a name or email address generally cannot be matched; if so, we will tell you what would make it actionable. An authorized agent may submit a request on your behalf. We will respond to your request in accordance with the legal timelines and requirements.

We take your privacy seriously and will ensure that all requests are handled promptly, following the relevant state-specific privacy laws. For more detailed information about your rights, please refer to the full privacy policy or contact us directly.

Consumer Opt-Out
Consumers may limit the sharing of their device mobile advertising identifier, as well as location information, in their mobile device settings. We are a member of the Network Advertising Initiative (NAI) and adhere to the framework principles. In addition, our data partners provide detailed instructions on how to opt-out on mobile devices via their websites or consumers can opt-out via the Mobile Choices page of the NAI’s site at https://thenai.org/opt-out/mobile-opt-out/. Because we do not have a direct relationship with consumers, we do not offer these tools directly.

Security
Accretive uses commercially reasonable efforts, including a variety of security technologies and procedures, to help protect client and end user data from unauthorized access, use, or disclosure, both during transmission and once it is received.

Contact Information
If you have any questions regarding this Privacy Policy, or would like more information on our privacy practices, please contact us at privacy@accretiveads.com or by mail at:

Accretive Media LLC

2006 N Sepulveda Blvd. #757

Manhattan Beach, CA 90266

ATTN: Privacy

REVISED August 1, 2026