Accretive Privacy Policy

Accretive Media LLC (“Accretive”, “we”, “us”, “our”) is a leading out-of-home data and technology company that provides a platform used for the measurement of out-of-home advertising. This Privacy Policy is provided to help you understand how Accretive processes user data on behalf of our clients who use the Accretive platform. 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. We are a “data processor” that collects and analyzes end user data from our advertisers and partners at the specific request of our clients, the “data controllers.”

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:

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
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

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, user name, 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 serves as a data processor, acting at the direction of our data controller clients and utilizing our data controller partner assets.

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 May Clients 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

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.

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

How Does Accretive Adhere to GDPR Principles?

Accretive serves as a data processor under GDPR, and adheres to the principles and rules of GDPR. Specifically, Accretive implements privacy by design and default principles, ensures limited data retention protocols, adheres to incident response norms, allows for appropriate third party audits, ensures data is only transferred internationally with a lawful basis, only contracts with sub processors with adequate written commitments to data processing, respects data subject rights, does not process sensitive personal data, and provides data processing agreements to all appropriate clients and partners. (In addition to GDPR, Accretive respects and adheres to similar data privacy laws in other jurisdictions, such as the California Consumer Privacy Act.)

Legal Basis
Your data will be processed on the following legal bases:

Your consent to data controllers in accordance with Art. 6 (1)(a) GDPR;Y
For the performance of a contract with you in accordance with Art. 6 (1)(b) GDPR;
For the fulfillment of statutory obligations in accordance with Art. 6 (1)(c) GDPR; or
From a legitimate interest in accordance with Art. 6 (1)(f) GDPR (and, to the extent we base the processing of your personal data on legitimate interests, such data will only be used to improve or carry our services, protect against misuse or fraud, and maintain statistical integrity with business partners and customers).

How Long Do We Keep Information?

Data is retained in order to provide anonymized reporting for our clients throughout the duration of their ad campaign and never longer than 1 year.

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 their Code of Conduct. 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 legal@accretiveads.com or by mail at:

Accretive Media LLC
2711 N Sepulveda Blvd,
#757 Manhattan Beach, CA 90266
ATTN: Privacy

REVISED 6/30/23