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SteelHouse Privacy Notice

Effective Date: April 1, 2020

Steel House, Inc. (“we,” “us,” or “our” “SteelHouse’) provides marketing services (collectively, the “Services”). This privacy policy (“Privacy Policy”) describes how we collect, use, and share information through: (i) our Services, and (ii) our corporate website at https://www.steelhouse.com or any SteelHouse-owned or SteelHouse-licensed website (collectively the “Site”) and applies to individuals in the European Economic Area who use the Site or whose personal data is otherwise provided to or collected by us in connection with the Services.

For the purposes of users of the site located in the EU, we are the controller of any information we may collect when you visit our Site. Lee Stevens, with the contact email address privacyrights@steelhouse.com, is our representative in the EU for the purposes of the GDPR. Our data protection officer can be contacted at privacyrights@steelhouse.com.

Please read this policy carefully so that you understand your rights in relation to your data, and how we will collect, use and process your data.

Section 1: Our Corporate Website

This section of the Privacy Policy describes how we may collect, use, and share information collected on our Site.

Information Collection

We may collect a variety of information when you visit our Site. We only collect certain personal information if you contact us, request services, or otherwise provide it to us, and in each instance only to the extent you provide us with your personal information. This personal information may include any of following: your name, email address, phone number, and any other such information you directly provide to us. Additionally, when you visit our Site, we collect device identifying information such as your IP address or Device ID, which is necessary to provide you with access to the Site. Device identifying information is potentially personal data, if it is combined with other data provided by your ISP service provider, but SteelHouse does not have access to your ISP’s data. Your device identifying information is not used by SteelHouse to identify you.

We may also collect certain technical information when you visit the Site. This type of information is your country, city, browser type, operating system, service provider, the areas you visit on the Site, time and date of your visit, and Google Analytics client ID. We may collect this technical information through cookies, web beacons, or other similar technologies. We may combine device identifying information and technical information together.

How We Use Information

As it is in our legitimate interests to be responsive to you and to ensure and improve the proper functioning of our Site, we may use any of the information we collect for the following purposes:

Information Sharing

We may share the information we collect with the following third parties:

We may share information with third parties that has been anonymized and aggregated. We require all advertisers or publishers to disclose any third party data collection and use and provide an opt-out: http://optout.networkadvertising.org/

As a member of the Network Advertising Initiative (“NAI”), we adhere to the NAI Code of Conduct. Click here if you would like further information regarding the DAA principles and here if you would like information about the NAI Code of Conduct.

Social Media Tools and Links to Other Websites

The Site may provide links to other websites that we do not control. We encourage you to review the privacy policy of those websites you may visit.

The Site may include social media tools or “plug-ins”, such as social networking and blogging tools offered by third parties. These social media companies may collect information about you and may use and share such information in accordance with your social media account settings, including by sharing such information with the general public. Your interactions with third-party social media companies and the use of their features are governed by the privacy policies of the social media companies that provide those features. We encourage you to carefully read the privacy policies of any social media accounts you create and use.

Your Choices: Analytics

We use Google Analytics to improve the performance of the Site and our Services and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you visit our Site or use our Services, visit https://www.google.com/policies/privacy/partners/, and to opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

How long do we store your data? after you visit our Site?

You can request deletion of your information by following the process set out in Section 3 below. All data provided by you to us through our Site will be deleted no later than two (2) years after the date of disclosure.

Section 2: Marketing Services

This section of our Privacy Policy describes how we collect, use, and share information through our Services.

Where we use any of your information that includes personal data in order to provide the Services of serving to you advertisements that may interest you, we are acting as joint controllers with our customers and the companies assisting us to serve the advertisements, including the publisher (i.e. the owner of the applications and websites on which advertisements are displayed).

In our contracts with these partners, they are allocated the responsibility under the GDPR for providing the required notices, obtaining any necessary consents and facilitating the exercise of your data subject rights. We work with the IAB UK to ensure that the data we collect from our affiliates and ad technology partners (as further described in The Information We Collect) is processed with your consent. SteelHouse is a registered vendor under the Transparency and Consent Framework provided by IAB Europe. To learn more about this framework, please visit the IAB Europe page.

The Information We Collect

Through the provision of our Services we collect various types of information from our customers, affiliates and ad technology partners, including from:

How We Use the Information We Collect

We use the information we collect through the Services on the basis of our legitimate interest in running and improving our ad technology business to select and deliver targeted advertisements to a user’s browser or mobile apps and other uses such as:

In order to be able to serve advertisements to you that you may wish to see, we may combine data and link your activities across devices and websites through the use of your device identifying IP address. We also may use your device identifying IP address for advertising campaign performance purposes. Your IP address is used by us internally and is not shared with any third parties.

Information Sharing

We may share the information we collect through the Services with the following categories of third parties for the following purposes:

For a full list of the third parties which we work with, please click here.

Where do we store your personal data?

As we are United States company, any information provided to us, will be stored, processed, and transferred within, or to, the United States. Please be aware that the US and jurisdictions other than the one in which you are located will not have the same data protection laws as your own jurisdiction.

Your personal data is also processed by staff or service providers operating outside the EEA in the United States, who work for us.

Where we receive your information from publishers, advertisers or other ad technology partners, and they are located in the EEA, we enter the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2010/87/EU (Controller-to-Processor Model Clauses).

Your Choices

As part of our Services we collect information across non-affiliated websites over time. We collect this information to make inferences about your interests in order to provide advertising relevant to you based on those interests. This practice is known as interest-based advertising.

You can use your device settings, such as “Limit Ad Tracking,” to exercise choice regarding our collection and use of information for interest-based advertising from websites and mobile applications on your device. You can also limit our collection of precise location data through your device settings. For more information on your choices, including to opt out of receiving interest-based ads from many third parties, please go to: http://optout.aboutads.info/. For more information about opting out on mobile devices, please go to: https://www.networkadvertising.org/mobile-choice.

Many browsers (including Internet Explorer, Firefox, and Safari) allow you to set a Do Not Track (DNT) signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked. We follow DNT settings. You can usually access your browser’s DNT option in your browser’s preferences.

Note that if you exercise choice regarding interest-based advertising you will still see advertising in websites and mobile apps, but those ads may be less relevant to your interests. Data may still be collected from your device with your consent for purposes other than interest-based advertising after you make your choices. If you use different devices, or reset your device identifier, you may need to make your choices again.

California Residents

California law permits California residents to request certain information regarding our disclosure of personally identifiable information to third parties for their direct marketing purposes. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To make such a request, please contact us at privacyrights@steelhouse.com.

Retention of data

Targeting data is stored for a rolling period of two (2) years from the last website visit. Reporting data is stored for the duration of the contract. Reporting data may be deleted at the advertiser’s request, and in in all cases two (2) years after termination of the Agreement.

Section 3: Other General Privacy Practices for the Services and Site

Data Security

We implement reasonable security measures to help protect the security of information we collect through the Site.

Your rights

In certain circumstances you have rights in relation to the personal data we hold about you. We set out below an outline of, and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights. To exercise any of your rights, please email privacyrights@steelhouse.com. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.

Withdrawal of Consent

California Residents – California Consumer Privacy Act (“CCPA”)

The California Consumer Privacy Act (“CCPA”) provides California residents with the right to request certain information regarding our collection of personal information from California consumers. If you are a California consumer, you have a right to request the following:

  1. The categories of personal information we may have collected about you;
  2. The categories of sources from which the personal information may have been collected;
  3. The business or commercial purpose for collecting or selling personal information;
  4. The categories of third parties with whom we share personal information; and/or
  5. The specific pieces of personal information we may have collected about you.

SteelHouse may share device identifying information, such as your IP address and anonymous user agent and usage information with the service providers listed in this Privacy Policy solely for a business purpose pursuant to a written contract between SteelHouse and the service provider. SteelHouse’s service providers use the device identifying information as necessary to perform the business purpose stated in a written contract.

If you would like to request that SteelHouse not “sell” your personal information as that term is defined under CCPA, you may contact our Data Protection Officer with your “do not sell my personal information” request as follows:

Email: privacyrights@steelhouse.com
Phone:  (888) 978-3354

You may also request that SteelHouse delete your personal information and/or device identifying information by contacting us at the email or phone number provided above. Please understand that SteelHouse is required by CCPA to first verify any request received prior to complying with any CCPA request.

In some instances, SteelHouse is not required by CCPA to delete personal information. In such instance, SteelHouse will notify you if your personal information was unable to be deleted for one of the permitted exceptions under CCPA.

If you would like to opt out of receiving SteelHouse advertisements, please click below and click “opt-out” to exercise your “Do Not Sell My Personal Information” right under CCPA.

https://steelhouse.com/opt-out/

Objection to Marketing

Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at privacyrights@steelhouse.com and we will endeavor to deal with your request. This is without prejudice to your right to launch a claim the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.

Changes to This Notice

If we make changes to this Privacy Policy, we will post the new policy here. We encourage you to periodically check back to remain up to date on our privacy practices.

Contact Us

If you have questions, comments, or concerns about this Privacy Policy, please contact us at privacyrights@steelhouse.com.