PLAYWIRE PRIVACY POLICY

Please read this Privacy Policy carefully to understand how Playwire LLC, its subsidiary and affiliate corporations, successors, and assigns (collectively, “Playwire”) uses and protects the information you provide.

Publication Date: Jan 31, 2023
Updated: Mar 16, 2023

This “Privacy Policy” applies to www.playwire.com, the Playwire Platform (see below), and any other websites owned or operated by Playwire or that may be subsequently added, variations or successors to this website (the “Playwire Sites”), any Playwire computer software downloadable or otherwise available from the Playwire Sites (“Software”), Playwire’s services, including but not limited to, the Playwire digital advertising technology, advertising management services, mobile applications, Revenue Intelligence™, RAMP™, Trendi™, Kids Club^®, and all other Playwire platforms and networks (collectively referred to as the “Services, Platforms and Networks”) 

This Privacy Policy applies to all Users of the Playwire Sites, Software, the Services, Platforms and Networks.   If you are interested in finding out more information regarding our GDPR compliance, click here.

1. TYPE OF INFORMATION PLAYWIRE AND THIRD PARTIES COLLECT.

By use of the Services, Platforms and Networks, Playwire may collect two (2) types of information about Users: Personal and Non-Personal. In addition, Playwire works with advertisers, ad agencies, third-party traffic measurement services and other service providers (collectively “Third Parties”) to serve advertisements on publishers using the Playwire Services, Platforms and Networks. Third Parties may set and access their own tracking technologies on your device including but not limited to cookies, web beacons, device identifiers and other information as described below.

1. “Personal Information.” Personal Information refers to information that lets Playwire know the specifics of who you are and which may be used to identify, contact or locate you or a business interested in the Playwire Sites, Software, the Services, Platforms and Networks (e.g., name, mailing address, telephone number and e-mail address). Playwire may collect Personal Information when you use the Playwire Sites including, without limitation, setting up account information, filling out surveys, corresponding with Playwire, or otherwise volunteering information about yourself. Playwire does not sell, trade or rent Personal Information collected through the Playwire Sites to any third-party. Notwithstanding the foregoing, Playwire shall: (1) fully cooperate with law enforcement agencies; and (2) may be required to disclose Personal Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation.
2. “Non-Personal Information.” Non-Personal Information refers to information that, by itself, does not identify you as a specific individual (e.g., demographic information or website visitations). Playwire and/or advertisers, advertising agencies, third-party traffic measurement services and other service providers may collect and/or process Non-Personal Information through a variety of methods and industry standard technologies described further below.

• Information about your browser including: the type of browser you use, browser language, browser settings, cookie information and other locally stored objects. This may include data about you related to bid requests and ad impressions, collected when we decide to show you an ad on a Digital Property and when we deliver an advertisement.
• Information about your device including device operating system version, connection type, device make, device model, device Identifiers such as your IDFA or AAID, and the IP address from which the device accesses our Services, Platforms and Networks.
• Unique anonymous IDs assigned to your browser or device, which allows the Platform to automatically recognize your browser or device the next time it visits another Digital Property that has integrated our technology.  This allows our clients and partners to sync their own unique identifiers against this ID so that they can use their own data on the Services, Platforms and Networks that they may have associated with you (collectively “Digital Identifiers”).
• General geolocation information, as well as precise geolocation information when location services have been enabled for an app on your device that has integrated our technology or that sends that information to our Services, Platforms and Networks.
• Information about your online activity such as website visited, general browsing history, viewing history, referral source, search history and information regarding an individual’s interaction with an internet website, app, or advertisement, including the time web pages or apps were visited or used, including in-game or online viewing activity (e.g., videos viewed, pages viewed).
• Inferences or audience segmentation derived from our Services, Platforms and Networks, such as individual profiles, preferences, characteristics, and behaviors.
• Information about ads served, viewed or clicked on, including the type of ad, where the ad was served, whether you clicked on it and whether you visited the advertiser’s website or downloaded the advertiser’s app.
• Information about the specific content viewed on websites
• Email addresses in hashed form
• Information about your internet service including information about which internet service provider is used by you.

1. To receive more information about these practices and/or opt out of these types of data collection you may visit the following links:

• To opt-out of interest-based advertising using cookies:

https://thenai.org/opt-out/

https://optout.aboutads.info/ 

https://www.youronlinechoices.com/uk/your-ad-choices

https://youradchoices.com/appchoices 

https://allaboutcookies.org/how-to-manage-cookies

• To opt out of email-based identifiers go here:

LiveRamp:

When you use Playwire Publisher Websites and enter your email address on their websites (either to log in, or to sign up for a newsletter, or similar), we may share with LiveRamp and its group companies information that we collect from you, such as your email (in hashed, pseudonymous form), IP address, or information about your browser or operating system, with any of the following, acting as “joint controllers” (as applicable and defined in the GDPR).

LiveRamp uses this information to create an online identification code that we may store in our first-party cookie for our use in online, in-app, and cross-channel advertising. This may be shared with advertising companies to enable interest-based and targeted advertising. LiveRamp uses this information to create an online identification code for the purpose of recognising you on your devices. This code does not contain any of your directly identifiable personal data and will not be used by LiveRamp to re-identify you. 

Detailed information on LiveRamp’s data processing activities is available in LiveRamp’s privacy policy https://liveramp.com/privacy/. You have the right to withdraw your consent or opt-out to the processing of your personal data at any time https://liveramp.com/opt_out/.

Trade Desk UID:

https://transparentadvertising.org/

• To turn off personalized ads in Chrome go here: 

https://adssettings.google.com/authenticated

• To opt out of Google Analytics go here:

https://tools.google.com/dlpage/gaoptout 

Mobile device system software such as Apple iOS or Google Play Services provide mechanisms that allow users to opt out of the use of information about their usage of mobile apps to deliver targeted ads to their mobile device. For more information, or to opt out using these mechanisms, consult your device settings (“Opt out of Personalized Ads” on Android devices and “Limit Ad Tracking” on iOS devices). When Playwire’s technology encounters “Limit Ad Tracking” signals they are respected. Devices vary in where they include the setting to adjust.

2. HOW PLAYWIRE AND THIRD PARTIES USE THE INFORMATION WE COLLECT.

We use, and allow third parties as set forth herein to use, the information we collect for the following purposes:

1. System Administration. Playwire may use Non-Personal Information for the purposes of system administration, assisting in diagnosing problems with Playwire servers, monitoring Playwire’s Services, Platforms, and Networks performance and traffic on the Playwire Sites and to gather broad demographic information about Playwire customers.
2. For our legitimate business interests to provide services to advertisers, including providing and operating our services which include:

• Compiling statistics about the advertising transactions occurring through our Platform and conducting research and development for our own internal business purposes, such as analyzing campaign forecasts and conducting machine learning to help our clients improve their sales of ad space and delivery of ads to you
• Analyzing and reporting on campaign and ad performance, such as reporting to advertisers about when and how you have been exposed to ads or clicked on ads, and reporting to Digital Properties information about when and how ads were shown on their Digital Properties and whether they were clicked on
• Investigating, protecting against, and deterring malicious activity, fake traffic, or fraudulent, unauthorized, or illegal activity on the Platform and on the internet.

1. For our legitimate business interests to provide services to our customers and publishers, including providing and operating our services.
2. Playwire uses Cookies and IP Addresses to track features such as delivering content specific to your interests and informing you of new, relevant services or certain third-party offerings.
3. Notices to Registered Users. If you have registered for an Account, Playwire may use your Personal Information to send emails regarding your registration, including confirmation to verify the accuracy of any information you have provided. Playwire may also send you emails to verify your identity or to notify you if Playwire believes your use of Playwire Sites violates any applicable agreement for the use of the Playwire Sites.
4. Advertising-related purposes:

• Interest-Based Advertising: Using Platform Data to infer what you may be interested in and to serve ads to you based on these inferred interests.  
• Frequency Capping: Limiting the number of times you see an ad so you don’t see the same ad or type of ad too many times
• Showing Ads in Sequence: Showing you ads in a particular order to provide a better user experience
• Geo-Targeting: Customizing ads shown to you based on your current or prior location
• Contextual Ads: Showing ads to you based on the content you are viewing
• Ad Measurement: Understanding how users respond to ads (e.g., clicking on the ad)
• Aggregated Statistics: Reporting aggregated statistics regarding, for example, the effectiveness of online advertising campaigns
• Cross-Device Mapping: Enabling Cross-Device Mapping (grouping the devices that are owned by an individual or household) in order to serve or measure advertising on related devices on behalf of our clients.
• For ad campaigns that are intended for child-directed sites, we take measures (including activating all available child-directed tags and settings) to ensure that our service providers have disabled any and all forms of behaviorally targeted advertising and sensitive ad content categories and that the child’s anonymous browsing information is only used for permissible internal support operations in accordance with COPPA (e.g., contextual advertising, ad capping, etc.). All ads are subject to human review for appropriateness.

1. Promotional Emails.  Playwire may use your Personal Information to send you emails periodically listing promotions or events relating to the Playwire Sites or from Playwire’s marketing partners or sponsors. You have the choice to opt out of receiving such promotional emails by sending an e-mail to legal@playwire.com and/or following the instructions in such correspondence. Once Playwire has processed your opt-out request, Playwire will not send you promotional emails unless you opt back in to receive such communications.
2. Legal Rights and Compliance with Law: We may also disclose Platform Data in the event that we reasonably suspect malicious activity or fake traffic or when we reasonably believe it is required by law, subpoena, or other legal process, including to meet security or law enforcement requirements.
3. Contact Information. If you contact Playwire by telephone, e-mail, or letter, Playwire may keep a record of your contact information and correspondence. If you report a problem with the Playwire Sites, Playwire may collect this information in a file specific to you. You may contact Playwire at legal@playwire.com to request the removal of this information from Playwire’s database.

3. HOW TO ACCESS AND CHANGE YOUR PERSONAL INFORMATION

Upon request, Playwire shall allow Users to update or correct Personal Information previously submitted, but only to the extent such activities will not compromise privacy or security interests. Additionally, upon request, Playwire shall delete Personal Information from the database where such information is stored; however, it may be impossible to entirely delete a User’s entry without some residual information being retained due to the manner in which data backups are maintained. Requests to delete Personal Information shall be submitted to legal@playwire.com.

4. SAFEGUARDING YOUR PERSONAL INFORMATION

1. Security Measures. Playwire takes appropriate security measures to protect against unauthorized access, alteration, disclosure or destruction of Personal Information. These include, but are not limited to, internal reviews of: (i) Playwire’s data collection; (ii) storage and processing practices; (ii) electronic security measures; and (iv) physical security measures to guard against unauthorized access to systems where Playwire stores Personal Information. All Playwire employees, contractors and agents who access Personal Information are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution or unauthorized use or disclosure of Personal Information.
2. Third-Party Links. The Playwire Sites may contain links to third parties who may collect Personal Information and Non-Personal Information directly from you. Additionally, Playwire may use third parties to provide components of the Playwire Sites. In either case, such third parties may have separate privacy policies and data collection practices, independent of Playwire. Playwire: (i) has no responsibility or liability for these independent policies or actions; (ii) is not responsible for the privacy practices or the content of such websites; and (iii) does not make any warranties or representations about the contents, products or services offered on such websites or the security of any information you provide to them.

5. YOUR CHOICES AND RIGHTS

If you reside or are located in certain jurisdictions, you may have rights and protections regarding the collection, processing, sharing, and use of your data under a particular jurisdiction’s law. This may mean that you may have the right to:

• Request access and obtain a copy of your data;
• To request rectification of your data;
• In certain circumstances, and subject to some specific legal reasons where we may need to retain data, to request that your data be deleted or erased
• To opt out of the sale of your data to third parties;
• If applicable, to enforce your right to data portability;
• To object to the processing of your data in certain circumstances;
• Not be discriminated against for exercising your rights with respect to your data.

6. The GDPR and Your Rights as an EU or UK Data Subject

A.    Persons Covered.  If you are located in the European Economic Area (EEA), the General Data Protection Regulation (GDPR) applies to our processing of personal data. If you are located in the United Kingdom, then the Data Protection Act 2018 applies to our processing of personal data. These laws each grant those located respectively in the EEA and the UK a set of clear privacy rights and imposes responsibilities on Playwire as we process the personal data of data subjects located in those places. This section is designed to provide more information on how Playwire adheres to the GDPR and the Data Protection Act 2018 and your rights as a data subject located in the UK or the EEA.

B.    Definition of Personal Data.  Both the GDPR and UK Data Protection Act define personal data broadly. As such, where Usage Data and/or Profile Information relates to an individual in the EEA or UK we treat it as personal data. This includes: a) data collected via visits to Playwire.com; b) data collected from customers, Publishers and business partners; and c) data collected from employees and prospective employees.

C.    Special Categories of Personal Data.  Playwire does not collect nor process any special categories of personal data with respect to UK or EEA data subjects, and we do not create Profile Information of audience segments of such consumers based on special categories of personal data (i.e. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health, or data concerning a natural person’s sex life or sexual orientation).

D.    Legal Basis for Processing.  Both the UK Data Protection Act and GDPR requires entities seeking to process personal data to have a valid legal basis for doing so. The legal basis utilized by Playwire includes: a) consent; b) legitimate interest (i.e., where we believe that our need to process the data and/or the value we deliver by processing such data is not outweighed by the rights of the data subject); c) where necessary for the performance of a contract; and d) where processing is necessary to comply with our legal obligations. We will endeavor to outline our legal basis for the most common types of processing conducted by Playwire.

I.    Cookie and Similar Tracking Technologies – We endeavor to obtain consent for our placement of cookies, pixels and similar tracking technologies as required under the ePrivacy Directive as implemented throughout the EEA. As Playwire does not have direct relationships with Internet users in many cases, we ask Publishers and other partners to obtain a consent on our behalf as described below.  Where we directly place cookies (e.g., via Playwire.com) we directly obtain the consent from data subjects we’ve identified as being from the EEA or other place where consent is required.

II.    Usage Data and Profile Information – While we obtain a consent for our placement of cookies as described above, Playwire processes Usage Data and Profile Information under our legitimate interest. For purposes of clarity, where this data is utilized for analytics, targeted advertising, measurement or reporting, we also process it via legitimate interest. To offer additional transparency, we endeavor to mention some of these use cases in the consents obtained for cookies and pixels.

III.    Website Data – We collect personal data via Playwire.com. Where that data is provided to Playwire (e.g., via completing an online form), we consider it either Account Data and/or data collected pursuant to a Business Relationship which are described below. Where we place cookies via the website, we use consent. Where data is collected automatically (e.g., log files containing IP addresses), we process such data via our legitimate interest and in order to maintain the website and help us to a better job of personalizing the website to the interests of visitors.

IV.    Account Data and Business Relationships – We require some Publishers to setup an Account with Playwire. Similarly, we maintain accounts containing personal data with most of the vendors who provide services to Playwire, our customers, our employees and our business partners. If you are an employee of one of those entities, Playwire may have your personal data including your name, your work email or your work telephone number. For data subjects located in the EEA or UK, we process this data under the legal basis of contractual necessity. In other words, we need to process this data in order to honor the terms of the contract between Playwire and the Publisher, customer, vendor, etc. This includes maintaining an account and login credentials, billing and payment purposes, communicating with the other party, and fulfilling requests. Where we are seeking to market additional products and services to these entities, we will do so via legitimate interest unless applicable law dictates that we use consent (e.g., for email marketing).

V.    General Purposes – There are a number of instances where Playwire processes personal data which are distinct from the descriptions provided above. For example:

A.    Legal and Regulatory Compliance – Like most companies, Playwire will process data in order to comply with law, cooperate with requests from competent legal authorities such as the police, and to pay taxes. The legal basis for this type of processing is necessary for Playwire to meet our legal and regulatory obligations.

B.    Enforcement of Legal Obligations – To enforce our terms and conditions, protect of our intellectual property and/or the rights of third parties, Playwire processes personal data in these instances via our legitimate interest. This may include obtaining advice and conducting legal proceedings.

C.    Sell and Promote Our Business – Playwire may choose to conduct, evaluate and/or promote the sale of our business via our legitimate interest.

D.    Aggregated Data – Where we aggregate data and remove digital identifiers (e.g., cookie IDs), we may use this data for internal research, marketing, and statistical analysis purposes.

E.    UK and EU Data Subject Rights.  Where the GDPR or UK Data Protection Act applies, such data subjects have certain rights, including: a) The right to be informed about the types of data being processed and the legal basis for processing; b) the right to access and see the data being processed; c) the right of rectification, to make corrections to data subject to processing; d) the right to erase data; e) the right to restrict processing of data; f) the right of data portability; g) the right to object to the processing of data and f) the right not to be subject to automated decision-making. Some of these rights apply only in certain circumstances and depend on the legal basis relied upon to process the data. As an example, the right to object applies to processing which is carried out because it is necessary for our legitimate interests and only if we cannot demonstrate compelling legitimate grounds which outweigh your rights, interests and freedoms. The same right does not apply to processing which is necessary for us to comply with our legal obligations or to perform a contract with you. Given that both the UK Data Protection Act and the GDPR defines personal data broadly, these rights may extend to the personal data we place into cookies or similar tracking technologies.
Where processing is based on your consent, in accordance with the GDPR and UK Data Protection Act (as applicable), you may withdraw that consent at any time, although any processing previously carried out will still be legal. In order to exercise your data subjects’ rights or if you have any questions about these rights, you can write to us at gdpr@playwire.com . We will endeavor to respond to any requests to exercise your rights within one month from when they are made, although this period may be extended in some cases in which case we will inform you before the expiration of the one month period.

You also have the right to submit complaints to the supervisory authority in your jurisdiction. A list of supervisory authorities in the EEA can be found here: https://edpb.europa.eu/about-edpb/board/members_en.

F.    Cross-border transfers of EU or UK Personal Data.  We generally process data in the United States. When we share data, we provide data to companies globally. In each case, we have safeguards in place which allow those transfers to happen in a way that ensures data is handled in accordance with the applicable law. 
When we transfer personal data outside the EEA or UK, unless the recipient or location to which the data is transferred has been approved by the appropriate authorities as providing an adequate level of protection for personal data, we put in place measures to ensure that the transfer complies with the applicable data protection law and that the personal data which is transferred is appropriately safeguarded.

G.    Data Protection Officer.  Playwire has appointed a data protection officer to supervise our personal data processing-related activities, and to respond to requests as required.  Our Data Protection Officer can be contacted as follows: gdpr@playwire.com

7. CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

1. Overview of California Consumer Privacy Laws

This California Privacy Policy applies only to California consumers (“you” or collectively as “consumers”) and supplements the Playwire Privacy Policy (collectively, “we,” “us,” or “our”). The California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”), collectively referred to as “California Consumer Privacy Laws”, provide California consumers with specific rights regarding their personal information. This California Privacy Policy describes a California consumer’s privacy rights under the California Consumer Privacy Laws, explains how you may exercise your privacy rights, and provides an overview on the types of personal information we collect.

2. California Consumer Privacy Laws provide you with the following rights:

• Right to know. You have the right to know what categories and specific pieces of personal information we collect about you; the categories of sources from which we collect personal information; our business or commercial purpose for the collection, use, and sharing of your personal information; any categories of third parties with whom we share your information; and the specific pieces of personal information we have collected about that consumer
• Right to delete. You have the right to request that we delete the personal information that we collect about you.
• Right to opt out. You have the right to opt out of the sale or sharing of personal information. If we sell any of your personal information, you have the right, at any time, to tell us not to sell your personal information. You also have the right to request that we do not share your personal information.  If you wish to exercise these rights, please see our  Do Not Sell Or Share My Personal Information opt-out page.
• Right to correct. You have the right to request the correction of any inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.  We will use commercially reasonable efforts to correct the inaccurate personal information as you may direct.
• Right to limit use or disclosure of sensitive personal information (“SPI”). You have the right to limit the use and disclosure of your SPI, if we are using your SPI beyond what is reasonable and proportionate to provide the requested goods or services.   We do not collect SPI.
• Right to nondiscrimination. If you exercise any of your privacy rights, we will not discriminate against you.
• Notice of Financial Incentives. California Consumer Privacy Laws allow us to provide financial incentives for collecting, selling, or retaining your personal information.
• Right to know how long we retain your information. We will retain your information as long as it is reasonably necessary for each disclosed purpose, as outlined in the tables below. If you have any questions or would like to exercise any privacy rights, please contact us.

3. Information We May Keep. California Consumer Privacy Laws allow us to keep your personal information that we need to provide you with goods and services, ensure the security and integrity of your personal information, fix any errors, exercise free speech, use your information lawfully for our internal purposes, and to comply with the law.

4. Contact.  California Consumer Privacy Laws allow you to exercise your privacy rights and request your information from us, at no cost. We will provide our response in a readily usable format, which is usually electronic.  If you would like to exercise any of your privacy rights, please contact us through any of the following:

by writing to:    

Playwire, LLC
Attn: Privacy
4855 Technology Way
Suite 500
Boca Raton, Florida 33431

by email: legal@playwire.com

5. Verification of Your Identity. To protect your privacy, we will ask you to verify your identity. We will ask you to confirm your name, email address, phone number and other information so that we can reasonably confirm your identity. We will not share any information until we can reasonably confirm your identity.

6. Our Response Time to Your Privacy Request

• Response Time. We will respond to your verifiable consumer request (“VCR”) within forty‐five (45) days from when you contacted us.
• Response Time for Complex Requests. If you have a complex VCR, state privacy laws allow us up to ninety (90) days to respond. We will still contact you within forty‐five (45) days from when you contacted us to let you know we need more time to respond.
• Our Response.  Our response will cover the 12-month period preceding the business’s receipt of the VCR. A consumer may request that we disclose the required information beyond the 12-month period (limited to personal information collected on or after January 1, 2022), and we will provide that information unless doing so proves impossible or would involve a disproportionate effort. Note that there is no obligation to provide this information to the same consumer more than twice in a 12-month period.

7. Authorized Agent. California Consumer Privacy Laws allow you to ask someone else to exercise your privacy rights for you. This person is your “Authorized Agent.” Before we will share anything with your Authorized Agent, you will need to provide your written permission or other proof, such as a valid Power of Attorney. Please contact us if you would like us to know who your Authorized Agent is.  Once we have your written permission, we will also ask your Authorized Agent to verify their identity with us directly. We will not share any of your information with your Authorized Agent unless we have both your written permission and have verified the identity of your  authorized agent.

8. Information Collection and Use- Sources of Information. Please refer back to https://www.playwire.com/privacy-policy.  To help consumers make informed privacy decisions, the California Consumer Privacy Laws create and define categories of personal information. Some types of personal information may apply to multiple categories. We collect the categories of personal information described in Table 1 below. Depending on your level of interaction with us, we may not have collected your personal information from all of the categories.

9. Business Purposes Of The Personal Information We Collect And Sell.  Table 2 is a list of the categories of personal information we disclosed about consumers for a business purpose in the preceding 12 months.

10. Categories Of Personal Information We Sell Or Disclose For A Business Purpose

Table 3 below describes the categories of personal information we sell or disclose for business purposes. These are also the categories of information we sold in the past 12 months.  The sources for each category of personal information we collect, the business or commercial purposes for which we use each category of personal information, and the third parties with whom we may share your personal information with.

Playwire collects the personal information described above for a variety of business and commercial purposes.

For Ad Services, we use the personal information collected to provide our services; serve ads; provide information and reports to Media Buyers; prevent End Users from seeing the same ad too many times; customize and personalize ads; analyze ad performance; deliver Internet-based and location-based advertising; detect and prevent fraud and protect the security of our Ad Services; provide, manage and improve our Ad Services and develop new services; calculate usage levels of our Ad Services, help diagnose server problems and administer our Ad Services; and as we believe to be necessary or appropriate, such as to comply with legal requirements.

For Playwire properties, we use the personal information collected to send marketing and promotional communications; send administrative information; engage in and process transactions; post testimonials; provide interest-based advertising and engage in analytics on your activity on the Playwire Properties and other websites over time; manage accounts and provide customer support or other services; improve the content and quality of Playwire’s Properties and Ad Services; for legal purposes; and for our business purposes, such as to evaluate and improve our products, services, marketing, and client relationships. 

Categories of Third Parties to Whom We May Disclose or Sell Personal Information

We may disclose any of the personal information we collect for our business purposes, or sell the personal information, to the following categories of third parties:

• Playwire’s Publisher Clients
• Media Buyers & Planners
• Playwire’s other clients including advertisers, brands, agencies, and other third party advertising partners
• Attribution and Analytics Partners
• Playwire’s vendors, consultants, and other service providers
• Website advertising parties

8. SPECIAL NOTE REGARDING CHILDREN UNDER 13 YEARS OF AGE

1. Use of the Playwire Sites is not intended for minors under the age of 18 (“Minors”). Minors are not authorized by Playwire to use playwire.com, even if Minors set up an Account or accept the terms of any agreement for Playwire Sites. Parents or guardians may authorize Minors between the ages of 13 and 17 to use the Playwire Sites, provided they assume all responsibility and legal liability for the conduct of such Minor including, without limitation, monitoring the Minor’s access and use of the Playwire Sites.  Note that Playwire does work with Publishers who have their own sites that are intended for Minors and have their own separate privacy policies.
2. Playwire does not intentionally collect nor maintain any personally identifiable information from Minors. If you discover your Minor child has submitted his/her information to Playwire, you may request to have such information deleted from Playwire’s database by sending an email request to legal@playwire.com together with the e-mail address that was submitted by the Minor. Upon receiving the request, Playwire shall delete such information within twenty (20) business days. If Playwire learns that a Minor is using the Playwire Sites, Playwire will require verified parental or guardian consent, in accordance with the Children’s Online Privacy Protection Act of 1998 (“COPPA”). To learn more about COPPA, consult this simple one-page informational guide from the kidSAFE Seal Program: //www.kidsafeseal.com/knowaboutcoppa.html

9. CHANGES TO PLAYWIRE’S PRIVACY POLICY

Playwire continually strives to implement new technologies and processes to better protect you, your privacy and your use of the Playwire Sites. As a result, changes to this Privacy Policy may be made by Playwire from time to time. If we make changes, we will post them here and update the date above. If we make material changes to this Policy, we may take additional measures to notify you and, if necessary, gain your prior consent. In no event will these changes result in the degradation of any of the security measures designed to protect you from unauthorized disclosure, as such measures are described in this Privacy Policy.