Last Updated – November 30, 2023

Who We Are

TStack Inc (“TrustedStack,” “we,” “us,” “our”) is an advertising technology company. We use our platform and technology to assist websites and their business partners with the selection, delivery, and display of advertising on digital media properties (“media properties”). We also provide services that allow advertisers and their representatives and business partners (collectively “advertisers”) and media properties to find each other and connect. Media partners and advertisers can both be our “clients.” This privacy policy applies to this website and to the services we provide.

Notice at Collection

We collect personal information through this website and through our services. Personal Information (sometimes called “personal data”) includes information that identifies you directly, like your name and email address (“personally identifiable information” or “PII”) and information that does not identify you, but is linked to you, or could be combined with other information to identify you (“device identified information” or “device information”).

Information We Collect	How We Use the Information
Contact information	We use contact information such as your email address to communicate with you, to fulfill requests, and to maintain business relationships. We may also use it to inform you of other products and services.
Internet Protocol Address (IP address)	We use the Internet Protocol address (or IP address) associated with your device to help media properties request advertisements to display to you, to help advertisers deliver ads to you, and to determine your general geographic region.
Information about your web browser or your connected device	When you interact with our website or a media property that is using our services, we receive information about your browser and/or device. We use this to help ensure that advertising is displayed to you in the right way for you to view it.
User IDs (including cookies and Mobile Ad IDs)	We use unique identifiers for ad delivery, to ensure ads are not shown to you too often, to detect fraud, and even to track your choices about use of your personal information. We also use them so that we can compile aggregate information for reporting and analysis of our services and the performance of advertising. We use reporting and analysis to account to media properties and advertisers, and to improve our services.
Media Property Information	We receive information about the web page URL or application you are viewing, the page or application you were on when you navigated to the media property, information about formats for advertising on the page and the types of content or advertising you view on the page.
Online Activity, or “Web Usage” information	When you visit our website, and sometimes when you visit a media property where we provide services, we receive information about which content and advertisements you view. If a media property, advertiser, or business partner collects information about other website and apps you have visited, we receive that or an analysis of that, in order to provide relevant advertising.
Third party information	When media properties instruct us to do so, we may receive information from third parties, such as demographics information like your estimated age, and information about your behavior and interests, to help them request advertising that is relevant to you.
Choices you make	We use information about the choices you make in order to honor your preferences. For example, when you opt of targeted advertising, opt out of sale or sharing of your personal information, or exercise other rights you have under applicable law, we use the personal information we receive with your request only for this purpose.
Business contact information or other PII	When you communicate with us for any reason, including expressing an interest in our services, or to initiate or continue a business relationship, we receive your contact information to respond to your request or provide services.
Information about email delivery and receipt	We use information about whether you open our email messages to determine what interests you and to improve our email marketing

We work to maintain your trust. We use fair information practices designed to respect the rights and privacy of visitors to our website and to media properties where we provide services (“users”). The websites on which our services are used also have their own privacy policies, which may be different from ours.

You can click on the topics below to learn more about our collection, use and protection of your
personal information and to understand your choices.

Detailed Privacy Policy

Personal Information We Collect

We collect the following information when you visit our website or media properties where we provide our services.

Information about your browser and device. As noted above, this information, called Device Information, does not, by itself, directly identify you, but it is communicated when you visit a website. This information includes:

Your Internet Protocol address, or IP address. We receive the address of your device on the Internet, known as the IP address when you navigate to a web page or application. This allows content and advertisements on a web page to be delivered and displayed to you.

The type of browser you are using, if applicable (for example, Microsoft Edge, Google Chrome, Firefox or Safari). We also learn the language you are using to communicate. This helps us understand how you view content and advertising.

The type of device and operating system you are using (for example, smart phone or computer, windows, iOS, or android).

We also collect identifiers that media properties and advertisers associate with your browser or device to help us provide our services. These include:

Cookie IDs or other (non-cookie) user IDs that are specific to your web browser or device but do not directly identify you. These may include hashed email addresses mobile advertising IDs, unique platform IDs, and other types of identifiers. You can learn more about cookies here.

Media Property Information. We receive the web page URL or application you are viewing, the page or application you were viewing when you navigated to the media property, information about formats for advertising on the page you are visiting, and the types of content or advertising you view on the page.

Web Usage Information. We sometimes receive information about your activity on a website or app, or across different websites or apps. This includes information about content and advertising you view.

Third Party Information. When instructed to do so by media properties or advertisers, we obtain demographic and other general information about users (for example estimated age) and their interests and activities to determine which advertisements may be most relevant to them.

Click IDs are identifiers that are added to your browser when you click on an advertisement.

No Sensitive Information. We ask media properties and advertisers not to send us any sensitive information about you. If we receive information from your visit to a web page that includes content about sensitive health conditions, we do not use device information from that page to draw inferences about you or build profiles of you for targeting advertising. We discard the information in accordance with our Data Retention Policies. However, we may collect and use non-sensitive health information, for example, information that you viewed or searched for content about fitness or nutrition.

No Personal Information about Children. Our services are intended for use by other businesses, and our website and services are not directed to children or used for advertising to children. We do not knowingly collect any personal information from children under 18.

Your Choices. When you exercise your rights to opt out of sale or sharing, opt out of targeted advertising, or request a deletion or correction, we receive some personal information about you, depending on how you communicate with us.

Information you provide, including business contact information or other PII. When you communicate with us by email to ask a question or seek information about a possible business relationship, and when we actually provide services to you, we receive your email address and other PII.

Information about email delivery. We collect information about whether marketing emails and other messages we send are opened.

How We Use Your Personal Information

We use your IP address to ensure the right ads are delivered to you and to determine your general geographic area (such as the metropolitan area you are visiting the website from). Knowing your geographic area helps us deliver advertising relevant to that area and comply with applicable laws, including by offering you the choices to which you are legally entitled.

We use other information about your browser or device to help ensure the ads delivered to you display properly and to analyze the ways in which our services are accessed so that we can maintain and improve our services.

We use cookie IDs or similar assigned identifiers and tools (including mobile advertising identifiers) to collect information about your online activity. This includes recognizing your device if you have visited our website, or visited a media property, before. We use cookie information to ensure the same ads are not delivered too often to the same users, to prevent fraud by identifying automated and malicious activity, and to learn about your interests for “interest-based advertising” or “behavioral advertising.” This includes your interest in non-sensitive health-related information, for example, providing information about health care providers when you search for them, or providing information about nutritional supplements when you view nutrition websites, and information about workouts when you visit fitness websites. Advertising based only on the content of the page you are viewing, or the search results you obtain, is called “contextual advertising.”

We use information about your activity on our website that is collected by Google Analytics on our behalf, and their analysis of that information, to better understand our customers’ use of our website so that we can maintain and improve it.

We use all the device information and web usage information we collect to better understand and report on the performance of our technology and services and to improve them. We also use third-party information to select relevant advertisements for you based on inferences about your needs and interests.

We use information about your choices to ensure that we act on them. For example, if you opt out of the sale or sharing of your personal information, we use your preferences to ensure that we do not disclose your personal information to third parties who have independent rights to use the information for their own purposes. We do not use this information for any other purpose.

We use information you provide to us, including your email address, to respond to you or to offer or provide business services.

We use all this information to maintain and improve our services and to exercise and defend our legal rights when necessary. We also use all of this personal information to respond to government and user requests when required to do so, and to assist our clients and partners in responding to these requests when we are obligated to assist.

How and to Whom We Disclose (Sell or Share) Personal Information

We may disclose personal information for valuable consideration (for example, when we provide services to media properties and others) in a way that some U.S. states consider a “sale” of personal information. We may also disclose personal information in ways that are not considered a “sale.”

When you visit our website, and sometimes when we provide services to media properties, we disclose the information we collect from your browser or device to service providers who assist us in providing services, but are not permitted to use this personal information for their own or other purposes. We also share information collected on our website with our analytics partners, including Google Analytics.

We share information about the interaction of your browser or device with content and advertisements, and your interaction with search services, with media properties and advertisers so that they can determine whether certain advertisements are likely to interest you and can decide whether they want to present those ads to you. We also share personal information with media properties and advertisers in order to report on how we provide the services and how effectively advertising performs. Some of this reporting is in aggregate form that does not require sharing any personal information.

We share some additional information, such as cookies or similar IDs, with media properties and advertisers to help them manage ad selection and delivery for the purpose of ensuring that you see ads that make sense in the context (on the page) where you are viewing them, and don’t see ads too many times.

When we share device information with third parties and service providers, we contractually require them to post privacy policies that describe their own practices, and to comply with applicable privacy laws.

As we discuss below, if we receive notice of choices you make when you visit a media property on which we provide services, we will act on that information and pass it on to the third parties and service providers who work with us, requiring them to honor certain choices also, such as your choice to opt out of sale or sharing.

We do not knowingly sell or share the personal information of children under 18.

We also share personal information with government or law enforcement authorities to protect the personal safety of users, employees, or others.

Generally, we disclose personal information when we determine that we are required to do so in order to

• Comply with applicable laws, or with valid legal process;
• Protect or defend our rights or the rights of our users or business partners;
• Enforce our agreements with users or business partners;
• Protect anyone’s rights, property or safety (including ours).

If we are involved in a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of a bankruptcy, we will share personal information with an acquiring entity and its advisors.

Sources of Personal Information

We collect information from

• Your interaction with our website or the websites or search results pages where we provide advertising;
• Cookies, pixels, web beacons, SDKs, and other technologies used to gather information about a browser or device and its interaction with content and advertising;
• Media properties and advertisers share information about advertising opportunities and rates with us to so we can assist with the process of communicating to each of them and putting relevant (contextual or behavioral) advertising in front of you;
• Emails and webforms that express your choices about exercising your rights;
• Contact information in email, through social media, or in contact forms that express interest in our services;
• Other business information through business exchanges via email or otherwise;
• Third party data providers that license data to media properties and advertisers sometimes license it to us, or we receive demographic information from our clients and partners;
• Clear gifs (web beacons) in email messages we send, which we use to determine whether you open the emails.

Cookies and Other Identifiers

Cookies are small pieces of code stored on your browser that can allow information about your online activities to be stored on your browser and communicated to websites and others. Some cookies are necessary to allow web pages to properly display the information you want. You can reject other cookies by changing the settings in your browser, but if you do this some choices stored in cookies may also be lost.

Advertisements selected, delivered, and displayed through the use of our services, and websites where our services are used, may deposit cookies. We do not have information or control over information collected by third parties through their cookies.

For information about how to control the use of cookies and mobile identifiers to collect and store personal information for interest-based advertising, see Your Rights and Choices below.

For more information about cookies, including how to see what cookies and other tracking tools have been set on your device and how to manage and delete cookies and other trackers, visit www.allaboutcookies.org and www.youronlinechoices.eu.

Your Rights and Choices

Depending on where you live and where you access our services, you may have the right to request that we:

• Tell you how we use your personal information;
• Give you access to, and a copy of, personal information we store on our system;
• Update, correct, or delete your personal information held in our files;
• Stop using, and require that third parties stop using, some or all of your personal information for certain purposes, even if you continue to use our site or services; and
• Discontinue contacting you by phone or by email.

You may exercise these rights by submitting a privacy rights request here or by emailing us at [email protected] or through the webform on the page that describes rights for a U.S. state.

Some of our services are used to deliver interest-based advertising. We are a member of the Network Advertising Initiative (NAI), a U.S. self-regulatory organization of third-party advertising technology companies that provides detailed guidance to assist members in complying with privacy laws, and offers a choice mechanism for opting out of interest-based advertising. You can opt out of the collection and use of your personal information by us and other NAI members for interest-based advertising at www.networkadvertising/choices, www.networkadvertising.org/mobile-choice, www.aboutads.info/choices in the U.S. You can find out more about cookies and opt out at www.youronlinechoices.com in the European Union (EU) and United Kingdom (UK).

Please note that for all choices you make about the use of cookies, if you then switch to a different web browser or computer, or you clear, block, delete or restrict your cookies after opting out, you may need to repeat your choices. Mobile phones and other mobile devices allow you to limit tracking using mobile IDs through the device settings. Note that if you delete cookies but do not change mobile settings, personal information about your online activities may still be used for personalized advertising on mobile devices.

Consumers from certain U.S. states have specific rights and choices available to them. You can get more information about these specific rights and exercise your choices here.

Universal Opt-Out Signals

We honor certain universal opt out signals, including “Global Privacy Controls” that can be set in some browsers where we are required to do so by applicable law.

Do Not Track

We do not honor “Do Not Track” signals that do not meet the requirements of universal opt out signals in the applicable jurisdiction, or where we are not required by law to honor them.

Google Analytics

We use Google Analytics for site analysis. For more information about Google Analytics go to http://www.google.com/policies/privacy/partners (“How Google uses data when you use our partners’ sites or apps”). Users who don’t want their data collected and disclosed to Google Analytics can install the Google Analytics opt-out browser add-on. To opt out of Google Analytics, go to https://tools.google.com/dlpage/gaoptout .

Data Retention Practices

We retain your personal information only for as long as we need it.

We retain information from advertisers and from business partners for up to a year after we end our business relationships with them, unless we have a valid legal reason to retain it longer.

We retain personal information for up to 24 months.

We retain aggregated information (which is no longer considered personal information) for reporting and analysis for 1 year after the end of a business relationship, unless we are legally or contractually required to keep it longer.

We retain personally identifiable information you provide through business communications as long as our business relationship continues, and in some cases longer if we need to retain it to exercise our legal rights or defend legal claims.

Data Security

No information security is perfect, but we use commercially reasonable efforts and rely on technical and operational measures common in our industry to protect personal information and keep it secure. These methods include encryption, limiting access to personal information to those who need to know it, and limiting how long we retain information.

We expect the Services to include features that will help us track down bugs and crashes; some of these features will include reports that are generated by our users’ devices, and these reports include information about device type, capabilities, and other software running at the time of the crash. You will have the choice of whether or not to provide this information to us, and it will always be provided to us without being associated directly with your identity. We will use this information for our development, debugging and other quality improvement efforts.

Children

Our services are primarily intended for use by other businesses, and our website and services are not directed to children or used for advertising to children. We do not knowingly collect, use, sell or share any personal information of children under 16.

International Users

General Information. Our Services are provided in, and are directed at, users from the United States. Information we maintain may be stored both within and outside of the United States. If you live outside of the United States, you understand and agree that we will process your information in the United States, which may not provide the same level of protection for your personal data as the laws of other countries. When another company transfers personal data to us from the European Union, we agree to protect it as if it were protected under the General Data Protection Regulation (GDPR).

International users should know that the controller of the Trusted Stack website is TStack Inc. If you have a question or complaint, you can contact our privacy office as described in the “contact” section of this privacy policy.” European users can also contact their local data protection authority.

Our EU-GDPR Representative is:

Rickert Rechtsanwaltsgesellschaft mbH
– TStack –
Colmantstraße 15
53115 Bonn
Germany
[email protected]

Our UK-GDPR Representative is:

Rickert Services Ltd UK
– TStack –
PO Box 1487
Peterborough
PE1 9XX
United Kingdom
[email protected]

Legal Basis for Processing. In the European Union, we rely on three different legal bases for processing data– consent, legitimate interest, and contractual requirements.

If you are in the European Union, we obtain your consent before we place cookies or other tracking technology on your browser or device. When we provide services that assist in the delivery of personalized advertising, we require that the websites where the advertising is displayed obtain your consent to the use of your personal information for this purpose first and provide evidence of that consent to us.

When we rely on our legitimate interest as the legal basis for processing personal information, we first weigh whether the risk that the processing poses to data subjects outweighs the benefits we obtain by processing the data. If we are not able to reduce the risk to the data subject sufficiently, or the benefit of the processing does not outweigh it, we do not process the personal information.

We rely on our legitimate interest when we use limited information (such as the content on the page where an ad appears), without developing a profile of data subjects, to assist in ad selection and delivery. We do not believe that the use of this general information, which is not used to create a profile of you, presents a substantial risk to you and it permits us to provide advertising you may find relevant based on the content you are viewing. When a website relies on its legitimate interest to present advertising to you and it communicates that it relies on that legal basis to everyone involved in ad delivery, we too rely on legitimate interest to provide services to that website.

We also rely on legitimate interest to determine how many times an advertisement has been presented to you (so that you do not see it too often) and to detect fraud. There is little risk to you from the limited use of data in these processes compared to the benefit of maintaining the integrity of the advertising process.

We rely on contracts or potential contracts as the legal basis for processing the business contact information of our business partners and potential partners.

Participation in the advertising industry Transparency and Consent Framework. We participate in the IAB Europe’s Transparency and Consent Framework (“TCF”), which allows you to better understand who is providing advertising services to you on the websites you visit, and gives you choices about who can process your personal information. We are a registered vendor (1288) on the IAB Europe’s Global Vendor List (GVL).

Changes to this Policy

We may revise this policy from time to time – e.g., to keep up with changes in the law, or to reflect changes in how we are doing business. All Services that are governed by this policy will always include our most up-to-date privacy policy, and we include an effective date at the top of the policy, so you can quickly see when we last updated the policy. We will always include links to previous policies so that you can compare them. Any updates or modifications to this privacy policy will be effective as soon as we post the updated privacy policy to the Services unless we say otherwise, and it is your responsibility to review this privacy policy periodically to make sure you continue to agree to all of its terms.

Material changes to this policy will not apply to information we have already collected unless we receive your consent for them to do so.

Contact Us

We provide our users with a number of ways to contact us, so that they can reach us with their comments and questions. Our website has a “Contact Us” page that includes a contact email address and may also include a message form that you can complete in order to contact us directly from the website. You can also contact us through any social media pages we maintain, as well as other business networking platforms. If you communicate with us by email, even if you have not previously provided us with your email address, we will use your email address if necessary, in order to respond to you, and we may retain your email address in our files during and for a period after the time that we are in communication.

You can contact us at:

[email protected]

TrustedStack
442 Fifth Avenue, # 2707
New York, NY 10018

Please write Privacy in the subject line of any communication.

U.S. State Privacy Rights and Choices

If you are a California consumer, you have the right to:

• know what information we have collected;
• ask us to delete your personal information;
• ask us to correct personal information if you believe we are keeping inaccurate information about you; and
• opt-out of the sale or sharing of your personal information, including by sending a GPC signal from your browser.

We will not discriminate against you in any way for exercising these rights.

You can exercise these rights by emailing us at [email protected]. You can also make your request here. If you have a business account with us, we may use information in that account to authenticate you.

For certain requests (requests to know or correct the information we maintain about you) we may email you to confirm your identity. If we cannot confirm your identity for a request to delete information, we will treat it as a request to opt out of sale and sharing. An authorized agent may make requests on your behalf, but we will request proof that you gave permission for that agent to act for you.

If you are a Virginia, Connecticut or Colorado consumer, you have the right to

• Confirm whether or not we are processing your personal information and access your personal information;
• Correct inaccuracies in your personal data and the purposes for which we are processing it;
• Delete your personal information;
• Obtain a copy of personal data you have previously provided to us;
• Opt out of targeted advertising
• Opt out of the sale of your personal information;
• Opt out of profiling that would be used for significant decisions about you.
• If and when global privacy controls or other universal opt-out mechanisms are approved and honoring them is required in your state, you will also have the right to opt-out of sale, targeting, or profiling, or all of these, using these browser-based controls.

For certain requests, we may email you to confirm your identity. You can email us at
[email protected] or make your request here.