MIRROR DIGITAL CONNECTS YOU TO THE GROWING U.S. MULTICULTURAL MARKET THROUGH OUR NETWORK OF SOCIAL MEDIA INFLUENCERS, BOUTIQUE DIGITAL PUBLISHERS AND BLOGGERS NATIONWIDE.
MIRROR DIGITAL IS A LEADING PROVIDER OF INTERACTIVE MEDIA AND THE AUTHORITY ON THE MULTICULTURAL DIGITAL ECOSYSTEM
OUR CAPABILITIES INCLUDE
Last Updated: September 19, 2018
Mirror Digital provides our advertiser clients with the ability to purchase targeted advertising campaigns through our premium, multicultural distribution network. Our service was designed to protect the privacy of our advertiser and publisher clients, and the consumers who are served ads through the service. We believe that privacy is a right, and that you have a right to keep it private. Our goal is to be transparent about how we collect and use information about you, to keep such information secure, and to provide you with meaningful choices.
What this policy covers:
Mirror Digital, Inc. (“Mirror Digital”, “we”, “our”, or “us”) is a Delaware corporation located in the United States of America. We provide premium, high impact advertising products and services and leading campaign management, helping advertisers target the growing multicultural market through our network of social media influencers, boutique digital publishers and bloggers using online advertising (“Service”).
The Service is designed to display the ads of our clients to consumers who are likely to find those ads interesting. Our goal is to make advertising more relevant and useful to consumers by showing them ads that are based on their specific interests. These ads are displayed on websites and applications which rely on advertising revenue to support the free content we consume every day.
The Service is hosted in the United States, and is not directed to individuals under the age of sixteen (16). Mirror Digital does not knowingly collect information from individuals under sixteen (16) years of age without prior parental consent or consistent with applicable law.
People have different privacy concerns. We believe you should have tools to control information about you and manage your experience with us. For example, consumers who are served ads through the Service may opt out of interest-based or targeted advertising at https://adssettings.google.com/authenticated?hl=en. Please note that if you opt out of receiving interest-based or targeted advertising, you will continue to see the same number of ads, but they will be generic in nature, and may not be as relevant or useful to you.
You can also learn more about interest-based or targeted advertising and ad serving companies and opt-out capabilities at the Network Advertising Initiative Website, Digital Advertising Alliance Website, Digital Advertising Alliance of Canada, TrustArc, European Interactive Advertising Digital Alliance, and Your Online Choices. Please note that these opt-outs operate by placing an opt-out cookie on your device that is unique to the browser and device you used to opt-out. They may not function properly if you configured your browser to reject certain cookies. If you change browsers or computers, or delete the cookies on your computer, you will need to opt-out again. You also may be able to set your browser to notify you when a cookie is being set and to block most cookies. Your mobile device may give you the ability to opt-out of interest-based advertising (“Limit Ad Tracking” on iOS devices or “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices).
We collect information to better provide the Service to our advertiser and publisher clients, which includes offering a premium digital advertising network, enabling the purchase of targeted advertising, measuring advertising performance, and providing related research.
We may collect and combine information when you interact with the Service, including:
We do not collect any “sensitive” or “special categories of personal data” as defined under European data protection laws.
We use the information collected to provide the Service. For example, we use the information collected for the creation and purchase of targeted advertising campaigns. Such information may be used by itself, aggregated, or combined with other information we collect or from a third party. We may also use information collected to deliver you information and/or promotional materials about Mirror Digital and/or to carry out other purposes that are disclosed to you, and to which you consent.
We may also use the information collected for the following purposes:
We may share the information collected as follows:
Advertisers and Publishers: We may share information collected with our advertiser and publisher clients and third parties, including business partners such as advertising-related companies who are obligated to comply with applicable laws concerning usage of the information, as well as our corporate affiliates, in connection with the Service (such third parties and affiliates collectively, “Affiliates”). In addition, our Affiliates may share this information with their own third-party business partners who may use the information either for themselves or on behalf of the applicable Affiliate, each only for the purposes set forth in the section above headed How We Collect Information.
If you a resident located in the European Economic Area (“EEA”), our legal basis for collecting and using the information described above depends on the type of information concerned, and the specific context in which we collect it.
We may rely on our legitimate interest to collect information from you, except where such interests are overridden by your data protection interests or fundamental rights and freedoms. Where we rely on our legitimate interests to collect and process information about you, they include the interests described in the section above headed How We Collect Information.
However, in some cases, we may rely on your consent or have a legal obligation to collect the information about you, or may otherwise need the information to protect your and/or our vital interests or those of another person or entity. If we rely on your consent to collect and/or process information about you, we will obtain such consent in compliance with applicable laws.
If you have questions about or want further information concerning the legal basis on which we collect and use information about you, please contact us using the details in the Contact Information section below.
If you are a resident of a country in the EEA, you have certain rights and protections under the law regarding the collection, processing, and use of information about you. As set forth above, the information that we collect about you when you use the Service may include certain digital identifiers that are considered “personal data” under European law. We primarily process and store this data in the United States of America either as necessary to further our legitimate interest and/or pursuant to your consent.
As a resident of a country in the EEA, you have the right to: (i) request access to and obtain a copy of the information we collect about you; (ii) request rectification or erasure of such information; (iii) restrict the processing of such information; and (iv) if applicable, data portability with respect to such information. In certain circumstances, you may also have the right to object to the processing of such information.
If you would like to exercise any of these rights, please contact us using the details in the Contact Information section below. Please note that because most of the information we collect and maintain about you can only identify a particular browser or device, and cannot identify you individually, you may need to provide us with additional information to enable us to identify the information we have about you and ensure that we accurately fulfill your request. Although we use good faith efforts to respond to your request, we may not be able to provide and/or correct the requested information in all situations. For example, we may not be able to provide the information requested if it imposes an undue burden or expense, requires us to release confidential commercial information, or requires the disclosure of information relating to another person.
Finally, as a resident of the EEA, you have the right to lodge a complaint about our processing of personal data with a European Data Protection Authority. For contact details of your relevant local Data Protection Authority, please review the information located at: https://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
Our goal is to delete the Mirror Digital account information requested within 30 days of receiving your written request. If you close your Mirror Digital account, we will use reasonable efforts to ensure that information about you in the account such as your name, email or billing information is no longer accessible or used by the Service. However, as permitted by applicable law, we retain and may use information about you as necessary to comply with our legal and/or financial obligations, resolve disputes, enforce our agreements, and other legitimate purposes (including, for corporate governance, financial record keeping, document retention, and security purposes). Please contact us using the details in the Contact Information section below to close your Mirror Digital account or request changes or modification of the information you previously provided to us. Closing your Mirror Digital account does not affect ads you may receive on any of your devices.
Do Not Track (“DNT”) is a privacy preference that you can set in your browser that requests that websites and technology companies not collect certain browsing data. Currently, the standards regarding DNT and appropriate responses are not well defined. As such, Mirror Digital does not currently honor DNT settings in your browser.
Mirror Digital uses industry-standard physical, electronic, and procedural measures designed to safeguard the information in our possession against loss, theft and unauthorized use, disclosure, or modification. However, please note no transmission of information via the Internet or electronic storage solution can be guaranteed to be completely secure, although we take reasonable precautions to protect against security incidents.
We store information you provide to us (a) for as long as (i) needed to provide you the Service, or (ii) you have a business relationship with us, or (b) until you request that we delete your Mirror Digital account. We store the information collected about consumers who are served ads through the Service for 18 months before it is deleted, except that information collected regarding the ads served, including ad performance and attribution, are stored for 18 months before that data is anonymized and aggregated into summary reports.
In some cases notwithstanding the above, we may keep certain information for longer periods of time as permitted by applicable law, including to comply with our legal and/or financial obligations, resolve disputes, enforce our agreements, and other legitimate purposes (including, for corporate governance, financial record keeping, document retention, and security purposes).
You may opt-out of receiving promotional communications from us, by clicking on the “unsubscribe” link in the emails you receive from us, or by contacting us using the details in the Contact Information section below to have your contact information removed from our promotional email list.
Residents outside of the European Economic Area:
Mirror Digital, Inc.
Attn: Privacy Officer
448 S. Hill Street, Suite 508
Los Angeles, CA 90013
European Economic Area residents:
Mirror Digital, Inc.
Attn: Data Protection Officer
448 S. Hill Street, Suite 508
Los Angeles, CA 90013
Important note: The data controller of information about European Economic area residents is Mirror Digital, Inc. at the above address.