EU ePrivacy Directive and Privacy Choice Signaling Policy

Last updated: June 1, 2023

If your agreement with Lotame incorporates this policy, or you otherwise use a Lotame service that facilitates the collection of Personal Data from end users in the in the European Union, the European Economic Area, and the United Kingdom, you must ensure that:

• certain disclosures are given to, and consents are obtained from, your end users; and
• signals indicating choices end users make regarding the processing of their personal data are transmitted to Lotame via the IAB Europe TCF 2.0 specification or with Lotame’s approval, via Lotame’s proprietary Consent API.

If you fail to comply with this policy, we may limit or suspend your use of the Lotame service and/or terminate your agreement.

1. Properties under your control

If you use Lotame’s services on any website, app or other digital property that is under your control, you must obtain end users’ legally valid consent to:

• the use of cookies or other local storage; and
• the collection and use of Personal Data by Lotame to:
  • Create and use profiles for use in advertising and content personalization,
  • Measure advertising and content delivery performance,
  • Generate audience insights
  • Match and combine online and offline data sources, and
  • Link different devices.

Lotame requires consent as the legal basis for all of its processing activities. When seeking consent you must:

• retain records of consent given by end users; and
• provide end users with clear instructions for revocation of consent.

You must clearly identify that a third party is collecting and processing the end users’ personal data as a consequence of your use of Lotame’s Services. You must also provide end users with prominent and easily accessible information about the use of end users’ personal data.

2. Properties under a third party’s control

If an end users’ personal data from a website, app or other digital property that is not under your control, including those of your affiliates or your clients (each a “third party property”), is shared with Lotame due to your use of Lotame’s services, then you must ensure the operator of that third party property complies with the duties in Section 1 above.