Effective date: 15 September 2020

This cookie policy (“Cookie Policy”) of UpscaleDSP OÜ (registry code 17091567), has been created to inform you about the use of cookies, and other means of data collection on our websites and any on our content distribution platform ( “Services”), which you may see on third party websites of our publisher customers allowing us to redistribute their content or the content of our advertiser customers (collectively, “Customers”). The term ‘cookies’ in this Cookie Policy, refers to both cookies and other automated means of data collection, as defined below. By visiting the Sites and interacting with or using the Sites, you expressly consent to the use of cookies as explained hereafter. We ask our Customers to obtain consent on our behalf, where required by applicable data protection laws, for us to use cookies and other automated means of data collection on their digital properties.

Our Cookie Policy does not govern the use of the Sites, nor the processing of Information (as defined in our Privacy Policy) collected on the Sites. For more information about how we process your Information on the Sites and when you make use of or interact with our Services, please refer to our Privacy Policy. Please refer to the websites of our publisher Customers where we place our pixels to learn more about how they may use cookies on their websites or platforms and process your Information that they may have collected.

1. Cookies and Automated Pixel Data Collection

Cookies

Cookies are a tool that websites use to remember user preferences and behaviors. A cookie is simply a bit of text containing a name and a value placed on the browser of the hard drive of your computer (or similar device) by websites that you visit. Cookies are used in order to make websites function more efficiently, and to provide information to the publishers of the website. Cookies make your use of the Sites and Services more relevant and improve the functionality of the services we provide.  Upscale Digital also uses cookies to tailor content and information that we display to you and personalize your experience while interacting with our Services. For more information about relevant advertisements delivered by the Services, please read about our Interest Based Advertisements within our Privacy Policy.

Pixels

With the prior permission from our advertiser Customers, we may place a pixel on their website. Pixels (also known as beacons or clear GIFs) are typically transparent graphic images placed on a website. Pixels and cookies are used in combination to measure the actions and behavior of visitors to their websites that arrive through the Services. For example, we may use pixel tags to track specific actions or to assist in the creation of custom audiences for specific advertiser Customers to target on our network (i.e. retargeting).  For more information about how we may create a custom audience for our advertiser Customers targeting, please read about our Interest Based Advertisements within our Privacy Policy

The specific cookies that we and our service providers use on the Sites and/or when providing our Services are set forth in section 3 below.

2. What Information Do We Collect?

• Cookies used on our Sites: 
  • The information we receive from our trusted business partners placing third-party cookies on our Sites may include information about your operating system, the web pages accessed within our Sites, the link that led you to our Sites, and the dates and times you accessed our Sites.  We may also use third parties who collect Information about Site Visitors through their own cookies, pixels, and other technologies regarding your online activities, either on our Sites and/or other websites across the Internet, in an effort to understand your interests and deliver you advertisements that are tailored to your interests. 

• Cookies used through Services: 
  • The information that we collect via cookies may include information about your operating system, the web pages accessed within the websites of our Customers, the website that led you to our Customers’ websites, the dates and times you accessed our Customers’ websites or platforms, actions, and general location information.

Where any of the information addressed previously, alone or combined with other information, would constitute Personal Data under applicable laws, our Privacy Policy will apply to the processing of such information.

3. What Cookies Do We Use and Why?

• We use the information collected via third party cookies on the Sites to track and/or analyze your activity on the Sites, or to deliver you advertisements that are tailored to your interests on third party websites.  To find out more about how these third parties may collect information about you and deliver you advertisements that are tailored to your interests, please read about our Third Party Online Advertising in our Privacy Policy.

For these purposes, our service providers may use the following categories of cookies on the Sites:

• Strictly necessary cookies – These cookies are used for the sole purpose of (i) communication over an electronic communications network, or (ii) to allow the provider to provide such service as explicitly requested by you.
• Performance (analytic) cookies – These cookies collect information about how visitors use the Site, such as which pages visitors go to most often and if they get error messages from web pages. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. These types of cookies are only used to improve our services.
• Advertising cookies – These cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. They are placed by publishers on their sites with our permission.
• We use the information collected via cookies on the websites of our Customers to make your use of the Services more enjoyable and tailor the content and information that we may send or display to you.  For more information about relevant advertisements delivered by the Services, please read about our Interest Based Advertisements in our Privacy Policy.

For these purposes, we may use the following categories of cookies:

• Performance (analytic) cookies – These cookies collect information about how visitors use the Site, such as which pages visitors go to most often and if they get error messages from web pages. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. These types of cookies are only used to improve our services.
• Advertising cookies – These cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign.

To determine whether a cookie is a ‘first’ or ‘third-party’ cookie, the domain placing the cookie must be considered. First-party cookies are those cookies set by a website that is being visited by the user at the time. Third-party cookies are cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website this would be a third-party cookie.

Session cookies allow website operators to link your actions during a browser session. A browser session starts when you open the Internet browser window, and finishes when you close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted. Persistent cookies on the other hand are cookies which remain on your device for the period of time specified in the cookie. We use both session and persistent cookies.

4. How To Manage Cookies

Cookies used on our Sites: 

If you do not want our trusted business partners to place cookies on your device when browsing our Sites, you can adjust your browser settings to manage or reject cookies, or to notify you when a cookie is being placed in your Internet browser software. These settings are usually found in the ‘Options’ or ‘Preferences’ menu of your Internet browser. For more information on how to change your browser settings, click on the Help section of your Internet browser. Modern Internet browsers also allow you to see what cookies are currently stored on your device and selectively delete them as you wish.

Cookies used through our Services: 

If you do not want us to place cookies on your device when you interact with or use our Services in order to tailor content and information that we may send or display to you and otherwise personalize your experience while interacting with our Services, you can either adjust your browser settings (as explained above).  

To opt out of Cookies from other websites or companies please visit the Network Advertising Initiative (NAI) website at www.networkadvertising.org/managing/opt_out.asp , which will allow a User to opt out of seeing targeted ads from us and from other NAI-approved member companies. For mobile opt outs, the NAI provides instructions to engage system-level opt outs in Android, iOS, and Windows Phone environments.

5. Changes and Updates

We may update this Cookie Policy from time to time. We encourage you to periodically review this Cookie Policy to stay informed about our use of cookies, the information we collect via cookies, and any updates in relation thereto.

We will post any changes to this Cookie Policy on our Site. If we make any changes to this Cookie Policy that significantly impact the way we use cookies, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.

Your continued use of the Site and the Services constitutes your agreement to this Cookie Policy and any updates.

6. Contact Us

If you have questions about this Cookie Policy, you may contact us at privacy@upscale.digital