MediaWallah, LLC (hereinafter “MediaWallah”,” “we,” “us,” “our”) respects each person’s right to privacy. Our Privacy Policy explains the ways in which we collect information and maintain and use that information.

Guide to Content

Data Collection and Use Practices for Our Company
Website Data Collection and Use
Practices for Our Services Data
Security Legal and Regulatory Compliance
Third Parties
Children
Third Party Service Providers
Business Transfers
Aggregate Information
Information for European Union and Switzerland Residents
Information for California Residents
Changes to Our Privacy Policy
Contact Us



Data Collection and Use Practices for Our Company Website
This portion of our Privacy Policy explains how we collect, use and share information in connection with, your use of our company website (the “Website”), and how you can exercise your privacy rights regarding such information. This Privacy Policy only applies to the data we collect through our Website. If you are a consumer and would like to understand how MediaWallah collects, uses, and discloses data through its technology and services, please review the portion of this Privacy Policy entitled “Data Collection and Use Practices for Our Services.” 


Information We Collect Related to Use of Our Website
The term “PII”refers to information that identifies you as a specific individual, such as your name, mailing address, email address, phone number, or other information that identifies you as a natural person. In general, you can visit our Website without providing us with any PII. However, you may choose to submit PII through our Website in order to communicate with us (for example, to ask a question about our Services).  

We may also collect information (including PII) about you from third parties. For example, if you are on another website and you opt-in to receive information from MediaWallah on that website, that website will provide your contact and other information to us so that we may contact you as requested. We may supplement the information we collect directly with information we collect from third parties. 

We and our third-party service providers may automatically collect certain information when you interact with our Website, such as the browser and operating system you are using, the URL or advertisement that referred you to our Website, any search terms you entered into a search engine that led you to our Website, the are as within our Website that you visited, the time of day you visited our Website, the IP address of the network that you use to connect to the Website and unique identifiers for any computer, mobile phone, or other device used to access our Websites (together, “Usage Information”).  

Social Features on our Website
The Website may offer social sharing features and other integrated tools (such as the Facebook“Share” button), which let you share actions you take on our Website with other services, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features. 

Cookies and Similar Tracking Technologies

We and our third-party service providers, including third-party advertisers and analytics providers, may use cookies or similar technologies to collect Usage Information when you visit our Website. A “cookie” is a data file stored on your computer’shard disk or similar device when you retrieve content from a Web server.Cookies may be used for a variety of purposes, e.g., to identify your device when you revisit our Website, to recall your authentication information, to store information related to your navigation throughout our Website, or to enable certain features on our Website. We may also employ software technology known as “web beacons” or “tracking tags” to help us keep track of what content on our Website is effective and to serve relevant advertising to you. Web beacons are small graphics with a unique identifier that may be invisible to you, and which are used to track the online activity of Internet users.  

How We Use Your Information
We collect, store and use information about you to: (a) enable you to use our Website, and to provide related user service, such as responding to your questions; (b) administer and develop our business relationship with you and the company you represent, and contact you with administrative communications, if applicable; (c) provide you with information, products, or services that you have requested or agreed to receive or that we otherwise believe will interest you; (d) tailor content, recommendations and offers we display to you; (e) conduct internal analyses, such as surveys and market research, to improve our Website, our products and services, and for other internal business purposes; (f) process information you provide via our Website, including verifying that your e-mail address is active and valid; (g) enforce our terms and conditions, protect our business or this Website; and (h) carry out purposes as disclosed at the time you provide your information, with your consent. 

Analytics Providers, Ad Servers, and Similar Third Parties
We work with network advertisers, ad agencies, analytics service providers and other vendors to provide us with information regarding traffic on our Website, including pages viewed and the actions taken when visiting our Website, to serve advertisements for our Services on other digital media properties, and to provide us with information regarding the use of our Website and the effectiveness of our advertisements. For example, if you view or click on an advertisement for our Services, our service provider(s) may be able to tell us the advertisement that you clicked on and where such advertisement was displayed. Our service providers may set and access their own tracking technologies on your device (including cookies and web beacons) and may otherwise collect or have access to information about you and your visits to and activity on the Websites, as well as on other websites or online services. 

Your Choices: Marketing Communications and Opting Out
You may opt out of receiving promotional and marketing communications from us by emailing us at privacy@mediawallah.com or by using the opt-out mechanism included in the commercial emails we send. Even if you opt out, we will still send you certain communications relating to your use of our Websites, service announcements, notices of changes to this Website Privacy Policy or our Terms of Use or similar administrative or transactional messages.  

We use a variety of service providers to perform advertising services. Some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”).These organizations provide tools for opting out of online behavioral advertising by participating companies. You may elect to block cookies as described under the “Opting Out”section below, or you may elect to opt-out from online behavioral advertising from participating companies as described under the “Opting Out” section below(see the sub-heading entitled “industry opt-outs”). Please note that opting out through these mechanisms does not opt you out of being served advertising from the participating companies. You will continue to receive ads from participating companies that are not targeted to your interests while online.  

Data Collection and Use Practices for Our Services  

Overview of Our Services
MediaWallah provides data connectivity services designed to enable our clients, who are marketing and technology platforms, data companies, brands, and publishers, to reach consumers with greater efficiency and more relevant messages across various digital channels, including online and mobile (the “Services”). Through our Services we establish user connections between devices, browsers, apps and events, and provide data, insights and reporting to clients for commercial and advertising purposes. 

In this privacy policy, “users” (also referred to as “you” or “your”) means end users or visitors of browsers, applications, devices or other forms of media; “partners” means suppliers and data sources who provide us with data related to users; and “clients” means our customers.  

In order to provide our Services, we collect and store select information from devices, applications and browsers directly through the tracking technologies described below. We may also receive additional information about the device, browser, application, a user or a user’s use of a device, website, application or browser from partners or clients that have an existing relationship with the user, or from other third parties

DATA ELEMENTS WE COLLECT AND SHARE FOR SERVICE


For the purpose of our Services, we do not collect the following information from users:

Tracking Technologies Used

The technologies that we may use to collect information for our Services include: 

We use the tracking technologies listed above across platforms including websites, mobile applications and emails for the purpose of providing our Services.  Examples of how we deploy these technologies include: (1) when an ad is delivered and (2) when we integrate with our partners’ websites, newsletters and applications.  

We do not use “zombie cookies” or “history sniffing.” We do not use local storage and flash cookies. 

How We Use the Information We Collect
We use the data we collect to establish connections between devices. These connections allow us to understand that a single user or household is accessing advertisements or content from multiple devices.  

We also use the data we collect for the purpose of enabling our clients to perform online behavioral advertising (which we define to mean advertising to users based on their interests as inferred from their activities across websites or apps over time). 

We use the data we collect to provide data, insights and reports to our clients, to enable our clients to synchronize or target advertising or content, and to enable our clients to understand the performance of advertising or content across relevant devices.  

In cases where a user provided opt-in consent, we may also use the data we collect to enable our clients to perform advertising based on the precise location of the user. 

The data we collect may be used to detect fraudulent activity, to administer and enhance the Services, to perform internal analysis and to improve our Services. 

If you would like to opt-out of being tracked uniquely by MediaWallah, please the section below entitled “Opting Out”. Because web browsers, mobile apps and other forms of media have different identifiers, you will need to opt-out of each environment separately.

Opting Out

There are several ways you can opt-out of being tracked uniquely by MediaWallah: To opt out of cookies on desktop and mobile browsers:

To opt out of the use of mobile advertising identifiers on mobile devices:

Industry opt-outs

Some of our clients and partners participate in the industry opt-out tools of the Network Advertising Initiative (NAI) or the Digital Advertising Alliance (DAA). When a user uses these industry-opt-out tools to opt out of online behavioral advertising by such participating clients or partners, and where such clients or partners communicate your opt-out preferences to us, we honor such choices. You may opt out of online behavioral advertising from participating clients and partners by:

Please note that opting out through the above mechanisms does not opt you out of being served advertising from the participating companies. You will continue to receive ads from participating companies that are not targeted to your interests while online.

Data Retention

We retain the types of information noted above for up to one year from the date on which such information was collected. After one year,we discard the information about individual users and retain only aggregated or summary data. Aggregated and summary data is retained as necessary to fulfill a legitimate business purpose, comply with our legal obligations, resolve disputes, and enforce our agreements.

Data Security

We take commercially reasonable steps to help protect and secure the information that we hold about you. However, no data transmission over the Internet or wireless connection, or electronic storage of data, can be guaranteed to be completely secure. We cannot guarantee perfect security of any information we collect.

Legal and Regulatory Compliance

We reserve the right to disclose information if we have a good faith belief that such disclosure is required to comply with legal or regulatory requirements, or to protect our or others’ rights or prevent harm, including in response to lawful requests by public authorities, to meet national security requirements or to meet other law enforcement or legal requirements.

Third Parties

Our Website and Services may contain tracking technologies of third parties or may link to third party content or services. We do not control and are not responsible for the privacy practices of third parties, and this Privacy Policy does not cover collection or use of information by third parties.Visitors to or users of third party websites, content, services or other media should consult the privacy policies of such third parties to learn about such third parties privacy practices.

Children

We do not knowingly collect any personal information from or provide any services to children under the age of 16. If we learn that a user is under 16 years of age and we can identify personal information relating to such a user, we will take steps to delete such information promptly.

Third-party Service Providers

We may retain certain third party service providers to perform functions and services on our behalf, such as cloud services for storing and processing information, and customer relationship management services. We may share information with our third party service providers to the extent necessary to perform such functions and services, pursuant to obligations on such third party service providers that are consistent with this Privacy Policy.

Business Transfers

We may disclose information we have collected to third parties if we sell or buy any business or assets or if we merge with any other business. In this case, we may disclose your information to the prospective seller or buyer of such business or assets or to the entity with whom we merge.

Aggregate Information

We may share aggregate and anonymous usage statistics regarding the Services and our Website with the public or businesses with whom we work. We may also use such aggregated information to help us improve our Website and our Services.

Information for European Union and Switzerland Residents

It is our policy to not accept any personal information originating from the European Union (including the UK) or Switzerland. We have implemented a process designed to ensure that data determined to originate in any EU(including the UK) member country or Switzerland is not collected or stored. Should you have any questions or requests in this regard, please contact us by sending an email to us at privacy@mediawallah.com.

Information for California Residents

This section supplements the information contained in MediaWallah’s Privacy Policy, and applies solely to all visitors, users, and others who reside in the State of California("consumers" or "you"). We have adopted this section to comply with the California Consumer Privacy Act of 2018 (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this section. This section is effective as of January 1, 2020.

Information We Collect

Our Website and Service collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). We have collected, in connection with our Website or our Services, the following CCPA categories of personal information from consumers within the last twelve (12) months. Please note that information listed in some categories may overlap with other categories.

CATEGORY

COLLECTED

DETAILS

SOURCE

A. Identifiers

YES

From users of our  Website: name, postal address, email address, telephone number  

From users of our Website, and from Internet or digital media users for purposes of our Services.

IP address, hashed email  address, cookie ID, user agent string, operating system, and (in the case of  mobile devices) device type and mobile device advertising identifier (e.g.  Apple IDFA or Android Advertising ID).

Collected from our website or from third parties, or from our communication with the consumer.  

Collected directly from consumers through our tracking technologies; collected from clients and partners such as data suppliers, data aggregators, owners or operators of digital media properties, advertisers and agencies

B. Personal information categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))

YES

From users of our Website:name, postal address, email address, telephone number

Collected directly  through our tracking technologies; collected from partners such as data  suppliers, analytics partners

C. Protected classification characteristics under California or federal law.

NO

D. Commercial information

YES

Records of personal  property, products or services purchased, obtained, or considered, or other  purchasing or consuming histories or tendencies.

Collected from clients  and partners such as data suppliers, data aggregators, owners or operators of  digital media properties, advertisers and agencies

E. Biometric information

NO

F. Sensory data

NO

I. Professional or employment related information

NO

J. Non-public education  information (per the Family Educational Rights and Privacy Act (20 U.S.C.  Section 1232g, 34 C.F.R. Part 99)).

NO

K. Inferences drawn from  other personal information.

YES

We make inferences that  certain devices are being used by the same consumer or household.

Our internal analytics.

Note: “Personal information” does not include:

The Purposes for Which We Collect and Use Personal Information

MediaWallah is an advertising technology company that provides data connectivity services designed to enable our clients to reach consumers with greater efficiency and more relevant messages across various digital channels, including online and mobile.The personal information we collect is for the purpose of providing our services to our clients, and for the purpose of operating our website. In order to provide our services and/or operate our website, we also use the personal information we collect for these additional business purposes:

MediaWallah will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

MediaWallah will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

MediaWallah may disclose your personal information to a third party for a business purpose, or sell your personal information (subject to your right to opt out of such sales – see “Do Not Sell My Personal Information” below). We share your personal information with the following categories of third parties:

Disclosures of Personal Information for a Business Purpose

In the preceding twelve(12) months, MediaWallah has disclosed the following categories of personal information for a business purpose:

We disclose your personal information for a business purpose to the following categories of third parties:

Sales of Personal Information

In the preceding twelve(12) months, MediaWallah has sold the following categories of personal information:

We disclose your personal information for a business purpose to the following categories of third parties:

We sell your personal information for a business purpose to the following categories of third parties:

Do Not Sell My Personal Information

If you would like to exercise your right to opt-out of our sale of your personal information, you or your authorized representative may submit a request to us by visiting the following page: Don’t Sell My Information

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information.This section describes your CCPA rights and explains how to exercise those rights. 

Access to Specific Information and Data Portability Rights
You have the right to request that MediaWallah disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

Deletion Request Rights
You have the right to request that MediaWallah delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Exercising Access, Data Portability, and Deletion Rights
To exercise the access,data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at + 1 (855) WALLAH1 or +1 (855) 925-5241 or by emailing us at privacy@mediawallah.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. 

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. 

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights. 

Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive,repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.


Non-Discriminaton
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA,we will not:

However, we may offer you certain financial incentives permitted by CCPA that can result in different prices, rates or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website and our Service that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@mediawallah.com or write us at:

MediaWallah, LLC
100 Park Ave
16th Floor
New York, NY 10017

Do Not Sell My Personal Information

We may change this California Privacy Notice from time to time in response to changing legal, technical or business developments. Such changes will be effective as soon as we post the revised policy on this page, unless a different date is stated. If we are required by applicable data protection laws to obtain your consent to any material changes before they come into effect, then we will do so in accordance with such data protection laws.

This section supplements the information contained in MediaWallah’s Privacy Policy, and applies solely to users originating from the European Union (including the UK) or Switzerland ("consumers" or "you").  We have implemented a process designed to ensure that data determined to originate in any EU (including the UK) member country or Switzerland is governed by Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995. This Directive addresses the protection of individuals with regard to the processing of personal information and on the free movement of such information, as well as the national legislation of European Union Member states (EU).  Should you have any questions or requests in this regard, please contact us by sending an email to us at privacy@mediawallah.com.

Contact Us

If you have questions or comments about this Privacy Policy, you can contact us at: privacy@mediawallah.com  or by mail, to the following address:

MediaWallah, LLC
100 Park Ave
16th Floor
New York, NY 10017

Last Updated: December 30, 2019