Trust

California Consumer Privacy Act Disclosures

Last Updated: December 12, 2019

1. The following information is provided to satisfy the requirements of Title 1.81.5 of the California Civil Code (the “CCPA”) to which Amobee, Inc. (“Amobee”) is subject. Unless otherwise specified all section references are to the California Civil Code. Regulation references are to the California Code of Regulations, Title 11, Division 1, Chapter 20. These disclosures do not cover Amobee’s practices regarding the personal information of Amobee’s own employees.
2. The CCPA defines the following categories of personal information. These categories are relevant to the disclosures below.
   1. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers
   2. Any categories of personal information described in subdivision (e) of Section 1798.80. (These are categories subject to California’s data breach law, including social security numbers and bank account numbers, and several of these are already listed in category (a))
   3. Race (including hair texture and protective hairstyles), color, religion (including dress and grooming), sex and gender (including pregnancy, childbirth, breastfeeding), gender identity, and gender expression, sexual orientation, marital status, certain medical conditions falling short of a disability (specifically, genetic characteristics, cancer or a history of cancer), military or veteran status, national origin (which may include immigration status), ancestry, disability (mental and physical, including HIV/AIDS, cancer and genetic characteristics), genetic information, request for family leave, request for medical leave, request for pregnancy leave, retaliation for reporting patient abuse and age over 40
   4. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
   5. Biometric information
   6. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement
   7. Geolocation data
   8. Audio, electronic, visual, thermal, olfactory, or similar information
   9. Professional or employment-related information
   10. Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)
   11. Inferences drawn from any of the foregoing to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
3. Two other definitions relevant to the disclosures below are “categories of source” and “categories of third parties.” The CCPA regulations define “categories of sources” to mean the types of entities from which Amobee collects personal information about consumers, including but not limited to the consumer directly, government entities from which public records are obtained, and consumer data resellers. The CCPA regulations define “categories of third parties” to mean the types of entities that do not collect personal information directly from consumers, including but not limited to advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, and consumer data resellers. In the disclosures below, Amobee will refer to these specific categories which were defined by the California attorney general.
4. Below is a chart of the categories of personal information which Amobee collects and has collected over the previous twelve months, the categories of sources from which the personal information was collected, the business or commercial purpose for which the information was collected, the categories of third parties to whom the personal information was sold and the categories of personal information which were disclosed.

Category of personal information	Amobee will collect	Amobee has collected over previous 12 months	Categories of sources from which collected	Business or commercial purpose for which collected	Categories of third parties to whom sold	Disclosed for a business purpose†
a	Some but not all of the information in this category	Some but not all of the information in this category	The consumer directly and consumer data resellers	Digital advertising activities	Advertising networks, internet service providers, data analytics providers, social networks and consumer data resellers	Some but not all of the information in this category
b	No (except real name and e-mail, which are listed under category (a))	No (except real name and e-mail, which are listed under category (a))	N/A	N/A	N/A	No (except real name and e-mail, which are listed under category (a))
c	Some but not all of the information in this category	Some but not all of the information in this category	Consumer data resellers	Digital advertising activities	Data analytics providers	Some but not all of the information in this category
d	Yes	Yes	Consumer data resellers	Digital advertising activities	Data analytics providers	Yes
e	No	No	N/A	N/A	N/A	No
f	Yes	Yes	The consumer directly and consumer data resellers	Digital advertising activities	Data analytics providers	Yes
g	Yes	Yes	The consumer directly and consumer data resellers	Digital advertising activities	Data analytics providers	Yes
h	No	No	N/A	N/A	N/A	No
i	Yes	Yes	Consumer data resellers	Digital advertising activities	Data analytics providers	Yes
j	No	No	N/A	N/A	N/A	No
k	Some but not all of the information in this category	Some but not all of the information in this category	Consumer data resellers	Digital advertising activities	Data analytics providers	Some but not all of the information in this category

† Amobee uses cloud computing vendors which qualify as “service providers” under CCPA. The transfer of data to a cloud computing vendor is defined as a “disclosure” under CCPA.

5. Amobee does not sell the personal information of consumers where Amobee has actual knowledge that the consumer is less than 16 years of age.
6. You have the right to request what information Amobee collects, uses, discloses and sells about you. To submit this request please visit the portal at https://www.amobee.com/ccpa or call +1.877.326.5657. Amobee will verify your request by checking the information it holds against the information on your computer or mobile device. 
7. You have the right to request Amobee to delete the personal information it holds about you. To submit this request please visit the portal at https://www.amobee.com/ccpa or call +1.877.326.5657. Amobee will verify your request by checking the information it holds against the information on your computer or mobile device.
   1. While Amobee will normally attempt to honor this request, pursuant to Section 1798.105(d), Amobee reserves the right not to comply with your request to delete this personal information if it is necessary for Amobee to maintain this personal information in order to: (1) complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of Amobee’s ongoing business relationship with you, or otherwise perform a contract between Amobee and you; (2) detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for that activity; (3) debug to identify and repair errors that impair existing intended functionality; (4) exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; (5) comply with the California Electronic Communications Privacy Act; (6) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent; (7) to enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business; (8) comply with a legal obligation; or (9) otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information. 
8. You have the right to direct Amobee to not sell your personal information to third parties. To do so, click this link: Do Not Sell My Personal Information. If Amobee has received direction from you not to sell your personal information, Amobee is prohibited from selling your personal information for a period of 12 months after Amobee’s receipt of your direction. Note however that the “personal information” Amobee holds is tied to your computer or mobile device. Therefore, if you use a different browser, or if you delete the Amobee opt-out cookie from your browser, or if your browser automatically deletes the Amobee opt-out cookie, you may need to renew your opt-out choice for that browser. Similarly, if your mobile device’s advertising identifier is reset or you use a new mobile device, you will need to renew your opt-out choice for that device. 
9. You have the right not to receive discriminatory treatment by Amobee for exercising CCPA privacy rights.
10. You can designate an authorized agent to make a request under the CCPA by loaning the agent your device and having the agent visit the portal or Do Not Sell My Personal Information links above.
11. Your contact for questions or concerns about Amobee’s privacy policies and practices is amobeeprivacy@amobee.com.
12. Pursuant to Regulation 999.317(g), Amobee informs you of the following metrics:
    1. The number of CCPA requests to know that Amobee received, compiled with whole or part and denied in 2019: 0, 0 and 0
    2. The number of CCPA requests to delete that Amobee received, compiled with whole or part and denied in 2019: 0, 0 and 0
    3. The number of CCPA requests to opt-out that Amobee received, compiled with whole or part and denied in 2019: 0, 0 and 0
    4. The median number of days within which Amobee substantively responded to requests to know, requests to delete and requests to opt-out: N/A, N/A and N/A
13. A plain text file version of this document is available at https://www.amobee.com/trust/ccpa.txt for persons with disabilities or to be printed out as a separate document.