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websites, services that we provide to you through our website or technology platform, and ads we
display to you on other websites. It is effective as of December 31, 2019 (“Effective
- This policy is incorporated into, and subject to, Centro’s Terms of Service.
- By using Centro’s site, or any product or service offered, you acknowledge that you have read,
and agree to, this policy.
What is in this document?
This document provides information about our website and our digital
advertising technology platforms (“Basis DSP”, “Basis Platform”)
which enables our clients to buy digital advertising, and then describes our policies about data
collection and use. It also provides information on the type of data we collect and utilize when
serving ads to individuals.
CONSUMER OPT-OUT CHOICES
Centro supports empowering you to make informed decisions about the
type of advertisements that are delivered to you online, and, as such, we are providing you the
opportunity to opt out of the tailored ads delivered to you by Centro based on your interests,
previous visits to other sites, and information stored in your web browser or mobile device.
If you select this option, you will still see just as many ads, but
they will no longer be personalized based on the information Centro has collected, (i.e. the ads
will likely be less relevant to you and your interests) and any information we have collected thus
far will be dissociated from your device, thereby preventing its use. If our systems detect that
your computer or mobile device is located in the European Economic Area and you opt-out, we will
treat that opt-out as a request for the Basis DSP to cease processing your personal data.
Feel free to opt out here if you so desire:
- For desktop and mobile web, click
here. The opt-out requires a cookie to be stored by your browser, in order to signal your
opt-out status to us during future ad calls. By opting-out, you consent to Centro’s opt-out
cookie being stored by your browser.
- For mobile app:
- Find your phone’s Android Advertising Identifier (for Android
devices) or Apple Identifier for Advertising (for iOS devices).
- On Android 6, open the Settings app and select “Google”. Select “Ads”. Choose “Opt out
of Ads Personalization”, and make a note of your advertising ID. In earlier versions of
Android, this is found in a separate Google Settings app instead.
- On iOS, open the Settings App and select “Privacy”. Select “Advertising”, and enable
“Limit Ad Tracking”. On iOS 10 and above, this will set your Identifier for Advertising
to “0”, and no further action is needed, as this prevents its use. On iOS 9 and below,
for additional confidence, you may wish to download an app such as My
TUNE Device to determine your Identifier for Advertising and enter it in the box
- Enter it here:
It should also be noted that Centro is committed to industry
self-regulation, and as such, is a member in good standing with the Interactive Advertising
Bureau, (“IAB”) and is a participant in the Digital Advertising Alliance
(“DAA”) following the Self-Regulatory Principles for Online Advertising,
including its “AdChoices” program.
You may also visit the self-regulatory program opt-out pages:
for the USA, http://www.youronlinechoices.com
for the EU, http://www.youradchoices.com
Basis DSP PRIVACY PRACTICES
What is Basis DSP?
Basis DSP provides tools for advertisers, or media buyers, to purchase
digital ad space on website and mobile sites and applications. To accomplish these goals, the
Basis DSP collects pseudonymous information from these websites, mobile sites and mobile
applications and supplements that information with data from third parties. Advertisers and media
buyers use Basis DSP to engage in a variety of advertising techniques, including interest-based
advertising, real-time (programmatic) advertising, contextual, and location-based advertising.
Basis DSP also provides buyers other tools, like the ability to measure how effective their ads
were, designed to make the buying of ad space seamless.
What information does Basis DSP collect?
Basis DSP is designed to use certain types of data. It includes data
generated through Basis DSP as well as data clients receive from other sources and then use on
Basis DSP, or that they buy through Basis DSP. This may include pseudonymous information about
Internet users’ browsers and devices, such as:
- the type of browser and its settings,
- information about the device’s operating system,
- cookie information,
- information about other identifiers assigned to the device,
- the IP address from which the device accesses a client’s website or mobile application
- information about whether an Internet user has visited a Centro client’s website, based on web
beacons placed on the site by our customer
- information about the websites (i.e., the URLs) and mobile applications upon which we serve
- information about the geographic location of the device when it accesses a website or mobile
- inferences or information about users’ interests that are created, acquired, bought, sold, or
used by our clients
How does Basis DSP use the information that it collects?
We use the information we collect to serve targeted ads to individuals.
More specifically, the platform enables our users to use this
- Determine what ad to show an individual, and to serve that ad (including behaviorally targeted
ads) to that individual
- Customize ads to particular types of audiences;
- Customize ads to the type of web page an individual is viewing;
- Perform analysis of how effective the ads served are;
- Learn more about their own customers;
- Limit the number of times an individual sees an ad;
- Detect fraud; and
- Troubleshoot platform or campaign issues.
In order to use this information as described above, we may need to
transfer that information to third party partners, and such transfer may be considered a sale of
data in California.
How long is the information stored and kept?
For data collected via browsers and stored in cookies, Basis DSP
stores this data for up to 60 days. For data collected via mobile
application advertising and stored via mobile advertising IDs Basis DSP stores this data for up to
180 days. Our systems typically reset the retention period each time we encounter the same user.
How does Basis DSP collect this information?
associated with particular devices or web browsers. Customers then use this data within Basis DSP
to enhance and refine digital ad campaigns.
Does Basis DSP use web beacons (aka clear GIFs or web bugs)?
Yes. “Web beacons” are small images (generally a single transparent
pixel) with a unique identifier, served to you as part of a web page or other document. Web
beacons may be used in parts of our services for purposes such as site traffic reporting, unique
visitor counts, advertising auditing and reporting, and personalization. For more information on
web beacons, see http://www.allaboutcookies.org/faqs/beacons.html
How does Centro use the information provided by Basis DSP advertisers?
We use any information provided by Basis DSP and Basis Platform
advertising customers for the following service-related purposes:
- To provide, operate, manage, maintain and enhance the platform. We internally perform
statistical and other analysis on information we collect (including usage data, device data,
referral data, and information from page tags) to analyze and measure user behavior and trends,
to understand how people use our services, and to monitor, troubleshoot and improve our
- To assist the enforcement of our Terms of Service.
- To prevent potentially illegal activities.
- To screen for undesirable or abusive activity.
- To contact you about your service or account. We occasionally send you communications of a
transactional nature (e.g. service-related announcements, billing-related matters, changes to
our services or policies, welcome emails when you first register, etc.). You can’t opt out of
these communications, since they are necessary in order for us to effectively provide our
services to you.
- To contact you for marketing purposes. We will only do this if you have given us your express
permission to contact you for this purpose.
- To respond to legal requests and prevent harm. If we receive a subpoena or other legal
request, we may need to inspect the data we hold to determine how to respond.
- To create new services, features or content. We may use any information you provide us (e.g.
via email or through our ticketing system) to create and provide new services, features or
Will Centro share the information collected via the Basis DSP or Basis Platform?
- We share aggregate information collected from the Basis DSP for marketing purposes. For
example, we may issue a press release announcing that users who have visited travel sites have a
higher click-thru rate on finance related web pages.
- Billing and Contact information – We work with trusted agents and service providers to assist
us in billing and account maintenance for our clients. These companies are required by contract
to only use the information as directed by Centro and are prohibited from selling it. For
example, if you fund your platform account with a credit card, we use a credit card processing
company to bill you for the services and share your address and billing details with them in
order to do so. These service providers do not retain, share, store or use that information for
any other purpose.
- To interact with ad delivery partners - As noted above, in certain instances, we may share
information and “cookie sync” with our suppliers, which include data companies and ad exchanges.
- To provide the services – Centro may provide customer platform data to partners and service
providers for the purpose of operating, managing, maintaining, or enhancing Centro’s services,
including for the safety and security of the platform and the online industry, or as required by
law. Centro does not share the information collected on the platform with other third parties,
unless legally required.
As a Basis DSP user or Basis Platform customer, what communications can I expect from
- Special Offers and Updates – We will occasionally send you information on products, services,
special deals, and promotions (if you opt-in on our registration page). If you no longer wish to
receive this type of communication, you can opt-out through the link in the email communication.
- Surveys or Contests – From time to time, we may provide you the opportunity to participate in
contests or surveys on our site. If you participate, we may request certain personally
identifiable information from you. Participation in these surveys or contests is completely
voluntary, and you therefore have a choice whether or not to disclose this information. We use
this information to notify contest winners and award prizes, and to process and analyze survey
results. We use a third party service provider to conduct these surveys or contests; that
company is prohibited from using our users’ personally identifiable information for any other
- Service-related Announcements – We will send you strictly service-related announcements on
rare occasions when it is necessary to do so. For instance, if our service is undergoing
temporary maintenance, we might send you an email. Generally, you may not opt-out of these
communications, which are not promotional in nature. If you do not wish to receive them, you
have the option to deactivate your account.
- Customer Service – Based upon the personally identifiable information you provide us, we will
send you a welcoming email to verify your username and password. We will also communicate with
you in response to your inquiries, to
provide the services you request, and to manage your account. We will communicate with you
through our ticketing system, via email, and by phone.
If you no longer wish to receive our promotional communications, you
may unsubscribe by following the instructions included in each communication.
Through our partners, we use web beacons in our HTML-based emails to
let us know which emails recipients have opened. This allows us to gauge the effectiveness of
certain communications and the effectiveness of our marketing campaigns.
Supplementation of Information: In order to provide certain
services to you, we may supplement the personal information you submit to us with information from
third party sources, for example, in connection with credit decisions and verification of any
CENTRO'S BUSINESS OPERATIONS
What information does Centro collect pursuant to running its business, and how is it
In addition to running our website, which is discussed below, we
collect certain information as part of running our business. We maintain contact records of
business partners, service providers and customers. We provide some of them to login to our
systems to view reports and as such will process their email addresses and passwords to enable the
login. We also obtain billing and payment information from them so we can collect payment for our
services. We only use this information for the purpose it is collected and don’t sell this
CENTRO.NET WEBSITE VISITORS
What information does the Centro website collect, and how is it used?
We collect usage data about you whenever you interact with our website.
This may include which of our pages you visit, what you click on, when you performed those
actions, and so on. Additionally, like most websites today, our web servers keep log files that
record data each time a device accesses those servers. The log files contain data about the nature
of each access, including originating IP addresses. We collect data from the device and
application you use to access our services, such as your IP address and browser type. We may also
infer your geographic location based on your IP address. If you arrive at our website from an
external source (such as a link on another website or in an email), we record information about
the source that referred you to us. We use third party tracking services that employ cookies and
page tags (also known as web beacons) to
collect pseudonymous data about visitors to our websites and their collection of data may
constitute a sale under California law. This data includes usage and user statistics, but not
personally identifiable information.
Yes. “Cookies” are pieces of information (actually, alphanumeric
identifiers) generated by web servers, and stored on your web browser for future access. Cookies
cannot view or retrieve data from other cookies, nor can they capture files or data stored on your
computer. We do not link the information that we store in cookies to any information that may be
used to ascertain your real world identity. We use both session ID cookies and persistent cookies.
We use session cookies to make it easier for you to navigate our site. A session ID cookie expires
when you close your browser. A persistent cookie remains on your hard drive for an extended period
of time. You can remove persistent
cookies by following directions provided in your web browser’s “help” file. We set a
persistent cookie to store your passwords, so you don’t have to enter it more than once.
Persistent cookies also enable us to track and target the interests of our users to enhance the
experience on our site. If you reject cookies, you may still use our site, but your ability to use
some areas of our site will be limited. For more information on cookies, see: http://www.allaboutcookies.org/faqs/cookie-file.html
GENERAL PRIVACY INFORMATION
How do I access my information?
You have the right to access, update, and correct inaccuracies in
certain information in our custody and control, subject to certain exceptions prescribed by law.
You may request access, updating and corrections of inaccuracies in the personal information we
have in our custody or control by emailing us at email@example.com. We may request certain personal
information for the purposes of verifying your identity when requesting access to or correction of
your personal information records. If your personally identifiable information changes, or if you
no longer desire our Service, you may correct, update, delete or deactivate it by emailing us
at firstname.lastname@example.org. EU and California data subjects may
be entitled to
additional rights as described below.
Is my information secure?
Yes, the portions of our website (and our other services) that handle
sensitive confidential information are secure. We are committed to maintaining the security of
your information and have measures in place to protect against the loss, misuse, and alteration of
the information under our control. We employ industry-standard techniques to protect our systems
from intrusion by unauthorized individuals. Our data center utilizes state-of-the-art physical
security measures to prevent unauthorized access to the facility. In addition, all information is
stored in a secure location behind firewalls and other sophisticated security systems with limited
(need-to-know) administrative access. All provider employees who have access to, or are associated
with, the processing of personal information are contractually obligated to respect the
confidentiality of your information and abide by the privacy standards we have established. Please
be aware that no security measures are perfect or impenetrable. Therefore, while we strive to use
commercially acceptable means to protect your personal information, we cannot guarantee its
Onward Transfer – Will my information be transferred?
Centro may transfer data processed by our Platform to our advertisers,
their ad agencies or their data management platforms and such transfers may constitute a sale of
data under California law. As described above, Centro may share information with trusted
third-party agents such as billing and payment processing vendors and hosting providers for the
Centro website and DSP. These third-party contractors are prohibited from using the information
for purposes other than performing services for Centro. Other third-party service providers used
by Centro include: a) cloud computer, data storage and file storage providers, b) email marketing
providers, c) website and b2b sales analytics providers, d) customer relationship management,
contact database vendors, data hygiene vendors, survey vendors and project management software
providers, e) customer billing systems partners, f) login authentication providers to ensure that
the logins to our systems are working efficiently, g) social media platforms for advertising and
marketing purposes, h) outsourced computer programmers helping ensure our systems are operating
properly, i) auditing, debugging and security vendors. These agents work on our behalf and use
data only as directed by us, provided that such third party agents provide at least the same level
of privacy protection as we do.
The above notwithstanding, we may disclose any of the information we
collect when we believe that we have a legal obligation to do so or to protect the safety,
property or rights of Centro or of any third party. For example, we may disclose any of the above
in order to (i) protect our rights and/or comply with a judicial proceeding, court order, or legal
process served, (ii) for law enforcement or national security purposes including sharing data of
EU and Swiss individuals in response to lawful requests from public authorities to meet national
security and law enforcement requirements, or (iii) protect or defend our proprietary rights.
Centro is responsible for the processing of personal information it
receives under the Privacy Shield and subsequently transfers to a third-party acting as an agent
on its behalf. Centro shall remain liable under the Privacy Shield principles if its agent process
such personal information in a manner inconsistent with the Privacy Shield principles, unless the
organization proves that it is not responsible for the event giving rise to the damage.
We will also provide an EU or Swiss individual with opt-out or opt-in
choice before we share their personal data with third parties other than our agents, or before we
use it for a purpose other than which it was originally collected or subsequently authorized. If
you’re located in the EU or Switzerland and seek to limit the use and disclosure of your
information, please submit a written request to email@example.com.
In the event that Centro (or its parent or subsidiary companies) goes
through a business transition, such as a merger, acquisition by another company, or sale of all or
a portion of its assets, your personally identifiable information will likely be among the assets
transferred. You will be notified via prominent notice on our site for 30 days of any such change
in ownership or control of your personal information.
This site contains links to other sites that are not owned or
controlled by Centro. We are not responsible for the privacy practices of such other sites. We
encourage you to be aware when you leave our site, and to read the privacy statements of each and
every site that collects personally identifiable information. This privacy statement applies only
to information collected by Centro.
We reserve the right to modify this privacy statement at any time, so
version, together with an updated Effective Date, on this page. We encourage you to check this
page periodically for any changes.
CALIFORNIA DATA SUBJECTS
Effective January 1, 2020, the California Consumer Privacy Act (CCPA)
provides additional privacy protections for California data subjects and users, including: a) the
right to see what personal information we have about you, your computer or device (the right to
know), b) the right to delete the personal information we have about you, your computer or device
(the right to delete) and c) the right to opt-out of the sale of personal information about you,
your computer or device to certain third parties (the right to opt-out from sales of your personal
information). We do not discriminate against you if you exercise any of the above rights.
Moreover, we may not be able to honor a right if doing so would violate applicable law.
If you are a Customer or partner of Centro and have questions about
your ability to see the data
used to login to our systems, we ask that you direct your question to the person that owns the
If you would like to exercise your Right to Know or Right to Delete,
you may do so by clicking the following link and completing
the associated form, or by calling
844-784-5263. As a California data subject, if you
make a subject access request as set out in this policy, you are entitled to see and delete the
personal information that we have about you. We will confirm your request within 10 days and make
a good faith attempt to fulfill your request within 45 days.
We may take reasonable steps to verify your request. We will fulfill
requests we are able to
verify so long as we are not prohibited from doing so by applicable law and/or the information is
not essential for us for billing, fraud prevention or security purposes. We will share our
reason(s) for denying your request in the event that we are unable to fulfill your request.
You may make an access or deletion request via an authorized agent by having such agent follow the
process below. Please note that we will request any authorized agent demonstrate that they have
been authorized by you to make a request on your behalf. And we will attempt to verify your
request. We require any authorized agents to provide us with contact details such as an email
address and phone number so that we may ensure a timely response.
The CCPA defines personal information broadly and as such, it includes
such as cookie IDs and mobile advertising IDs. Under the CCPA, your request to see the personal
information that we have about you may include: (1) specific pieces of personal information that
we may have about you; (2) categories of personal information we have collected about you; (3)
categories of sources from which the personal information is collected; (4) categories of personal
information that we sold or disclosed for a business purpose about you; (5) categories of third
parties to whom the personal information was sold or disclosed for a business purpose under the
CCPA; and (6) the business or commercial purpose for collecting or selling personal information.
Do Not Sell My Personal Information (California Residents)
If you are a California resident, you are also entitled to opt-out of sales of your personal
information by Centro to third parties. To exercise those rights, please click here to access “Consumer Opt-Out Choices” and follow the instructions
EUROPEAN UNION DATA SUBJECTS
The General Data Privacy Regulation (“GDPR”) affords additional rights
to EU data subjects. Those rights include the right to complain to EU Supervisory Authorities and
the right to access, correct, port to another party and delete certain personal data processed by
With respect to EU data subjects, personal data includes pseudonymous
information such as an IP address, a mobile advertising ID or a cookie ID. Where Centro is a
controller of data (e.g., via our Basis DSP), the legal basis will be both legitimate interest and
consent depending on the type of information subject to processing and the information we receive
from upstream partners. Where we rely upon legitimate interest, we have assessed the processing is
not high risk and will not violate fundamental human rights of EU data subjects.
Where Centro receives from an EU data subject a request to cease
processing of data via one of the choice mechanisms listed above, Centro will stop all data
processing with respect to the opted out browser or device unless such processing is required by
If you’re an EU data subject and believe Centro is processing your
pseudonymous information (e.g., Centro cookie ID or mobile advertising ID) or your contact
information (e.g., email address, telephone number) and you wish to exercise your right to access,
delete, port or remove such information, please send an email to firstname.lastname@example.org and we will respond to your request
within 30 days.
Centro’s Data Protection Officer and EU representative is Dr. Christoph
Bauer, CEO at ePrivacy GmbH and he may be contacted at email@example.com.
Centro complies with the EU-US Privacy Shield Framework and the
Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the
collection, use, and retention of personal information from European Union member countries and
Switzerland transferred to the United States pursuant to Privacy Shield. Centro has certified
that it adheres to the Privacy Shield Principles with respect to such data. If there is any
Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy
Shield program, and to view our certification page, please visit https://www.privacyshield.gov/
With respect to personal data received or transferred pursuant to the
Privacy Shield Frameworks, Centro is subject to the regulatory enforcement powers of the U.S.
Federal Trade Commission.
In compliance with the Privacy Shield Principles, Centro commits to
resolve complaints about your privacy and our collection or use of your personal information
transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals
with Privacy Shield inquiries or complaints should contact firstname.lastname@example.org.
Alternatively, you may contact us at the address below:
11 E Madison St., 6th Floor
We have further committed to refer unresolved privacy complaints under
the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY
SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely
acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please
for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above
channels, under certain conditions, you may invoke binding arbitration for some residual claims
not resolved by other redress mechanisms. See Privacy Shield Annex 1 at: https://www.privacyshield.gov/article?id=ANNEX-I-introduction
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