Privacy Policy Aug. 24, 2016

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The Trade Desk is committed to protecting consumer privacy and respecting your right to choice as it relates to advertising and the data used to help serve ads relevant to those consumers. The Trade Desk is a technology company which helps advertisers connect with consumers who are interested or could benefit from the advertisers’ products. Protecting consumer privacy is of the utmost priority to The Trade Desk. See below for our complete Privacy Policy or to opt out of receiving relevant ads served by us.

If you would prefer not to have The Trade Desk serve you relevant ads, you may opt-out here: Opt Out of Relevant Advertising. If you do so, you will continue to see ads, but they will not be targeted based on your online activity.

The Trade Desk is committed to following the OBA Principles, and as a member of the Digital Advertising Alliance as well as the Network Advertising Initiative: NAI, is in compliance with the industry’s Self-Regulatory Code. Click here if you would like further information regarding the DAA principles and here if you would like information about the NAI principles. Consistent with these principles, the health/fitness related segments available in The Trade Desk for OBA can be viewed here.

The Trade Desk also adheres to the European Interactive Digital Advertising Alliance’s (“EDAA”) principles. You can learn more and opt out of behavioral advertising here.

Further, The Trade Desk adheres to the Canadian Self-Regulatory Principles for Online Behavioural Advertising’s (“DAAC”) principles. You can learn more and opt out of behavioral advertising here. Please contact privacy@thetradedesk.com for any questions about The Trade Desk privacy, security, and data practices. Please see below for our complete Privacy Policy.

PRIVACY POLICY Effective: June 12, 2015

Background Regarding The Trade Desk’s Technology and Services The Trade Desk (“we”, “us”, or “our”) is an online advertising and technology platform headquartered in the United States. We provide this privacy policy to inform you about how our technology platform (“Technology”) processes information on behalf of online advertisers, website owners, data providers and other businesses that use our services (collectively, our “Clients”). This policy also outlines our privacy practices for our corporate website, which is located at www.thetradedesk.com (the “Website”). If you have any questions about this privacy policy, please feel free to contact us at privacy@thetradedesk.com. The Trade Desk runs a buying platform for media and data. The Trade Desk Technology allows our Clients to buy ad space on websites for online advertising and allows for the use of proprietary and third party data in the purchase of that media. When ad space on or within a website or mobile application is bought or sold (usually to an advertiser or ad agency by a web publisher) the Technology, fulfills the transaction by delivering the ad to Internet and mobile users who visit that site or use that application. Generally, an Internet user’s computer, browser or device comes into contact with The Trade Desk when a user views an ad, or visits a website (or uses an app), delivered or serviced by or with our Technology. Serving users relevant advertising is sometimes referred to as interest based advertising or online behavioral advertising (“OBA”).

PRIVACY PRACTICES FOR OUR TECHNOLOGY

Information Our Technology Collects We believe that consumers prefer more (rather than less) relevant ads, tailored to their interests. To do this, we collect a variety of data from Clients and across platforms, to help optimize ads and increase the likelihood that a particular unique, but anonymous users will be interested in (rather than potentially annoyed by) an ad they see. For more information on the technology used to collect the below information, please refer to the below section titled “Cookies, Web Beacons and Mobile SDKs.”

  • Our Technology collects Non-Personally Identifiable Information (“Non-PII”) that may include, but is not limited to, your IP host address, the date and time of the ad request, pages viewed, browser type, the referring URL, Internet Service Provider, and your computer’s operating system, as well as how you interact with a web page or ad. We may also collect Non-PII such as age, gender, income, education, interests, and usage activity from Clients or other third parties. We also may collect analogous Non-PII from mobile platforms, which may include information about your interactions with those applications (including your IP address and time-stamp information), and information about your mobile device (including device type, handset name, operating system information, mobile identifiers such as Apple IDFA and Android Advertising ID, app-specific identifiers, and a list of the applications your device interacts with).
  • Sometimes, we obtain the above information from other ad platforms, application platforms or providers, customers or websites and services (including our Clients). We may work with Clients to synchronize or “sync” unique, anonymous identifiers to match our Clients’ non-PII data or identifiers to our own, in order to , enhance data points about a particular unique browser or device, and thus, and thus enable or send ads that are more relevant, match consumers to their likely product interests, or better synchronize, cap, or otherwise optimize advertising.

How We Use Information Our Technology Collects

The Trade Desk uses Non-PII to target and serve relevant advertising to consumers and to perform attribution analysis or other analytics regarding advertising audiences, as well as to compile, match and link audiences on behalf of Clients. For instance, we may use this non-PII, generally on behalf of Client, to:

  • Determine what ad to show a consumer, and customize ads to particular types of audiences;
  • Customize ads to the type of web page users are viewing;
  • Limit the number of times a consumer sees an ad or a type of ad;
  • Perform analysis of how effective the ads are;
  • Help advertisers learn more about their own consumers.

Sometimes we may use or make available to Clients the non-PII we collect or receive (such as IP Address) to recognize users or try to resolve a commonality of users (or households) across platforms or across devices, such as smartphones, computers, tablets or related browsers. For instance, we might infer that a common IP address seen across different devices represents a common user (or a related or similar user), and use that inference in tailoring ads. Occasionally, we receive anonymized data sets (which may constitute hashed or obfuscated personally identifiable information (“PII”)), in order to promote, test or validate the accuracy of such inferences.

Cookies, Web Beacons and Mobile SDKs

In order to help make the online advertisements more relevant to users, our Technology uses the standard “cookies” feature of major browser applications that allows us to store a small piece of data on users’ computers about users’ visits to certain websites. We also use cookies to understand users’ browsing and buying activities so that we can measure the success of online advertising campaigns we run.

Cookies are small text files that web servers typically send to users’ computer when they visit a website. Cookies are stored as text files on users’ hard drive, and can be accessed by web servers when the user visits a website or views an advertisement. Cookies are used by companies to collect and send information about a user’s website visits – for example, number of visits, average time spent, pages viewed, navigation history through the website, and other statistics. This information helps companies improve a user’s online experience in many ways: for example, by allowing companies to monitor website performance, making the website easier to use, measuring the effectiveness of their promotional placements, and tailoring their website (including the ads and offers they receive) to better match a user’s interests and preferences. . Users who prefer not to accept cookies can set their Internet browser to notify them when they receive a cookie or to prevent cookies from being placed on their hard drive.

The Trade Desk cookie is set to expire after one year; our opt-out cookie lasts longer. Our cookie expiration may reset upon further interaction between ourselves (or as applicable a Client) and a browser or device.

The Trade Desk also uses web beacons (also known as 1×1 gifs), along with cookies, to determine if a user has visited a particular website. These beacons aid in providing more relevant advertising to the user, as well measuring the success of an advertising campaign, but provide no personally identifiable information.

HTML5 and Locally Stored Objects. Similar to cookies are “locally stored objects,” which we may also use for storing non-PII. Locally stored objects, such as HTML5 Web Storage, are used for similar purposes as cookies but typically may contain a greater amount and different types of data than browser cookies. Most current versions of common web browsers clear this locally stored data when you delete or clear your cookie cache. To confirm whether this is the case for the browser you are using, or to learn more about how to precisely control this data storage, please consult the Help function of your browser.

Mobile Device Identifiers and SDKs. We may sometimes work with Clients that use mobile SDKs to collect information. A mobile SDK is the mobile app version of a pixel tag or beacon (see those descriptions, above). The SDK is a bit of computer code that app developers can include in their apps to enable ads to be shown, data to be collected, and related services to be implemented. We may use this technology, or work with others who use this technology, to deliver certain advertising through mobile applications and browsers based on information associated with mobile devices. If you’d like to opt-out from having ads tailored to you in this way on your mobile device, please follow the instructions in the “Choices” section below.

Information Sharing

The Trade Desk may share the non-PII that we collect and receive in various ways.

  • Primarily, we may work with Clients and other third parties to help optimize ads and make them more likely to be relevant to consumers, by comparing, syncing and sharing the non-PII described above. For instance, we may disclose to other ad platforms, customers or websites and services (including our Clients), non-PII we have collected (generally, unique, anonymous identifiers representing consumers’ browsers), to match their unique identifiers to our own, so that we can “sync” identifiers in order to help them show more relevant ads, match consumers to their likely interests, or better synchronize, cap, or otherwise optimize advertising.
  • Further, the non-PII we collect and receive may be processed on our behalf by third-party service providers that assist us in running our business, including providers of data storage and processing facilities.
  • We may disclose your information to third parties when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual activities that may harm any person, our company, the Technology, or otherwise violate any law.
  • Also, in the event The Trade Desk is merged into another company, or another company acquires all or substantially all of The Trade Desk’s assets, including, without limitation, in the event of bankruptcy, all data compiled or owned by The Trade Desk may be among the items transferred in that transaction.
  • Finally, we may share aggregated, non-personal information with Clients in connection with reporting and accounting needs as well as with other unaffiliated third parties for various purposes such as statistical or educational analysis (such as the creation of predictive models).

Your Opt-Out Choices

If you’d like to opt-out from having The Trade Desk use your Non-PII in connection with ad targeting based on your behavioral activity, please click here. When you opt out, we will place an opt-out cookie on your computer. The opt-out cookie tells us not to collect your Non-PII to tailor our online advertising campaigns. Please note that if you delete, block or otherwise restrict cookies, or if you use a different computer or Internet browser or update or re-install your current browser, you may need to renew your opt-out choice. Please also note that if you choose to disable this function, your online experience may be diminished and some features may not work as they were intended.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data and advertising partners. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at http://www.aboutads.info and at http://www.networkadvertising.org/choices/. If you are located in Canada, you can access this information at http:// http://youradchoices.ca/choices/. If you are located in the EU you can access this information at http://www.youronlinechoices.eu.

You may also opt out of ad tracking on devices such as iPhones, iPads, or iPods, or Android Devices. For the most effective and up to date methods of doing so, you should consult your device settings, and instructions provided by those device manufacturers. However, we provide the following exemplary information solely for informational purposes, and we disclaim any warranty or representation that the below opt out methods will work in all cases, or that they are most current.

Opting Out on iOS Devices Such as iPhones, iPads or iPods

If you have an Apple device, you can opt out of our behaviorally targeted advertising services by updating to iOS 6.0 or higher, and setting Limit Ad Tracking to ‘ON’. You can do this by clicking on Settings -> General -> About -> Advertising and toggling Limit Ad Tracking to ‘ON’. Our systems are designed to respect your choice and not use information to provide interest-based advertising when this setting is ON. Again, you should consult Apple’s support web pages and instructions for the most current applicable settings.

Opting Out on Android Devices

If you have an Android device and would like to opt out of our behaviorally targeted advertising services, you may do this as follows:

  1. Open the Google Settings app on your device
  2. Select Ads
  3. Either “Reset advertising ID” or
  4. Opt out of interest-based ads

Our systems are likewise designed to respect these choices transmitted by your Android device. Again, however, please consult Google’s settings and instructions for the most current settings information.

Data Storage and Security

We retain the non-Personally Identifiable Information collected via our Technology for up to eighteen months. After 18 months (or sooner) the data is stored in aggregate for up to three years.

The security of your information is important to us. The Trade Desk has implemented security measures to prevent the loss, misuse, and alteration of the information that our Technology collects, but we make no assurances about our ability to prevent such loss, misuse, to you or to any third party arising out of any such loss, misuse, or alteration.

Changes To Our Policy

We may revise this policy at any time. Any changes and/or updates to the policy will be updated directly on this page. We encourage you to visit this page periodically to review our current privacy policy so that you will always know what information we gather and how we may use that information.

International Transfers and Safe Harbor

The Trade Desk operates the Technology from servers located in the United States of America and the information it collects through Clients is processed in the United States of America. Laws governing the collection and use of data in the United States may not be equivalent to those in the country where you reside, but The Trade Desk will at all times protect your data in accordance with this Policy.

To the extent they are applicable, The Trade Desk, Inc. complies with the principles of the U.S./EU and U.S./Swiss Safe Harbor Frameworks regarding Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement with respect to the personal information it receives in the U.S. from the relevant European countries. To exercise their rights under Safe Harbor or file a complaint, residents of those countries may contact The Trade Desk, Inc. as described in the next section of this privacy policy, and our business customers can log into their accounts to directly access and correct certain information they have submitted. In the event we are unable to resolve a disagreement with a covered European resident regarding the handling of his or her personal information under Safe Harbor, we agree to resolve the matter through TRUSTe. To learn more about the Safe Harbor Frameworks, please visit http://www.export.gov/safeharbor. You can search for and review our Safe Harbor certification at https://safeharbor.export.gov/list.aspx.

Contacting Us

Should you have any questions in regards to this policy or The Trade Desk’s privacy practices, please contact our representatives at the following email and they will be more than happy to clarify and assist you in any way possible: privacy@thetradedesk.com, or by mail at:

Privacy

The Trade Desk, Inc.

505 Poli Street, 5th Floor

Ventura, CA 93001


PRIVACY PRACTICES FOR OUR WEBSITE

Effective Date: 06/04/2014

This privacy policy describes how The Trade Desk collects and uses the personal information you provide on our Web site: www.thetradedesk.com. It also describes the choices available to you regarding our use of your personally identifiable information (“PII”) and how you can access and update this information.

The Trade Desk has received TRUSTe’s Privacy Seal signifying that this privacy statement and our practices have been reviewed for compliance with the TRUSTe program viewable on the validation page available by clicking the TRUSTe seal. The TRUSTe certification covers personal information collected through this site: www.thetradedesk.com.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe at https://feedback-form.truste.com/watchdog/request.

To the extent they are applicable, The Trade Desk, Inc. complies with the principles of the U.S./EU and U.S./Swiss Safe Harbor Frameworks regarding Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement with respect to the personal information it receives in the U.S. from the relevant European countries. To exercise their rights under Safe Harbor or file a complaint, residents of those countries may contact The Trade Desk, Inc. as described at the end of this privacy policy, and our business customers can log into their accounts to directly access and correct certain information they have submitted. In the event we are unable to resolve a disagreement with a covered European resident regarding the handling of his or her personal information under Safe Harbor, we agree to resolve the matter through the International Centre for Dispute Resolution / American Arbitration Association Safe Harbor Dispute Resolution Program (http://go.adr.org/safeharbor). To learn more about the Safe Harbor Frameworks, please visit http://www.export.gov/safeharbor. You can search for and review our Safe Harbor certification at https://safeharbor.export.gov/list.aspx.

Information We Collect On Our Website

We collect PII such as name, email address and phone number when you contact us with questions regarding our service or to request a demonstration of our product.

We may also collect Non-PII from visitors to this Website for a variety of reasons including to streamline website usability.

How We Use Information We Collect On Our Website

On this Website, PII is only collected on the Contact Us, Request a Demo, Get More Info, or Newsletter Signup sections.

Communications From The Site

Newsletters

If you wish to subscribe to our newsletter, we will use your email address to send the newsletter to you. If you no longer wish to receive these email communications you can follow the unsubscribe instructions contained in the emails you receive or by contacting us at privacy@thetradedesk.com.

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 temporarily suspended for 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.

Who We Share PII With

  • We will share your personal information with third parties only in the ways that are described in this privacy statement.
  • We may provide your personal information to companies that provide services to help us with our business activities such as sending email communications on our behalf. These companies are authorized to use your personal information only as necessary to provide these services to us
  • We may also disclose your personal information:
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  • When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request,
  • If The Trade Desk is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information, to any other third party with your prior consent to do so.

Third Party Websites

The Trade Desk Website may contain links to and advertisements for websites operated by third parties whose privacy practices may differ from ours. While we endeavor to associate only with reputable entities, The Trade Desk is not responsible for the privacy practices of these other websites. We encourage you to check the privacy policies of all websites that you visit.

Updating / Deleting your PII

If you’d like us to update, correct, delete, or deactivate any PII that you have provided to us on this Website, please resubmit your contact information on the Contact Us page or send your request to us at privacy@thetradedesk.com and we will process your request within 30 days of receiving it.

Data Retention

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Security

The security of your personal information is important to us. The Trade Desk has implemented security measures to prevent the loss, misuse, and alteration of the information that our Technology collects, but we make no assurances about our ability to prevent such loss, misuse, to you or to any third party arising out of any such loss, misuse, or alteration.

Third Party Advertisers

We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personally identifiable information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking.[DD1] Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

Tracking Technologies

Log Files

We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole.

Cookies

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on this site. We do link the information we store in cookies to any personally identifiable information you submit while on our site.

You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. If you reject cookies, you may still use our site, but your ability to use some areas of our site, such as contests or surveys, will be limited.

The use of cookies by our partners and service providers is not covered by our privacy statement. We do not have access or control over these cookies.

Clear Gifs

Our third party advertising partner employs a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We tie the information gathered by clear gifs to our customers’ personally identifiable information.

We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

Our Web site includes Social Media Features, such as the Facebook Like button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Testimonials

We post customer testimonials on our web site which may contain personally identifiable information. We obtain the customer’s consent via email prior to posting the testimonial to post their name along with their testimonial. If you want your testimonial removed please contact us at privacy@thetradedesk.com.

Changes To This Privacy Policy

We may update this privacy policy to reflect changes to our information practices. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

If you have any questions or suggestions regarding our privacy policy, please contact us at: 505 Poli St., Ventura, CA 93001 or via email at privacy@thetradedesk.com.