PRIVACY POLICY

CREDEBAT put a lot effort to make the way of using 1st Party Data more secure and trustable to all the party, we also protecting the consumer data of our clients as well as personal information of our Users. 

Application

CREDEBAT provides a technology platform designed to help 1st Party data operators manage and protect consumer data. This privacy policy governs the technology platform (the “Platform”) as well as our CREDEBAT website located at www.credebat.com (the “CREDEBAT Site”), and any information provided to us by employees or potential employees.
We provide a Platform that enables our clients to manage their digital data subject to their own privacy policies. In that way, we enable our clients to manage their data in a responsible way and we empower consumers to better understand what data is collected via the Platform and how it is used.
Before using CREDEBAT Platform as well as services, please read this Agreement carefully and make sure that you understand all the definitions and provisions of this Agreement. This Privacy Agreement applies to all technology platforms provided by CREDEBAT, and defines the procedure for collecting and using personal data.

CREDEBAT Technology Platform

CREDEBAT is an agent working under the direction of our Clients which are generally website and/or mobile application owners or operators that use our Platform. We offer a data management Platform that collects Non-PII from Internet users when they visit the website or mobile applications of one or more of our Clients (the "Client Site" or “Client App”, collectively, the “Client Site(s) and App(s)”). We don’t place PII on the Platform nor do we allow our Clients to do so. This data is collected and used subject to the individual privacy policy for each Client. We use a number of different technologies to maintain user state, collect data, and to help us operate the Platform and describe some of them below.

Cookies, anonymous identifiers and other services

HTTP Cookies

CREDEBAT uses cookies in connection with the Platform, including on the CREDEBAT Site and Client Sites. Cookies are small, often encrypted text files, located in browser directories.  All CREDEBAT cookies other than the CREDEBAT Opt-Out cookie expire automatically if inactive for six (6) months. When a user visits one of our Client Sites, the user is assigned a CREDEBAT user ID that is placed into an HTTP cookie which is then placed on that user’s computer or device. 

HTML5 Cookies

CREDEBAT uses HTML5 cookies in Connection with the Platform, including on the CREDEBAT Site and most Client Sites. An HTML5 cookie is also known as HTML5 Web storage and is an alternative to the commonly used HTTP browser cookie. CREDEBAT uses HTML5 cookies as a backup storage mechanism to HTTP cookies; storing both ad targeting data as well as user opt-outs in both HTTP and HTML5 cookies (collectively, our “Cookies”).

Statistical Identifiers

CREDEBAT is experimenting with the use of statistical identifiers in connection with the Platform, including on the CREDEBAT Site and some Client Sites where requested by Clients. Statistical identifiers are created using non-PII about computers and mobiles devices such as the operating system, user-agent string, IP address (in jurisdictions where this is not considered to be personal data), Internet browser, installed fonts, and similar information. This information makes your computer or device distinct enough for our systems to determine within a reasonable probability that they are encountering the same computer or device. Statistical identifiers enable users to be uniquely identified via the Platform, enabling the Platform to store ad targeting, analytics and other data. If you want to see whether CREDEBAT is using a Statistical Identifier on the browser you are currently using, please visit Opt-out page.

Pixel Tags

We also use pixel tags in connection with the Platform, including on the CREDEBAT Site and Client Sites. Pixel tags (also known as web beacons) are small strings of html or JavaScript code that provide a method for delivering a graphic image on a Web page or other document. Pixel tags may be used to obtain information about the computer or device being used to view a particular Web page such as the IP address of the computer or device to which the pixel tag is sent, the time it was sent, the computer or device’s operating system and browser type, and similar information.

Mobile Device Identifiers

CREDEBAT uses mobile device identifiers such as the Android Advertising ID and Apple iOS’ IDFA in connection with the Platform where Clients ask CREDEBAT to store information collected via Client Mobile Apps. Mobile device identifiers enable users to be uniquely identified via the Platform, enabling the Platform to store ad targeting data.

How we Collect and use Non-PII via our Technology Platform

CREDEBAT offers a technology Platform for website and mobile application operators, and we utilize the Platform when users visit the CREDEBAT Site. When a user visits the website or mobile application of one of our Clients (the "Client Site" or “Client App”, collectively, the “Client Site and App”), the Client collects and transfers to CREDEBAT and/or enables CREDEBAT to collect Non-PII related to that user’s visits to their website or mobile app (our Client’s "Session Data"). This Session Data may include information about how the user came to the Client Site and App, which search engines they use, the search terms used to find the Client Site, their experience on the Client Site and App, information about how they interact with the Client Site and App, demographic information that the Client has collected from that user and other visitors, data from third-party data providers, and information regarding how users interact with advertisements on the Client Site and App.  Additionally, browsers send certain standard information to every website a user visits, such as an IP address, browser type and language settings, access times, and referring website addresses. This information is collected during visits to each Client Site and App, including the CREDEBAT Site. We make Session Data accessible only to each individual Client. The Client typically uses this data on our Platform to deliver targeted advertising campaigns both on the Client Site and App as well as off their sites and apps. For example, Clients may use the Platform to help them find interested users and to deliver ads that attempt to bring those users back to the Client’s Site and App.  Where our systems can reasonably infer that a particular computer and/or mobile device belong to the same user or household, we may store such information for use on the Platform. The data stored on our Platform may be combined with other third party data in order to better target advertisements, to enable Clients to better understand users across multiple computers and devices, and for ad delivery and reporting purposes.
While CREDEBAT does not allow PII directly onto the Platform, we do receive PII from Clients outside of the Platform. Typically, we receive the PII as part of an onboarding process whereby CREDEBAT receives data that contains PII and render that data into Non-PII targeting segments utilizing a privacy-by-design process. CREDEBAT may work with a third-party technology partner to help facilitate the onboarding process.
CREDEBAT does not directly share Non-PII with either partners or third parties.  Clients may choose to share their Non-PII data with others at their discretion, and CREDEBAT may assist them to share user data collected on those Client Sites and Apps. Reporting is done at the aggregate level, with no user level information accessible.

Sensitive Data

In accordance with industry standards, we do not knowingly collect, manage, or enable the commercial use of PII relating to children less than 13 years of age.
CREDEBAT does not knowingly collect, use, or store sensitive information on our technology Platform.  Sensitive information ("Sensitive Data") includes certain types of information associated with a specific individual, such  Government-issued identifiers, financial account numbers, sexual orientation, precise information about an individual's past, present, or potential future health or medical conditions or treatments (such as diabetes, heart attacks, etc.), including genetic, genomic, and family medical history. Sensitive Data also includes information deemed sensitive by a particular jurisdiction. For example, laws of the European Union, Australia and Canada have additional restrictions on the use of Sensitive Data as defined by those jurisdictions. CREDEBAT imposes rules around delivering targeted advertisements via our Platform based upon knowledge of precise medical conditions or other Sensitive Data.  Clients may request that CREDEBAT collect non-sensitive data for items such as skin care products, diet pills, allergies medications, and cold and flu treatments in order to target advertisements and as otherwise specified by each Client’s privacy policy.

Opt-Out

Browser Opt-out
CREDEBAT offers a one click opt-out solution here for users who wish to opt-out solution here.  If you choose to opt-out, CREDEBAT deletes any targeting data it may have for your browser, and we will no longer enable our Clients to target that browser using our technology Platform.  You will likely still receive advertisements, but CREDEBAT technology will have no input or impact on tailoring those ads.  Please note that if you delete, block, or otherwise restrict cookies, or if you use a different computer, device or Internet browser, you will need to renew your opt-out choice. Also, because we utilize HTML5 cookies to record your opt-out choice, it may take an additional visit to one of our Clients’ websites for your opt-out choice to go into effect. To the extent that a particular browser and a mobile device are linked via our Platform, opting out will sever the link.

Mobile App Opt-out
To opt-out of the collection and use of data for interest-based advertising on your mobile device, you can modify the settings on your mobile device. For example:
For Apple Devices: Go to Settings, Select Privacy, Select Advertising, and enable the “Limit Ad Tracking” setting.
For Android Devices: Open the Google Settings App, Select Ads, and enable the “Opt out of interest-based advertising” setting.

Note: The specific opt-out instructions for each device may differ slightly depending on which version of the operating software you are running.
Note: Even after you opt-out of the use of your information by Lotame for Interest-Based Advertising, Lotame may continue to collect and use such information for other purposes, including analytics and research. Should you elect to opt-out, you will still receive ads, but these ads may be less relevant to your interests.
Also, after choosing to opt-out via any of the methods above, if you use a different device or a different browser, or if you delete browser cookies, you may need to repeat the opt-out steps for that particular device or browser. In addition, if you block cookies on your browser or if third-party cookies are blocked by default, some of the opt-out tools above may not function.
Do Not Track
Some web browsers offer a mechanism, known as a "Do Not Track" ("DNT"), that allows a user to elect to stop the collection of certain browsing data by websites and technology companies. Currently, the standards regarding the DNT signals and appropriate responses are not defined.  As a result, CREDEBAT is experimenting with DNT and may place an opt-out cookie on computers or other devices when we see a valid DNT signal.

Changes

From time to time, we may update this privacy policy to reflect changes in industry standards or evolving legal requirements when necessary and all changes will comply with regulatory, legal, and industry standards. Please review this privacy policy from time to time to remain informed regarding how CREDEBAT is protecting your information.  If we decide to utilize information about you for a purpose that is significantly different from the one described in this privacy policy, or that was conveyed to you, we will give you the chance to choose not to have your data used in that way (e.g., opt-out).
2 May 2017

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