LiveRamp Services, Website and Marketing Privacy Policy (‘Privacy Policy’)

1. Extent Of This Privacy Policy
2. Personal Information LiveRamp Processes About You
3. LiveRamp’s Use of your Personal Information
4. Your Choices and Rights Regarding Your Personal Information
5. LiveRamp’s Disclosures of Your Personal Information
6. LiveRamp’s International Transfers Of Personal Information
7. Data Security
8. Data Retention
9. LiveRamp’s Contact Details
10. Updates

Annexure 1 (Services)

Annexure 2 (Website and Marketing)

LiveRamp Australia Pty Limited (‘LiveRamp’, ‘us’, ‘we’, ‘our’) respects your privacy and is committed to protecting your personal information. This Privacy Policy will inform you about how we collect, hold, use and disclose your personal information in relation to our Services (Annexure 1) and Website and Marketing (Annexure 2).

This Privacy Policy is designed to be easy for you to use, but you can always email us at: [email protected] if you have questions. You may also contact us via this Form to exercise your rights under the Australian Privacy Act 1988 (Cth) (Privacy Act).

1. Extent Of This Privacy Policy

This Privacy Policy applies to the personal information processed by us when we receive or collect personal information in the context of providing our Services (as outlined in Annexure 1) or our Website and our Marketing activities (as outlined in Annexure 2 ).

This Privacy Policy does not apply to:

• The collection of personal information about you by LiveRamp’s clients or other third parties. Our clients and other third parties are responsible for their own collection practices and use of personal information for marketing and other purposes (including their use of your personal information in our services in connection with sending you online advertising). To find out more about our clients’ collection and use of personal information, we suggest that you review their privacy policies.
• The collection of personal information in relation to recruitment or employment. For information about our collection and use of your personal information in relation to our recruitment processes, please refer to our Recruitment Privacy Policy. 
• Third-party websites, plug-ins, and apps linked to from this website..

2. Personal Information LiveRamp Processes About You

In the performance of our business, we may process personal information about you that has been made available to us by you or by our partners to whom you have made your information available. The categories of personal information are outlined in Annexure 1  (Services) and Annexure 2 (Website and Marketing).

LiveRamp does not collect any ‘sensitive information’ (i.e., information about your race, ethnicity, religious or philosophical beliefs, sexual orientation or practices, political opinions or associations, health or genetic information, trade union membership or associations, or some aspects of biometric information) or any personal information about individuals under the age of 18.

3. Purposes For Which LiveRamp May Use Your Personal Information 

We will only use your personal information as permitted by law. Most commonly, we will use your personal information for the purposes specified in this Privacy Policy and to provide you with information, products, and services. This is usually something that you have requested or for which you’ve signed up. Your personal information may also be collected in regard to any legal obligations we may have.

The specific purposes for which we use your personal information are outlined in Annexure 1 (Services) and Annexure 2  (Website and Marketing).

If you do not provide us with your personal information, we may not be able to deliver LiveRamp products and services to enable LiveRamp and its current and prospective clients and/or partners (through their use of our products and services) to deliver better marketing experiences to you.

4. Your Choices and Rights Regarding Your Personal Information

LiveRamp respects that you have the right to have control over your personal information, so we provide you with multiple choices for managing that control with us.

4.1 Opt Outs

• Marketing opt outs
  • You can ask us to stop sending you marketing and/or other messages related to our own products and/or services at any time by clicking ‘unsubscribe’ in the marketing messages we send you. You may also opt-out by submitting an online Form. 
  • Please be aware that where you opt out of receiving our own marketing messages, that opt out will not apply to any marketing messages received by you from our clients or partners as enabled by LiveRamp’s services.
• LiveRamp cookies opt outs
  • Cookies are small text files that are downloaded onto your computer and/or other devices you use to browse the internet and visit a website. Cookies allow us to recognise your device and gather some information about your preferences and past actions, which is then stored in connection with your cookie. The cookies and associated information are used to provide you with a more tailored experience on webpages, including remembering your previous activities on the website, providing you with tailored content based on your previous interactions on that website, and remembering your log-in information (where you choose to allow that).
  • You can change your default browser settings to be notified whenever a new cookie is dropped on your browser, or even to block cookies all together.

4.2 Accessing Your Personal Information 

You have the right to access personal information that we hold about you. You can request access by submitting this online Form. Please ensure that you provide us with the correct information about you so that we can identify you in our systems. When you make a Subject Access Request to LiveRamp, you are entitled to all the personal information that we hold about you (unless an exception under the Privacy Act applies). 

Please be aware that we may need you to confirm your identity before fulfilling your request, such as by asking you for a scan of your government-issued ID. We do this to help ensure that we do not provide your information to someone that may not be you, and comply with our obligations under the Privacy Act.

4.3 Correction of Your Personal Information

If you feel that we may have processed personal information about you that is incorrect, or if you wish for us to amend any personal information about you that may have changed or is out of date in anyway (i.e. you now have a different email address than what you believe we have in our system for you), then please also send your request of correction of your personal information by submitting this online Form. 

You will not have to pay a fee to exercise any of your rights. However, we are permitted by law and may charge you a reasonable fee for giving access to the requested personal information, depending on the circumstances. Alternatively, we are permitted by law to refuse to comply with your request in certain circumstances. In such a case, we will provide you with reasons for our refusal.

We try to respond to all legitimate requests within 30 calendar days. It could, however, occasionally take us longer than a month if your request is particularly complex or if you have made a number of requests. In these situations, we will notify you and keep you updated on the status of your request.

5. LiveRamp’s Disclosures of Your Personal information

We may disclose your personal information within LiveRamp and/or with third parties insofar as reasonably necessary for the purposes set out in this Privacy Policy. Please see specific disclosures in Annexure 1 (Services) and Annexure 2 (Website and Marketing).

LiveRamp requires all third parties to whom we distribute your personal information to respect the security of your personal information and to treat it in accordance with the law. We make efforts to ensure that the recipients of your personal information are reputable entities, including by conducting appropriate checks on them.

6. LiveRamp’s International Dislcosures Of Personal information 

LiveRamp is a global organisation, which means that in the performance of our business we may transfer your personal information outside of Australia. Whenever we transfer your personal information outside of Australia, we require that a degree of protection similar to the protection that we provide ourselves, is afforded to your personal information. We do not usually share personal information outside of Australia, but in some cases, we may disclose your personal information overseas including to our parent company located in the United States.

7. Data Security

LiveRamp takes protection of your information seriously and has implemented appropriate technical, organisational, and physical measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed. In addition, we limit internal access to your personal information to our employees, agents, contractors, and other third parties who have a legitimate business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

We have also put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

We take various factors into consideration to determine the appropriate retention period for your personal information, including:

• the amount, nature, and sensitivity of the personal information;
• the potential risk of harm from unauthorised use or disclosure of your personal information;
• the purpose(s) for which we process your personal information;
• whether we can achieve such purpose(s) through other means; and
• the implications of retaining your personal information under our applicable legal, regulatory, tax, accounting, and/or other necessities and obligations.

We will not store your personal information for longer than necessary to fulfil the purposes for which we collected it for or for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting obligations. We may, however, retain your personal information for a longer period as reasonably necessary for us to deal with a complaint or if we reasonably believe that litigation may be likely with respect to our relationship with you or our use or retention of your personal information.

9. LiveRamp’s Contact Details 

If you have any questions or complaints about this Privacy Policy or our privacy practices, please contact us in the following ways:

By email to LiveRamp: [email protected]

By post to LiveRamp: LiveRamp Australia Pty Limited, 03W103, WeWork 1 Sussex St, Barangaroo, 2000, NSW, Australia

10. Updates

Please be aware that we may update our Privacy Policy from time to time at our discretion to ensure legal compliance and to meet our business needs. If we make any important changes to this Privacy Policy that may affect you, we will bring this to your attention in a clear and appropriate manner, such as by a pop-up notice upon visiting our website, and will include the date of such updates at the bottom of this page.

This Privacy Policy has been updated on: [31 October] 2022

Annexure 1 – Services

This Annexure sets out specific details about LiveRamp’s collection, use, handling and disclosure of your personal information, from/to our clients and partners, in the context of delivering LiveRamp products and services, including how LiveRamp and its current and prospective clients and/or partners (through their use of our products and services) may use this information to deliver better marketing experiences to you. To avoid any possible confusion, LiveRamp, in delivering its products and services, does not directly collect personal information from end users/consumers, and only process and use personal information under the instructions of our clients and/or partners.

1. Personal information LiveRamp collects/receives and processes about you
• Identity Data, such as first name, maiden name, last name, username (or similar identifier), title, date of birth, and gender;
• Contact Data, such as postal address, email address, and telephone number;
• Unique Identifiers and Associated Data, such as the online and offline IDs that we create or collect, including IDs that we use internally only for identity recognition purposes and IDs that we share with our clients and providers, as well as Technical Data associated with the IDs;
• Transaction Data, such as details received from our clients about products and services you have purchased or ordered, as well as information related to payments made to and by you;
• Technical Data, such as internet protocol address (commonly known as your ‘IP address’), your log-in data, web browser type and version used, time zone setting and country, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access websites;
• Usage Data, such as information about how you use websites and their products and services.
2. Purposes For Which LiveRamp May Use Your Personal Information

The primary purposes for which LiveRamp will use your personal information in the delivery of our products and services is to allow us to create and provide solutions to our clients and providers to be used for recognition and online targeted advertising.

Recognition is where we use our technology to generate IDs out of the personal information provided to us by our clients and send them to destinations/distribution partners as instructed by our clients. For example, a client would use our services to better serve advertisements to their customers. Such client sends us a file of their customer data, which we then create a client-specific pseudonymized LiveRamp proprietary identifiers (“RampID”) using our algorithm. We then delete all directly identifiable personal information received from the clients/partners, unless we are instructed. We exchange this RampID data list (the audience) with our Distribution Partners, who then facilitate the sending or display of the client’s advertisements to those consumers. The recognition process is used to assist our clients with online targeted advertising and measurement of advertising effectiveness. More specifically, we may process information about you:

• For online interest-based advertising displayed to you by our Distribution Partners at the direction of our clients. For example, if you have visited a clothing-related website and browsed through or purchased sports clothing, you may then see advertisements for sports clothing on other websites. This is due to a cookie being placed on your device that has associated you with the advertiser’s audience of consumers interested in sports clothing, which is then used by the advertiser through our services and products.
• For use in the measurement and performance of analytics of the effectiveness of our clients’ advertising campaigns. For example, a sports clothing company wants to better understand if its website advertisements for a new line of sports clothing contributed to an increase in sales. Our services and products can be used by the advertiser to see how many ads were viewed and actually clicked on, and if the consumer purchased any of the advertiser’s sports clothing.
• For enabling our clients and partners to personalise their products and services to you, such as through website and email personalisation or dynamic marketing and advertising optimisation. For example, if you have previously indicated an interest in sports clothing and then visit a sports clothing company’s website, that company can display offers for sports clothing tailored for you on their website.
• For enabling our clients and partners to connect your online behavioural preferences across the various browsers and/or devices you use to more accurately market to you. For example, you are logged into multiple devices (such as your desktop, your smartphone, and your tablet) using the same login and have clicked on a sports clothing company’s online advertisement on at least one of those devices. Where we determine that you are most likely the same user logged in on those different devices, we will communicate that information to the partner. The sports clothing company can thus display more consistent offers to you via automated technologies (such as a de-identified device ID or email address) on your different devices.
• For creating modelled audiences to which our clients can market their products and services. For example, a sports clothing company is looking for new potential customers who are likely to be interested in sports clothing. The sports clothing company can use our services and products to look for key characteristics between consumers with similar characteristics that have shown an interest by their online activities in shopping for sports clothing and other consumers with some of the same similar characteristics. A similar interest can be inferred or anticipated based on these similar characteristics, such as from browsing for sports shoes.

In addition to the above, we also process personal information for the following additional purposes:

• To analyse, develop, and improve the use, function, and performance of our products and services. For example, we may process personal information for our own research and development purposes in support of our products and services, such as to enhance the quality of our products, to develop new features and support new functions of our services, and for internal statistical analyses of our products’ and services’ performance.
• To manage the security of our sites, networks, and systems, and to operate our business. We may collect usage and systems operations data from our website(s) and/or services platform(s) in order to better manage our operations and/or to help keep our products and services secure (including your information), as well as to investigate and help prevent cyber-attacks or potential fraud, including ad fraud and to detect bots. We may also process personal information in the operation of our day-to-day and overall business, such as when we conduct audits and investigations, as well as for finance, accounting, archiving, and/or insurance purposes.
• To comply with applicable laws and regulations. In some cases, we may process personal information as part of our compliance with applicable laws and regulations, such as in responding to a request from a regulator or to defend a legal claim.
3. LiveRamp’s Disclosures of Your Personal information

We may share your personal information to the following parties:

• to our clients (or their advertising agencies) who are ‘brands’ for their use in marketing and advertising to consumers like you. Some examples of our clients’ industry types that you could expect to use your data include automotive, education, retail, travel and leisure, home improvements, mail order, market research, publishing and media (including social media), and consumer goods (such as cosmetics and food),.
• to our Distribution Partners, such as online advertising platforms and other marketing companies who send you advertisements at the direction of their own advertising clients. 
• to third-party service providers who support us and our own services and products;
• in the event we acquire or merge with other businesses. If this occurs, then the new owners may use your personal information in the same way as set out in this Privacy Policy; or
• to comply with legal obligations (such as subject to a subpoena or other legal processes), in order to protect both your and our rights, and to ensure your safety. Such instances can include situations where we must respond to government requests, investigate fraud, and even where we respond to public and government authorities outside your country of residence for national security and/or law enforcement purposes.

Annexure 2 – Website and Marketing

This Annexure sets out specific details about LiveRamp’s data handling practices in relation to your visits to and uses of LiveRamp’s website, as well as in relation to marketing communications sent directly to you from us.

1. Personal information LiveRamp collects and processes about you
• Identity Data, such as first name, maiden name, last name, username (or similar identifier), date of birth, and gender;
• Contact Data, such as postal address, email address, and telephone number;
• Technical Data, such as your internet protocol (‘IP’) address, log-in data, time zone setting and location, web browser type and version used, web browser plug-in types and versions used, operating system and platform used, and other technology on the devices you use to access websites;
• Usage Data, such as information about how you use websites and their products and services; and
• Marketing and Communications Data, where you have stated that you would like to receive marketing from us and our third parties.

In the performance of our websites and our own marketing activities, we may process personal information about you that has been made available to us by you or by our partners to whom you have made your information available, such as:

• CRM: Customer Relationship Management and data platform
• Marketing Automation and Communication: Using client and prospect data to run personalised email programmes
• Web Analytics: Analysing website performance through traffic statistics
• Social Media Monitoring: Analysing engagement and brand interaction across social media platforms

Please be aware that we may collect your personal information by asking you to provide us with information about yourself and the company for which you work so that we can register you for certain products and services that you request or about which you request materials. The information you provide us will solely be used to:

• Support and develop your relationship with us;
• Help make our website(s) become easier for you to use; and
• Inform you of services and product updates, new products, and other related information.

We may also collect, use, and share statistical information that is not particular to you or any other individual, but rather represents a category or group with the same or similar interests or characteristics (which we call ‘Aggregated Data’) and that could be derived from your personal information and may be used for any purpose. You should be aware that Aggregated Data is not considered personal information under law, as it does not directly or even indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal information so that it can then directly or indirectly identify you, we treat the combined data as personal information and only use it in accordance with this Website and Marketing Privacy Policy and relevant laws.

2. Purposes

In the performance of our websites and our own marketing activities, LiveRamp processes your personal information for various purposes, which may include any of the following:

• To communicate with you. Where you have made any inquiries and/or requests to us (such as by submitting contact forms on any of our websites or sending us an email), we may process information about you to communicate with you to best respond to your inquiries and/or requests.
• To market our products and services to you. We process personal information about you to help enable us to market (both online and offline) our products and services to you based on your interests. More specifically, we may process information about you:
• To register for and/or allow you to subscribe to our special offers, demonstrations of our products and services, or seminars and events, such as LiveRamp’s annual RampUp conference;
• To sign you up to participate in surveys or even contests that we might provide;
• To allow you to download different papers and/or articles that we write, produce, or otherwise make available; and/or
• To actually provide you with access to our “Software as a Service” products, such as our Connect platform.
• To manage the security of our websites, networks, and systems, as well as to operate our business. We may process usage and systems operations data from our websites in order to better manage our operations, as well as to investigate and help prevent cyber-attacks or potential fraud. We may also process personal information in the operation of our day-to-day and overall business (such as when we conduct audits and investigations); for finance, accounting, archiving, and/or insurance purposes; as well as to help analyse, develop, optimise, or simply improve the use of our websites and products and services.
• To comply with applicable laws and regulations. In some cases, we may process personal information as part of our compliance with applicable laws and regulations, such as in responding to a request from a regulator or to defend a legal claim.

In order to best support the above-mentioned activities, we will ask you for personal information about you and/or the company for which you work. This allows us to better support and develop your relationship and interactions with LiveRamp.

3. LiveRamp’s Disclosures of Your Personal information

We may share your personal information to the following parties:

• to third-party service providers who support us and our own services and products (such as to Salesforce – CRM data platform, Marketo – Marketing Automation and Engagement platform, Sales Loft – Sales Communication platform, and Google Analytics – Web Analytics platform);
• in the event we acquire or merge with other businesses. If this occurs, then the new owners may use your personal information in the same way as set out in this Privacy Policy; or
• to comply with legal obligations (such as subject to a subpoena or other legal processes), in order to protect both your and our rights, and to ensure your safety. Such instances can include situations where we must respond to government requests, investigate fraud, and even where we respond to public and government authorities outside your country of residence for national security and/or law enforcement purposes.