Privacy Policy

Innovid, LLC, having its principal office and place of business at 30 Irving Place, 12th Floor, New York, NY 10003, together with its affiliates and subsidiaries from time to time, including without limitation Innovid EU Ltd., Innovid Media Limited, Innovid AU PTY Ltd., Innovid Argentina SRL, TV Squared, Inc, TV Squared Limited and TV Squared GmbH (collectively, “Innovid”, “our”, “we”, or “us”) has a strong commitment to protect the data privacy of its clients, partners, suppliers and their representatives as well as its website and site visitors and users. Our Privacy Notice describes how information is collected and utilized by Innovid. This Privacy Notice (the “Policy”) describes the data we collect about visitors to the websites and platforms located at Innovid.com, tvsquared.com, and subdomains thereof, including Innovid’s user interfaces available through such websites and platforms (collectively, the “Innovid Websites”), and to end users of the various third party websites, applications and other online media on which Innovid’s advertising and measurement services (the “Services”) are deployed. Please contact us with any questions or concerns at privacy@innovid.com.

Please read the following carefully to understand our practices regarding your information and how we will treat it.  By accessing or using the Innovid Websites or Services, you agree to us processing your information in accordance with this Policy.

The Innovid Websites may link to, and the Services may appear on, third party websites and online media. Innovid does not control and is not responsible for the privacy practices of third parties, and this Policy does not cover collection or use of information by third parties on such properties. Visitors to or users of such third party websites or other media should consult the privacy policies of such properties to learn about such third parties’ privacy practices.

With respect to data governed by: (i) the EU’s General Data Protection Regulation 2016/679 (“GDPR“), (ii) the GDPR as transposed into UK national law by operation of section 3 of the United Kingdom’s (“UK”) European Union (Withdrawal) Act 2018 (the “UK GDPR”); or (iii) the Swiss Federal Act on Data Protection 1992 (“Swiss DPA”), some of the data processed by Innovid includes “personal data”, as further described below under the Section entitled “Additional Information for Residents of the European Union, UK and Switzerland” and “The EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF”. With respect to data governed by the GDPR, the UK GDPR and the Swiss DPA, and for the benefit of Data Subjects, we have added clarifications to this privacy policy for clarity and transparency.

Except as stated under the Section entitled “Additional Information for Residents of the European Union, UK and Switzerland” below, this Policy does not cover Innovid’s collection, use or disclosure of information relating to employees of Innovid or candidates for employment with Innovid (collectively, “HR Data”), as Innovid provides a separate privacy policy to such individuals governing HR Data.

Quick Guide to Content

Innovid Website Visitors
Enterprise Customers of the Services
Google Analytics
Intercom
Pendo
Cookies on the Innovid Website
Innovid’s Services
Cross-Device Tracking
Industry Self-Regulation
Opt-Out of Interest-Based Advertising
Do Not Track Signals
Data Retention
Legal and Regulatory Compliance
Affiliated Entities and Third Parties
Business Transfers
Newsletter Subscriptions
Aggregate Information
Communication
Data and Information Security
Children’s Privacy
International Data Transfers
Additional Information for Residents of the European Union, UK and Switzerland
The EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF
Enforcement Complaints
Additional Privacy Information For Residents of California, Virginia, Colorado, Connecticut, Utah, Nevada, Texas, Oregon, and Other U.S. States in Which an Applicable State Privacy Law is in Effect
Contact

Innovid Website Visitors

We collect information about your visit to our Websites, including:

– information about your activity on our Websites, including mouse scrolls and clicks, keystrokes entered, clickstream behavior, pages and files viewed or visited, and the duration of such visits.

– information about the devices and software you use to access our Websites, such as browser information, operating system information, device identifier, IP address, general geographic location, date, and time of visit, whether you are a new or a return visitor, and other such information as may be delivered or shared by the applicable browser or access software or device.

– any phone number used to call our customer service number.

– any other information you provide to us through our Websites, including via our contact form or live chat function.

Collectively, “Website Data”.

Where legally required, our collection of Website Data is subject to the End User setting their preferences as further described under the section entitled “Cookies on the Innovid Website”.

Enterprise Customers of the Services

If you are an agency, brand or publisher that is a customer of our Services (a “Customer”), or if you are an employee, staff member or personnel of a Customer, we collect:

– your contact information, including name, title, company name, business address, email address, telephone number and login credentials.

– information about your activity on our Websites, including mouse scrolls and clicks, keystrokes entered, clickstream behavior, pages and files viewed or visited, and the duration of such visits.

– information about the devices and software you use to access our Websites, such as: browser information, operating system information, device identifier, IP address, general geographic location, date and time of visit, whether you are a new or a return visitor, and other such information as may be delivered or shared by the applicable browser or access software or device.

– any phone number used to call our customer service number.

– any other information you provide to us through our Websites, including via our contact form or live chat function.

Collectively, “Account Data”, We use and retain the Account Data, alone or in combination with Website Data, in order to provide our Services to you, manage and maintain the relevant account, conduct internal analysis, perform billing, invoicing and payment functions in connection with the relevant account, send Services-related information, alerts and promotional messages to you, monitor and assist in improvements to the Innovid Websites and our Services, customize your experience on the Innovid Websites, and maintain and improve the performance of the Innovid Websites and Services.

We also receive information about existing and prospective Customers from third party partners, from attendance at events such as talks, presentations and seminars, from publicly available sources, and from general business networking efforts.

Google Analytics

Innovid uses Google Analytics, a service provided by Google, to help analyze how users use the Innovid Websites. Google Analytics uses “cookies”, which are text files placed on a user’s computer or device, to track the user’s activity (including information such as the user’s flow, location by country, language, browser and OS, ISP, and devices) on the Innovid Websites. We use this service with a view to analyze usage across devices and offer improvements for all users. To learn more about Google Analytics, please click here. To opt out of this feature by installing the Google Analytics Opt-out Browser Add-on, please click here. You may also opt-out by blocking cookies from the Websites.

Intercom

For customer management purposes, we provide a limited amount of information about users of the Innovid Websites and user interface (such as the user’s email address and sign-up date) to Intercom, Inc. (“Intercom”). We utilize Intercom for additional data analysis, e.g., retrieving a user’s sign-up date or activity when providing customer support. We may also use Intercom as a medium for communications, either through email, or through messages within our product. To help us understand our user base, Intercom collects publicly available information, such as a user’s company, job title, website URLs, social network handles and physical addresses. For more information on the privacy practices of Intercom, please visit http://docs.intercom.io/privacy. If you would like to opt out of having this information collected by or submitted to Intercom, please click here.

Pendo

Innovid uses Pendo.io to better understand how our customers are using our platform and tools, in order to assist our product and product design team(s) when making updates to our platform. Through the use of a java script pixel on the Innovid platform, Pendo may collect a limited amount of behavioral information from customers accessing the Innovid platform, and in addition Innovid may share a limited amount of data with Pendo in order to tie the information together. The information Innovid shares with Pendo includes, name, user ID, email address, and country. To learn more about Pendo, please click here. To view Pendo’s privacy policy and learn more about your choices, please click here.

Cookies on the Innovid Website

Innovid, and Innovid’s vendors performing services in relation to the Innovid Websites, may collect the data described above, including personal data, using cookies, which are small text files stored on the visitor’s computer. Visitors can set their browser to reject cookies altogether, to reject Innovid’s cookies in particular, or to delete cookies. For our EU and UK based website visitors, we also put in place a cookie consent tool on our site. Aside from strictly necessary cookies, we will only place cookies on the browsers of EU and UK visitors subject to their consent.

Innovid’s Services

Innovid partners with numerous companies to provide and measure online advertisements to visitors of third party websites, mobile websites, mobile applications, connected applications, smart televisions, digital media streaming devices and other online media, and to measure the performance of advertisements across various third party linear and digital televisions, channels, platforms, and devices (collectively, “Media Properties”). Visitors to Media Properties are referred to herein as “End Users”.

Data Collected from End Users: When an End User browses or uses Media Properties that make use of the Services, Innovid may collect data about such interaction, as well as about any further interaction by such End User with the advertisements provided or measured by the Services and the Media Properties on which such Services are utilized, such as advertisements viewed, impressions, clicks and other actions taken, mouse movements, viewing duration, IP address, cookie ID, date and time of interaction, information about the general geographical location from which an End User is viewing an advertisement, device type, URL, referral URL, information on browser and operating system, user agent and device type. In addition, in the event that the data being collected is from a mobile device, Innovid may also collect the mobile advertising ID of the device (e.g., IDFA and Google AdID), and in the event that the data being collected is from a television with third party connected applications, a smart television, or a digital media streaming device (collectively, “CTV”), Innovid may also collect the advertising identifiers made available by the CTV.

Data Collected from Agencies, Brands, and other Customers of Innovid: Brands, agencies and other customers who use Innovid’s measurement services may provide or upload advertising delivery or viewership information to Innovid, including IP addresses, cookie IDs and/or advertising or device IDs, in order to enable Innovid’s provision of such measurement services to such customers. Innovid is a Processor (under GDPR) and a Service Provider (under CCPA, CPRA and similar laws) on behalf of its customers, with respect to the data described in this paragraph.

Data Collected from Third Party Sources: On occasion, Innovid may also receive data from third parties that enable advertisement optimization and/or measurement, independent of or in combination with the data collected by Innovid from End Users, such as audience interest segments, ad viewership or delivery information, television spot data, and product or media categories. It is possible that some of the data that Innovid obtains from third parties was previously associated with directly identifiable information (such as address, phone number, email and/or mailing address). However, this data goes through a de-identification process before it is shared with Innovid, such that by the time it reaches Innovid, it no longer contains directly identifiable information.

The data collected by Innovid and/or received from third parties may be shared and used to provide information, analytics and reports to advertisers, agencies and publishers who participate in the Services, to schedule, deliver and optimize advertisements, to limit the number of times a specific advertisement is presented to the same browser or device (frequency capping), to detect and eliminate fraudulent activity, to administer and enhance the Services and perform internal analysis, and to help Innovid display, optimize, target, sequence and/or customize advertisements to the inferred interests or preferences of End Users. Innovid may use certain general health-related segments received from third parties in delivering advertisements based on inferred End User interest in such topics, such as general health, wellness, common ailments and illnesses, beauty, and fitness. Such health-related segments do not include sensitive health information (such as an End User having a certain medical condition like heart disease or arthritis).

From time to time, advertisements served by Innovid contain functionality that enables an End User to enter personal data into such advertisements or into the landing page to which such advertisements are linked, in order to allow the End User to sign-up for or receive information regarding an advertiser or publisher’s product, service, program or other offer. In the event that an End User elects to provide personal data under such circumstances, Innovid stores such information and shares it with the advertiser, agency, or publisher on behalf of whom the advertisement was served, and/or with such entity’s service provider. Innovid may use such information to fulfill or aid in the fulfillment of the End User’s request and/or to auto-populate future requests by the End User’s device. In cases where the advertisement contains functionality enabling Innovid to store personal data, the End User will have the option to opt-out of the storage of such information by indicating their preference in the appropriate checkbox shown in the advertisement, or by clicking through to the settings available through the advertisement. The End User should review the advertiser or publisher’s privacy policy to understand how such entity will process any personal data entered by the End User or captured. In order to exercise End User’s rights to delete, access, rectify or move personal data, the End User must contact the controller (our customer). In some cases we are able to support exercise of these rights. If you have any other questions or requests with respect to privacy, please send us an email at privacy@innovid.com.

Innovid works with Nielsen to better understand the reach of ad campaigns. To learn more about what information Nielsen collects, how it uses and shares that information and your choices, please visit http://www.nielsen.com/digitalprivacy.

Innovid uses Google’s YouTube API Services. The Google Privacy Policy can be found at: https://policies.google.com/privacy and the Google App Permissions page can be found at: https://myaccount.google.com/permissions. The YouTube Terms of Service (ToS) can be found at: https://www.youtube.com/t/terms.

Cross-Device Tracking

Innovid may, or may use the services of third party companies to, establish connections between a user’s devices and to provide interest-based advertising across devices and to measure the performance of advertising across devices. Cross-device connections allow Innovid to understand that a single user is accessing advertisements served or measured by Innovid from multiple devices, and to synchronize or target advertising messages and/or measure the performance of advertisements across those devices. If you would like more information about this practice and to know your choices with respect to it, please: (1) visit the NAI Choices page located at http://www.networkadvertising.org/choices/ to learn how to opt out of having your information collected in browsers for ad serving purposes; and (2) download the AppChoices application, available for iOS and Android (see http://www.aboutads.info/appchoices/), or visit the NAI’s Mobile Choices page located at http://www.networkadvertising.org/mobile-choice, to learn how to opt out of having your information collected in mobile apps. Because web browsers and mobile apps have different identifiers, you will need to opt-out of each environment separately.

Industry Self-Regulation

Innovid LLC, and its subsidiary TV Squared Ltd. dba InnovidXP, each participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Innovid LLC’s identification number within the framework is 452, and TV Squared Ltd. dba InnovidXP’s identification number within the framework is 985.

Innovid is a member in good standing of the Network Advertising Initiative (NAI).

Opt-Out of Interest-Based Advertising

Opt-out for Desktop or Mobile Web:

End Users can opt out of interest-based advertising served by Innovid on browsers used on desktop or mobile web. Click Here to opt-out, or opt-out through the NAI page located here. In order to comply with an opt-out request, Innovid may set a non-unique cookie for the sole purpose of complying with such request. Innovid will attempt to set such opt-out cookie for 5 years; however, the End User’s browser may impose a shorter timespan. If the browser causes the opt-out cookie to expire, or if an End User deletes its cookies or changes computers or devices after opting out, he or she will need to opt out again by clicking the link in this paragraph. Please note that where an End User blocks cookies on his or her browser, Innovid will be unable to set an opt-out cookie, and therefore unable to abide by such End User opt-out request.

Opt-out for Mobile Applications:

To opt-out of interest-based advertising for the mobile applications on your current device, the method of opting out depends on the type of device you have. Please also note that, in some cases (i.e., if you have an older device), it may be necessary for you to provide your device ID in order to opt out.

Opting out on Apple iOS devices: On iOS 12.4 go to Settings -> Privacy -> Advertising -> Limit Ad Tracking. On iOS 7.0 through 12.3, you can go to Settings -> Privacy -> Advertising and set the “Limit Ad Tracking” function to ‘ON’. For other (older or newer) iOS devices, please visit the NAI’s Mobile Choices Page located at https://www.networkadvertising.org/mobile-choices# for instructions.

Opting out on Android devices: In Android devices with Android 12.0 or higher, open your device’s settings app: Settings -> Google, or (depending on your device), open the Google Settings app. Under ‘Services’, select Ads. Depending on your device, turn on the ‘Opt out of ads personalization’ or opt of ‘out interest-based ads’ function by moving the switch to the right until it turns blue, or click on “Delete Advertising ID”. Note: If you clear your cache, you may lose your opt-out setting and may need to opt out again.

For older devices, please visit the NAI’s Mobile Choices Page located at https://www.networkadvertising.org/mobile-choices# for instructions. Please also visit the NAI’s Mobile Choices Page located at https://www.networkadvertising.org/mobile-choices# for additional detailed instructions on how to use the advertising choice mechanisms for various devices.

Opt-out for CTV:

To opt-out of interest-based advertising for a CTV (i.e., televisions with third party connected applications, smart televisions and/or digital media streaming devices), please visit the NAI’s Internet Connected TV Opt-Out Instructions Page located at https://www.networkadvertising.org/internet-connected-tv-choices/ for detailed instructions on how to use the advertising choice mechanisms for various types of CTVs.

Note: Following an opt-out using any of the above methods, Innovid’s system will still provide advertisements to the End User. Please note, however, that these advertisements may be less relevant to such End User’s interests.

Opt Out of InnovidXP Measurement Services:

The advertiser, as the owner or manager of its website and applications, is responsible for informing its end users about all data being collected (including by Innovid) and for collecting appropriate consents and honoring all opt-out choices from End Users, in accordance with applicable data and privacy laws.

End Users may also wish to manage their cookies on a wider basis through their browser or operating system settings on their computer or device. They can find out instructions on how to do this through the browser or operating system they are using.

The Digital Advertising Alliance (www.digitaladvertisingalliance.org/) and Network Advertising Initiative (www.nai.org) also provides helpful resources for end users in relation to opting out of interest-based ads, re-setting advertising IDs, and limiting ad tracking.

Do Not Track Signals

Some websites have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.

Data Retention

Personal data collected by Innovid, whether from desktop, mobile devices, mobile applications, CTVs or other Media Properties and advertisements may be retained for up to 12 months. Personal data is anonymized and used for reporting and analysis and may be stored as long as necessary to fulfill a legitimate business need or as required by law.

Personal data collected for the InnovidXP measurement offering (in cases where Innovid is not providing ad serving services) is retained for a period of 7 days. Personal data may be anonymized and used for reporting and analysis and may be stored as long as necessary to fulfill a legitimate business need or as required by law.

Legal and Regulatory Compliance

Innovid reserves the right to disclose information if it believes, in good faith, that such disclosure is required to comply with legal or regulatory requirements, or to protect others’ rights or prevent harm, including in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Affiliated Entities and Third Parties

Innovid provides information shared under this Policy:

with companies within the Innovid group;
with third parties approved by you, your agent, or your client as appropriate;
as described under “Enterprise Customers of Innovid” and “Innovid’s Services” above;
with third party service providers we engage to perform functions and services on our behalf, such as cloud services for storing and processing information (e.g., Amazon Web Services, Snowflake and Akamai), customer relationship management services (e.g., Salesforce) and enterprise resource planning services (e.g., Priority), to the extent necessary to enable such third party service providers to perform such functions and services, and only pursuant to obligations on such third party service providers that are consistent with this Policy.

In all cases in which Innovid transfers any personal data to a third party, it will do so pursuant to a data protection agreement governing such transfers. Where personal data is transferred outside of the EU or UK, appropriate safeguards are used such as the EU Standard Contractual Clauses and the UK International Data Transfer Addendum, as applicable, and/or Innovid’s certification under the E.U.-U.S. Data Privacy Framework, the UK Extension to the E.U.-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework.

Business Transfers

We will disclose personal data we have collected to third parties if we sell or buy any business or assets, in which case we will disclose your information to the prospective seller or buyer of such business or assets or if Innovid or substantially all of its assets are acquired by a third party, in which case information held by Innovid will be one of the transferred assets. Such transfers will be subject to contractual data protection provisions.

Newsletter Subscriptions

If you subscribe to the Innovid newsletter, or sign up to receive other forms of marketing information from Innovid, we will collect from you the following pieces of information: name, email, job title, company, company type, country, and state. We collect and store this data to provide you relevant information about Innovid products, services, and other marketing communication that may be of interest to you.

This information is also used for sales prospecting. You can change your subscription status with regards to Innovid’s email newsletters at any time. To unsubscribe, you can follow the instructions on the bottom of each newsletter, or by emailing support@innovid.com and writing “Cancel Newsletter Subscription” in the subject line.

Aggregate Information

Innovid may share aggregate and pseudonymous usage statistics regarding the Services with the public or businesses with whom Innovid works. Innovid may also use such aggregated information to help Innovid improve the design and delivery of its Services and increase its effectiveness for all users.

Communication

Innovid may send to registered users, advertisers, agencies, and publishers Services and/or account activity-related announcements from time to time.

Data and Information Security

Innovid is committed to protect the security of the information it collects, and takes such measures as are in line with industry practice to safeguard the data in its possession from unauthorized alteration, destruction, access, or misuse. We maintain tight controls over all the data we collect, retaining it in firewalled and secured databases with strictly limited and controlled access rights, to ensure it is secure. Access to personal data is protected and controlled by password and restricted permissions. Please note that where we have given you (or where you have chosen) a password that enables you to access the Innovid Website or Services, you are responsible for keeping this password confidential. Please be aware however that no method of Internet transmission or electronic storage is 100% secure. Innovid cannot ensure or warrant the absolute security of information you transmit to us, and you transmit such information at your own risk. For additional information regarding security, please contact: support@innovid.com.

Children’s Privacy

The Innovid Website and the Services are not intended for children under the age of 16, and children under the age of 16 are ineligible to register for an account on the Innovid Website. Innovid will never knowingly accept or solicit personal data from a visitor or End User under the age of 16 and will delete accounts that it believes to be in violation of this restriction. If you become aware that a child under the age of 16 has registered to use the Innovid Website or has provided Personally Identifiable Information to Innovid, please contact Innovid at privacy@innovid.com, so that Innovid can confirm and take appropriate steps to remove such account and delete the information.

International Data Transfers

The information that we collect from you and about you may be transferred to and stored in a country other than your country of residence, such as the USA and the UK, which may not offer the same level of protection of personal information as your country of residence. However, we will take contractual and/or other measures as required by GDPR Chapter V, to ensure your personal data is protected; this also includes Standard Contractual Clauses approved by the EU Commission and the UK International Data Transfer Addendum and/or the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework, where applicable, as further described below. Your personal data may also be transferred to Israel, which has been recognized by the EU as having adequate data protection.

Additional Information for Residents of the European Union, UK and Switzerland

Innovid collects personal data based on several lawful bases, depending on the exact circumstances. Account Data is processed on the basis of a contract between Innovid and the customer; we are not able to provide services and meet the terms of our customer agreements without such processing. Personal data may also be processed on the basis of the legitimate interest Innovid has in marketing, serving and measuring advertising, and analyzing, improving, optimizing, and personalizing its users’ experience. Where data is provided by Innovid’s brand, agency, publisher and other customers, Innovid’s standard terms require that the provision of such data is done on the basis that the entity providing the data has received any legally necessary consent or has another valid lawful basis to process and share such data and that any personal data provided to Innovid is done so legitimately. However, Innovid is a processor with respect to data provided to Innovid by brands, agencies, publishers and other customers; as such it is the responsibility of such brand, agency, publisher or other customer to secure the lawful basis for such processing.

To exercise data subjects’ rights, contact Innovid and its Data Protection Officer at privacy@innovid.com. Data subjects also have the right to lodge a complaint with a supervisory or data protection authority in their jurisdiction.

If you are a data subject with respect to whose data GDPR applies and we are a Controller of your data under GDPR, you have rights under GDPR and local laws, including, in different circumstances, rights to data portability, rights to access data, rectify data, object to processing, and erase data. A data subject who wishes to modify, delete or retrieve their Personal Data may do so by contacting Innovid (privacy@innovid.com). Where processing occurs based on consent, data subjects have a right to withdraw their consent. Note that we may have to undertake a process to identify a data subject exercising their rights. There may be exemptions to the rights for specific legal reasons which, if applicable, we will set out for you in our response to your request. We may keep details of data subject requests exercised for our own compliance and audit requirements. Please note that Personal Data may be either deleted, or may be retained in an aggregated manner without being linked to any Personal Data (including identifiers), depending on technical capability. Such aggregated information may continue to be used by Innovid.

Where Personal Data is provided by an enterprise customer of Innovid who is the data subject’s employer, such data subject’s rights will have to be effected through that enterprise customer in its capacity as the data subject’s employer.

Data subjects in the EU also have the right to lodge a complaint, with a data protection supervisory authority in the place of their habitual residence. If the supervisory authority fails to deal with a complaint, the data subject may have the right to an effective judicial remedy.

In addition to the above, Innovid has certified under the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework, as further described below.

The EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF

In respect of non-HR Data, Innovid, a U.S. company, complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF (“UK DPF Extension”), and the Swiss-U.S. DPF (“Swiss-U.S. DPF”).

In respect of HR Data, Innovid, a U.S. company, complies with the EU-U.S. DPF and the UK DPF Extension.

Innovid has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. DPF Principles with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. Innovid has certified to the U.S. Department of Commerce that it adheres to the UK DPF Extension with regard to the processing of personal data received from the UK in reliance on the UK Extension to the EU-U.S. DPF. Innovid has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. DPF with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the policies in this privacy policy and data subject rights under the EU-U.S. DPF Principles, UK DPF Extension or Swiss-U.S. DPF, the applicable DPF Principles shall govern and prevail over this privacy policy. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

If you are from the European Union, the UK or Switzerland and would like to gain access to, or request amendment, correction, or deletion of information that Innovid holds about you, please contact us using the details in the “Contact Us” section below. We will consider and respond to your request in accordance with the EU-U.S. DPF, the UK DPF Extension and the Swiss-U.S. DPF, and any applicable laws.

Innovid acknowledges the individual’s right to access their personal data and will provide you access to the personal information we hold about you to the extent it is reasonably available and allow you to correct, amend, or delete inaccurate information, as required, and permitted by applicable law. If you’d like us to correct, amend, or delete any other personal information that you have provided to us, please send your request to us at privacy@innovid.com and we will respond to your request within 30 days.

You may request that we cease sending you any marketing communications (including by email and SMS) at any time by notifying us in writing using the contact details provided below or following any “unsubscribe” instructions included in any marketing communications which we send to you.

We will also provide an individual opt-out or opt-in choice before we share your 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. To request to limit the use and disclosure of your personal data, please submit a written request using the details in the “Contact Us” section below.

With respect to personal data received or transferred pursuant to the EU-U.S. DPF, the UK DPF Extension or the Swiss-U.S. DPF, Innovid, LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC). Under certain conditions specified by the EU-U.S. DPF, the UK DPF Extension or the Swiss-U.S. DPF, you may also be able to invoke binding arbitration to resolve your complaint. Please click here for more information or to submit a complaint.

Under the EU-U.S. DPF, the UK DPF Extension and the Swiss-U.S. DPF, Innovid may remain liable if its third-party service providers process your personal data in a manner inconsistent with the EU-U.S. DPF Principles, the UK DPF Extension Principles or the Swiss-U.S. DPF Principles, unless we prove that we are not responsible for the event giving rise to the damage.

EU, UK and Swiss Individuals who believe that their personal data has not been processed in compliance with the EU-U.S. DPF, the UK DPF Extension or the Swiss-U.S. DPF may raise their complaint in the following ways:

In compliance with the EU-U.S. DPF Principles, the UK DPF Extension and the Swiss-U.S. DPF Principles, Innovid commits to resolve complaints about your privacy and our collection or use of your personal data. European Union, UK or Swiss individuals with EU-U.S. DPF, UK DPF Extension or Swiss-U.S. DPF-related inquiries or complaints should first contact Innovid directly using the details in the “Contact Us” section below. We will respond to your complaint within 45 days of receipt.
Innovid has further committed to refer unresolved privacy complaints related to non-HR Data, under the EU-U.S. DPF Principles, the UK DPF Extension or the Swiss-U.S. DPF Principles, to the BBB National Programs DPF Service as its dispute recourse mechanism. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.dataprivacyframework.gov/s/article/How-to-Submit-a-Complaint-Relating-to-a-Participating-Organization-s-Compliance-with-the-DPF-Principles-dpf for more information and to file a complaint. This service is provided free of charge to you.
Innovid has further committed to refer unresolved privacy complaints related to HR Data transferred from the EU or the UK respectively in the context of the employment relationship, under the EU-U.S. DPF Principles and/or the UK DPF Extension, to the applicable EU Data Protection Authorities (DPAs) or UK Information Commissioner’s Office (ICO), as applicable, as its selected dispute resolution provider. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.dataprivacyframework.gov/s/article/How-to-Submit-a-Complaint-Relating-to-a-Participating-Organization-s-Compliance-with-the-DPF-Principles-dpf for more information and to file a complaint. This service is provided free of charge to you.

Enforcement Complaints

Innovid has implemented processes to ensure compliance with this Policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible, and in conformity with the NAI Code of Conduct. We encourage interested persons to raise any concerns by emailing privacy@Innovid.com and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information.

To address any issues regarding our compliance with the NAI Code of Conduct, Innovid, along with the NAI and other NAI members have created a compliance program that incorporates attestation reviews, a consumer complaint process, sanctions, and annual reporting to help ensure that member companies keep their promises to you and abide by the NAI Code of Conduct. Please refer to the NAI site for more information.

Additional Privacy Information For Residents of California, Virginia, Colorado, Connecticut, Utah, Nevada, Texas, Oregon, and Other U.S. States in Which an Applicable State Privacy Law is in Effect.

In this section, we provide information for residents of California, Virginia, Colorado, Connecticut, Utah, Nevada, Texas, Oregon, and other U.S. states in which an applicable State Privacy Law is in effect as may be required under applicable privacy laws of such states from time to time (“State Privacy Laws”). For instance, the California Consumer Privacy Act (“CCPA”), as amended by the California Consumer Privacy Rights Act (“CPRA”), and the Virginia Consumer Data Protection Act (“VCDPA”), require that we provide their respective residents certain specific information about how we handle their personal information.

Under State Privacy Laws, subject to certain exceptions, “personal information” is generally any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular resident or household in the applicable state. Because certain State Privacy Laws require that we disclose specific information about how we handle certain personal information collected about residents of their states, the scope of this section may be different than the scope of our privacy policy.

Please note that for Innovid employee information-related requests, the Innovid employee privacy policy (which is separately provided to Innovid employees) applies.

What is a “sale of personal information” under State Privacy Laws such as CCPA and VCDPA?

A sale may occur any time a business sells or makes available any personal information to a third party for monetary or other valuable consideration. Innovid does not engage in the sale of personal information to third parties for any monetary or other valuable consideration.

What is a “share of personal information” under the CPRA?

Under the CPRA, “sharing” generally means disclosing, making available or communicating personal information by a business to a third party for targeted advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for targeted advertising for the benefit of a business in which no money is exchanged. Targeted advertising to a consumer is based on the consumer’s personal information obtained from the consumer’s activity across businesses, distinctly-branded websites, applications, or services, other than the business, distinctly-branded website, application, or service with which the consumer intentionally interacts. Innovid acts as a service provider to its customers and does not engage in sharing of personal information with third parties for targeted advertising.

What is “sensitive information” under State Privacy Laws?

“Sensitive information” is generally defined as personal information that reveals sensitive information about a consumer, such as social security, driver’s license, state identification card or passport numbers, account log-in, financial account, debit card or credit card numbers in combination with any required security or access code, password or credentials allowing access to an account, precise geolocation, data revealing racial or ethnic origin, religious beliefs, physical or mental health diagnosis, sexual orientation, or citizen or immigrant status, as well as processing of genetic or biometric data for identification, and personal data collected from a known child. Innovid does not collect information we believe to be sensitive under applicable law.

Categories of Personal Information that We Collect and Disclose to Others for a Business Purpose

The items below set out generally the categories of personal information that we collect and disclose to others for a business purpose.

We collect these categories of personal information from the sources described in our privacy policy above, and for the purposes described in our privacy policy above. Our collection, use and disclosure of personal information will vary depending upon the circumstances and nature of our interactions or relationship with the relevant individual.

Name, Contact Information and other Identifiers: Identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Do we collect? – YES
Do we disclose for a business purpose? – YES
Do we sell? – NO
Do we share with third parties for targeted advertising? – NO

Customer Records: Paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education, current employment, employment history, social security number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial or payment information, medical information, or health insurance information.

Do we collect? – YES
Do we disclose for a business purpose? – YES
Do we sell? – NO
Do we share with third parties for targeted advertising? – NO

Protected Classifications: Characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.

Do we collect? – NO
Do we disclose for a business purpose? – NO
Do we sell? – NO
Do we share with third parties for targeted advertising? – NO

Purchase History and Tendencies: Commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.

Do we collect? – YES
Do we disclose for a business purpose? – YES
Do we sell? – NO
Do we share with third parties for targeted advertising? – NO

Biometric Information: Physiological, biological, or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, faceprint, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

Do we collect? – NO
Do we disclose for a business purpose? – NO
Do we sell? – NO
Do we share with third parties for targeted advertising? – NO

Usage Data: Internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, including access logs and other activity information related to your use of any Innovid websites, applications or other online services.

Do we collect? – YES
Do we disclose for a business purpose? – YES
Do we sell? – NO
Do we share with third parties for targeted advertising? – NO

Geolocation Data: Precise geographic location information about a particular individual or device.

Do we collect? – NO
Do we disclose for a business purpose? – NO
Do we sell? – NO
Do we share with third parties for targeted advertising? – NO

Audio, Video and other Electronic Data: Audio, electronic, visual, thermal, olfactory, or similar information, such as CCTV footage, photographs, and call recordings and other audio recording (e.g., recorded meetings and webinars).

Do we collect? – YES (for internal training purposes)
Do we disclose for a business purpose? – NO
Do we sell? – NO
Do we share with third parties for targeted advertising? – NO

Professional or employment-related information: Employment history, qualifications, licensing, disciplinary record.

Do we collect? – NO
Do we disclose for a business purpose? – NO
Do we sell? – NO
Do we share with third parties for targeted advertising? – NO

Education Information: Information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

Do we collect? – NO
Do we disclose for a business purpose? – NO
Do we sell? – NO
Do we share with third parties for targeted advertising? – NO

Profiles and Inferences: Inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

Do we collect? – YES
Do we disclose for a business purpose? – YES
Do we sell? – NO
Do we share with third parties for targeted advertising? – NO

Rights of Residents of California, Virginia, Colorado, Connecticut, Utah, Nevada, Texas, Oregon, and Other U.S. States in Which an Applicable State Privacy Law is in Effect. State Privacy Laws grant residents of their states certain rights and imposes restrictions on particular business practices as set forth below.

Right to Opt-out of Sale of Personal Information. Residents of certain states have the right to opt out of the sale of their personal information. California residents also have the right to opt out of the sharing of their personal information for targeted advertising. We do not sell your personal information or share it with third parties for targeted advertising. However, if you wish to opt-out of interest-based advertising from Innovid, please visit the section of this Privacy Policy entitled “Opt-Out of Interest-Based Advertising”.

Right to Limit Use and Disclosure of Sensitive Personal Information. Innovid does not collect, use, or disclose information we believe to be sensitive under applicable law.

Right to Revoke Consent. Under certain State Privacy Laws, residents of certain states have the right to revoke consent they previously provided to the processing of their personal information, subject to exceptions provided by applicable law.

Notice at Collection. At or before the point of collection, notice must be provided to the individual of the categories of personal information collected and the purposes for which such information is used.

Verifiable Requests to Delete and Requests to Know/Confirm. Subject to certain exceptions, residents of certain states have the right to make the following requests, at no charge:

Request to Delete: Residents of certain states have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies.

Request to Know/Confirm: Residents of certain states have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the past and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. Residents of certain states also have the right to request that we provide them certain information about how we have handled their personal information in the past, including the:

categories of personal information collected;
categories of sources of personal information;
business and/or commercial purposes for collecting and selling their personal information;
categories of third parties/with whom we have disclosed or shared their personal information;
categories of personal information that we have disclosed or shared with a third party for a business purpose;
categories of personal information collected; and
categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.

Right to Appeal. You may appeal our decision with respect to a request you have submitted by emailing us at privacy@innovid.com.

Submitting Requests. Requests to Know and Requests to Delete may be submitted by emailing us at: privacy@innovid.com or (if the inquiry is specifically related to InnovidXP) privacy@tvsquared.com. We will respond to verifiable requests received from residents of the applicable states as required by law.

Right to Non-Discrimination. Certain State Privacy Laws prohibit discrimination against their residents for exercising their rights under applicable state laws. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates or penalties on residents who exercise their privacy rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.

Financial Incentives. A business may offer financial incentives for the collection, sale, or deletion of certain state residents’ personal information, provided the incentive is not unjust, unreasonable, coercive, or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. Residents of certain states have the right to be notified of any financial incentive offers and their material terms, the right to opt-out of such incentives at any time and may not be included in such incentives without their prior informed opt-in consent. We do not offer any incentives at this time.

CCPA Metrics for 2023

Pursuant to CCPA Regulation 999.317(g), Innovid informs you of the following metrics with respect to the year 2023.  Note: The foregoing numbers are based upon requests received from all individuals and not only from “consumers” as defined under the CCPA.

a. In 2023, the number of CCPA requests to know that Innovid received, complied with in whole or in part, or denied: 8,8, 0.

b. In 2023, the number of CCPA requests to delete that Innovid received, complied with in whole or in part, or denied: 17, 17, 0.

c. The median number of days within which Innovid substantively responded to requests to know, requests to delete, and requests to opt-out: 3

Your California Privacy Rights under California’s Shine-the-Light Law

Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to privacy@innovid.com. In your request, please attest to the fact that you are a California resident and provide a current California address.

For more information about our privacy practices, you may contact us as set forth in the “Contact Us” section below.

Contact Us

You may contact us and our Data Protection Officer at privacy@innovid.com.

Innovid
80 George St.
Edinburgh, EH2 3BU
In the US: see below.

Changes to the Privacy Policy

Innovid reserves the right to change or modify this Privacy Policy from time to time by posting the modified Privacy Policy on the Innovid Website. Your continued use of the Innovid Website or Services indicates your acceptance of the modified Privacy Policy.

Our mailing address is:

Innovid, LLC
Attn.: Privacy
30 Irving Place, 12th Floor
New York, NY 10003

Last updated: August 23rd, 2024