PLATFORM PRIVACY POLICY

If you are interested in learning about how we collect, use, and disclose information in connection with our digital advertising technology, you have come to the right place.

This privacy statement describes Apollo Program LLC's practices and policies with regard to Platform Data. It may describe how Apollo Program LLC enables or allows clients to use the Platform, but otherwise does not apply to our clients' or other 3rd parties' practices. Companies participating on the Platform own their own data, and Apollo Program LLC retains limited rights to use it to run the Platform. This document does not apply to our data practices offline or with respect to apolloprogram.com.

To opt out of our digital advertising technology data practices, click here

NAI Membership and Compliance

Apollo Program LLC is an approved member and adheres to the Code of Conduct(s) of the Network Advertising Initiative (NAI), the leading self-regulatory association dedicated to responsible data collection and its use for digital advertising. The NAI is an organization for third-party online advertising technology companies, including networks, exchanges, DMPs, SSPs, RTB platforms, analytics companies, and service providers.

The NAI’s role is to help promote consumer privacy and trust by creating and enforcing high standards for responsible data collection and use practices online and in mobile environments among its members. You can find a description of policies listed here: NAI Self-Regulatory Codes of Conduct. By joining the NAI, we have demonstrated commitment to consumer privacy and digital advertising best practices. You can find the NAI opt-out tool here, which allows you to opt out of Interest Based Advertising.

CCPA

If you are a resident of California, please review these additional privacy disclosures.

Disclosures

The California Consumer Privacy Protection Act (“CCPA”) requires us to disclose the categories of “personal information” we collect for each “consumer” as those terms are defined in the CCPA. Apollo does not collect names, addresses, phone numbers, or government identifiers, and the data it does collect is provided to it by third-party contractors on an anonymized basis. For additional details concerning Apollo’s collection of information, please see the section of this privacy policy entitled “What Do We Mean By Platform Data.” We are also required to disclose how we use personal information. As a general matter, Apollo utilizes the data it collects to facilitate internet-based advertising, to customize ads to a particular location, to perform analytics concerning groups of consumers, and for other purposes. For additional details, see “For What Purpose Do We Use The Information Collected On The Platform.” Details concerning the categories of sources from which Apollo collects personal information can be found at “How Do We Collect Information,” and the categories of third parties with whom we share personal information at “What Platform Data Does Apollo Program LLC Share With Third Parties.” Apollo is a registered data broker under California law.

Your Rights

If you are a California consumer, you may have the right to request that we disclose what information we collect, use, disclose or sell about you, to access the specific pieces of information we hold about you, and/or request the deletion of any of your personal information we collect or maintain, subject to certain exceptions. To make a verifiable deletion or access request, please contact us at privacy@apolloprogram.com. You may also designate an authorized agent to make such requests on your behalf, as permitted under CCPA. If you do so, we will require the agent to provide proof that they are acting on your behalf, and we may ask you to verify your identity and to confirm that you provided the agent with permission to submit the request on your behalf.

Please note that because most of the information we store can only identify a particular browser or device, and cannot identify you individually, you will need to provide us with some additional information to enable us to identify the information we hold about you, if any, and ensure that we accurately fulfill your request. If you have any questions about your rights or our disclosures, you may reach us at privacy@apolloprogram.com

Do Not Sell My Personal Information

Apollo Program does not sell User Information, but our clients may use our technology to buy or sell personal information as defined by California law. If you wish to opt out of the use of your personal information for interest-based advertising purposes, you may do so by following the instructions under “Opt Out of Interest-Based Advertising” below. Note that because these opt outs are specific to the device or browser on which they are exercised, you will need to opt out on each browser and device. You may also wish to utilize the opt-out options provided by advertising industry organizations such as:

Background Information

This document provides information about our digital advertising technology platform (the Platform), which enables our clients (advertisers) to tag content and collect data about consumers who interact with their websites and mobile applications. This document also describes our policies about data collection and use.

Our goal is to be transparent about our business by describing our technology in simple terms so that Internet users can understand our practices. However, please note that we do not have a direct relationship with individual consumers who interact with our client’s websites and mobile applications. Individual consumers with questions about the practices of those advertisers should review those companies’ own privacy policies and contact those companies directly.

What is the Apollo Program LLC Platform?

Apollo Program LLC has a marketing intelligence technology platform. By "platform," we mean a technology that provides tools for advertisers to purchase data from website and mobile application publishers, or sellers. Our clients want to use their advertising dollars efficiently by reaching the right audiences, and by measuring the effectiveness of the content or creative they are deploying. To help accomplish these goals, advertising buyers and sellers can use our Platform to engage in a variety of techniques, including interest-based data collection, real-time (or programmatic) advertising, contextual, and location-based advertising.

The Platform also provides advertising buyers and sellers other tools, like the ability to measure how effective their ads were, to help prevent malware attacks or other malicious online activity, and other functions designed to help determine the efficacy and reach of their advertising. They may also use our Platform to buy and sell data to help make the ads that their consumer end users see more relevant to them.

The Platform is operated by Apollo Program LLC, 536 Broadway, 11th floor, New York, NY, 10012, USA.

What do we mean by Platform Data?

The Platform is designed to use certain types of data ("Platform Data"). It includes data generated through the Platform as well as data our clients receive from other sources and then use on the Platform. This may include information about Internet users' browsers and devices, such as:

  • the type of browser and its settings,

  • information about the device’s operating system,

  • cookie information,

  • information about other identifiers assigned to the device,

  • the IP address from which the device accesses our client’s website or mobile application,

  • information about the user’s activity on that device, including web pages and mobile apps visited or used,

  • information about the geographic location of the device when it accesses a website or mobile application, and

  • inferences or information about users’ interests that are created, acquired, bought, sold, or used by our clients.

Some of this data is sometimes referred to as “HTTP header data” or “clickstream data.”

Platform Data does not include names, mailing addresses, phone numbers, email addresses, or government identifiers. Apollo Program LLC does not directly collect or allow such PII (Personally Identifiable Information) data to be used on the Platform. Apollo Program LLC partners with third party certified onboarders of such information that make available only anonymized data to Apollo, per contractual agreement.

Glossary of Basic Terms

Ad Server: An ad server, in its simplest form, is the computer responsible for delivering an ad to be shown in a web page or a mobile app. Today, communications may be sent to several servers in the process of selecting and delivering an ad. This occurs in a matter of milliseconds (thousandths of a second).

Beacons, Pixels, Tags, and SDKs: Beacons (also sometimes referred to as web beacons or pixels) and tags are elements included in web pages to enable companies to collect data, serve advertising, and provide related services, such as measuring ad effectiveness or preventing fake ad traffic. They do this by allowing communication between a web browser and a server. A beacon is a small transparent image that is placed on a web page. A tag is a small piece of website code that is run by the web browser. An SDK is a piece of computer code that developers include in their mobile applications.

Cookie: A cookie is a small text file that is stored in a web browser by a website or ad server. By saving information in a cookie, websites and servers can remember preferences or recognize web browsers from one visit to another or from one website to another.

Non-Cookie Tracking Technologies and Device Identifiers: Companies sometimes use alternative methods that perform functions similar to cookies in order to identify unique browsers or devices. For example, some platforms, such as Apple’s iOS and Google’s Play Services for Android, provide unique IDs to be used for advertising. Additionally, mathematical or statistical techniques are sometimes used to try to identify devices. These "Statistical Identifiers" are not 100% accurate.

ID Synching: ID synching (sometimes also referred to as cookie syncing is a common and long-standing process in the digital advertising industry. It enables advertisers to link up data from multiple advertising platforms. (In other words, it helps advertisers buy ads in more than one place.)

Here’s an example of how it works. Let’s say you sell a product on your website. A customer visits your site. Your website stores a cookie to identify that customer’s browser, and the cookie contains an ID of 12345. You then associate that ID with information about what the customer shopped for on your site.

If you want to then use that information to advertise to that user, you might go to an online advertising marketplace to buy ads. In order to buy the right ads and show them to the right user, you’ll need to match your ID, which is 12345 to the ID that the marketplace has assigned to the same customer (which let’s say for this example is ABCDE).

The result is a record that says ID 12345 = Marketplace ID ABCDE. That way, when the marketplace offers to sell you an ad to be shown to ABCDE, your system will know that ABCDE is the same as 12345, and you can pick the right ad to show the customer.

Cross-Device Mapping: Cross-device mapping is the process of making inferences that certain devices are related to each other, i.e. they belong to the same user or household. This is done using either “statistical” or “deterministic” methods (or a combination). “Statistical” refers to using mathematical techniques to make intelligent guesses that certain devices are related. “Deterministic” means using known relationships, for example logins that use the same email address or other personal information, to link multiple devices to a single user.

Interest-Based Advertising: Interest-based advertising uses information collected across multiple web sites or mobile apps to predict users' preferences and to show ads that are most likely to be of interest to them. For example, if a user visits a travel site or uses a travel app, she might see travel-related ads on another site or app. Advertisers may also use other information they have or can acquire about users’ interests. Users have choices with respect to this type of advertising, as discussed below.

Precise Geographic Location: A user’s device may be capable of sharing his or her precise geographic location with the apps or web pages he or she visits using that device. Devices use one or more methods to determine a user’s location, including GPS coordinates and information about wifi networks in the vicinity. Devices such as iPhone or Android phones typically ask for users’ consent before installing or using an app that accesses the device’s precise geographic location. The app, in turn, may make this information available to third-party advertising companies in order to make the ads you see more relevant.

Real-Time Transactions (Also called Real-Time Bidding or Programmatic Advertising): Advertising buyers are able to bid in "real time" for the opportunity to show an online advertisements when a web page is loaded or an app is used. The winning bidder gets to show its ad.

The explanations above are simplified. There are many resources available on the web to learn more about these concepts and online advertising in general. Although we have no responsibility for the content of these sites, we offer the following as additional places to learn more:

About web browser cookie settings:

What information do we collect and use?

The Apollo Program LLC Platform allows our clients to collect and use Platform Data.

The Platform collects information provided by third-party sources to allow clients to use such data to target ads. To do this, clients and data providers may use ID synching to enable the use of this information through the Platform.

Apollo Program LLC may collect Precise Location Information when, for example, an app makes such information available through the Platform. We ensure all Precise Location data is obtained via consumer consent.

How do we collect information?

The Platform uses Cookies and/or third party technologies, placed on our clients’ websites to collect Platform Data associated with particular web browsers or devices.

Cookie use by the platform

Although the specific cookies employed on the Apollo Program LLC Platform may change from time to time, the following describes the general purposes for which the Apollo Program LLC Platform uses cookies. These cookies enable our clients to target ads to users, to evaluate how well their ads work, and to see users’ opt-out choices.

What information do we collect and use? The Platform is designed to collect and use only Platform Data as described in this document.

How do we collect information? The Platform uses cookies, beacons, tags, mobile SDKs, and some non-cookie technologies to collect and store Platform Data about web browsers and devices across web sites and apps and over time.

For what purposes do we use the collected information? Apollo Program LLC uses the information collected on the Platform to provide, operate, manage, maintain, and enhance the Platform.

What information do we share with third parties? Clients have access to the Platform Data that they collect, acquire, or use on the Platform, and may remove it from the Platform for their own use. Apollo Program LLC may provide Platform Data to partners and service providers for the purpose of operating, managing, maintaining, or enhancing Apollo Program LLC’s services, including for the safety and security of the platform and the online industry, or as required by law.

How is the information stored and how long is it kept? Platform Data is usually aggregated or deleted within 12 months (from the last time we see a user), but may be retained in the Platform for up to 18 months from the date of collection before aggregation or deletion.

What are an individual consumer end user’s choices? End user choices are spelled out in the online and app privacy policies of our clients, but most web browser users may opt out of the use of the Platform for interest-based advertising in their web browser. Most mobile app users have access to choices provided by certain apps or in their device system software.

What happens if this privacy statement is changed? Check this policy for changes. Material changes will not be applied to previously collected Platform Data.

The Platform uses cookies:

  • To distinguish between unique web browsers, and to store data for advertising purposes, including interest-based advertising.

  • To store ad delivery and reporting data for clients, such as, for example, which ad was shown, the number of times a particular ad has been shown, and how recently an ad was shown to a particular web browser.

  • To enable ad buyers to track users' responses (clicks and conversions) to ads purchased on the platform.

  • With non-unique values for server load-balancing and similar technical purposes.

The Platform uses non-unique cookies to store users' opt-out choices.

The Platform may also use some Non-Cookie Tracking Technologies and Device Identifiers for these purposes (as defined above and as detailed below).In addition to mobile, this can include television streaming devices (ie connected television). Apollo treats this data the same as other sources and encourage consumers to follow the NAI’s detailed instructions on TV platform based opt-out tools.

Cookies play a role in cross-device linking in that cookies from different browsers or devices might be associated with each other.

Some browsers or other software may be configured to block 3rd party cookies by default.

For What Purposes Do We Use the Information Collected on the Platform?

Apollo Program LLC uses the information collected on the Platform to provide services to its advertiser clients, which primarily means we provide, operate, manage, maintain, and enhance the Platform.

The Platform enables Apollo Program LLC's clients to collect, buy, and sell data and to use Platform Data to buy and sell online advertising. Sometime Apollo Program LLC staff give "hands-on" help to clients using the Platform for these purposes, for example by configuring advertising campaigns for clients to best meet their objectives.

Particular advertising-related purposes for which Apollo Program LLC’s clients may use the Platform Data include:

  • Interest-based advertising (For information on how to opt out of interest-based advertising on the Platform, consumers can visit the "What are your choices?" section below and review our clients’ online and app privacy policies.)

  • Limiting the number of times a user sees a particular ad

  • Showing ads in a particular sequence

  • Customizing ads to a particular location

  • Showing ads related to the content of the web page on which they are shown

  • Determining how users respond to ads

  • Reporting aggregated statistics regarding, for example, the effectiveness of online advertising campaigns

  • Aggregated consumer analytics

What Platform Data Does Apollo Program LLC Share With Third Parties?

Apollo Program LLC may provide Platform Data to partners and service providers in order to provide, operate, manage, maintain, and enhance Apollo Program LLC's services. Apollo Program LLC may provide, or enable others to collect, information for purposes of protecting the safety and security of the online ecosystem, including to detect and prevent malicious activity or fake traffic.

Apollo Program LLC may also disclose such information in the event we reasonably suspect malicious activity or fake traffic, or believe that we are legally required to do so. Apollo Program LLC may also share aggregated data derived from the Platform, including, for example, statistics about Platform activity.

Our clients have access to their Platform Data that they collect, acquire, or use on the Platform, and may remove it from the Platform for their own use.

Finally, we may transfer Platform Data to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.

What are consumer choices?

Consumers should visit the privacy policies of our clients’ websites and mobile apps in order to learn about their choices.

Opt Out of Interest-Based Advertising:

Consumers can opt out of interest-based advertising related to the Platform as follows:

Apollo Program LLC Web Browser Opt Out

Consumers can click here to opt out of having the Platform used to select ads for the consumer’s browser based on his or her online web browsing behavior. When the consumer opts outs, an opt out cookie (from apolloprogram.io) will be stored in the consumer’s web browser. The Platform will know the choice the consumer has made when it sees the opt out cookie, and will apply that choice to all companies using the Platform. If a consumer blocks or deletes the opt out cookie, he or she will not be opted out and will need to allow cookies from Apollo Program LLC and renew his or her opt-out choice.

Important things to note about the opt out:

Blocked cookies: The opt out cookie may not work if a consumer’s browser is configured to block third-party cookies.

Deleting or protecting opt outs: If a consumer deletes cookies, he or she will need to opt out again. There are browser plugins to help a consumer preserve his or her opt out cookies. For more information, please visit http://www.aboutads.info/PMC.

Only a single browser: The opt out only applies to the browser profile in which the consumer sets it. For example, if the customer sets the opt out while using Firefox, but then uses Chrome, the opt out will not be active in Chrome. To opt out in Chrome, the consumer will need to repeat the opt out process. This is because the cookies cannot be read between different browsers or browser profiles.

The opt out does not block or delete cookies: It also does not prevent the use of cookies or other technologies for purposes other than selecting ads based on interests as inferred by a consumer’s online behavior. If a consumer opts out, data may still be collected about his or her web browsing activities and he or she will still see advertising. Ads may be selected, for example, based on the content of the web page in which they are shown. If a consumer wishes to block or delete cookies altogether, he or she can use web browser settings to do so.

Learn More: To learn more about interest-based advertising, and to access the opt outs of other online advertising companies, visit the Network Advertising Initiative opt out page.

Mobile App Opt Out: Mobile device system software such as Apple iOS or Google Play Services provide an opt out choice that is communicated to companies providing in-app advertisements. For more information, or to opt out using these mechanisms, a consumer should consult his or her device settings.

Consumers can also consult the NAI’s mobile opt out page here, which explains how users can manage these controls.

As mentioned above as well, consumers can also access the NAI’s instructions on how to opt-out of TV platform based data collection here.

Location: Most mobile devices offer the consumer the ability to stop the collection of location information at any time by changing the preferences on the device. The consumer may also be able to stop the collection of location information by particular apps by adjusting the settings for individual apps or following the standard uninstall process to remove specific mobile apps from the device. Apollo Program LLC requires partner data sources to adhere to NAI policy regarding consumer opt-in consent when it comes to PLI (Precise Location Information) as detailed here

Industry Self-Regulation

Apollo Program LLC supports industry self-regulation, and endorses best practices and self-regulatory requirements that apply to the Platform.

Certain companies may participate in the Digital Advertising Alliance ("DAA") AdChoices Program and may display an Advertising Option Icon for Interest-based Ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com/ and its opt-out program for mobile apps at http://www.aboutads.info/appchoices.

Please be aware that such opt-outs do not affect non-targeted ads. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt out options or programs or the accuracy of their statements regarding their programs. However, we support the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising available at http://www.iab.net/media/file/ven-principles-07-01-09.pdf and expect that ad networks, if any, that we directly engage in connection with the Platform to serve interest-based ads will do so as well, though we cannot guaranty their compliance.

Additionally, the following industry sites provide useful information about industry self-regulation of interest-based advertising: www.networkadvertising.org and www.aboutads.info

What Happens if this Privacy Statement is Changed?

Check this page for changes. We may change this privacy statement at any time. However, if we were to make material changes, those changes would not be applied to Platform Data collected prior to such changes.

More Questions?

If you have questions about privacy on the Apollo Program LLC Platform, you may send us a message here: privacy@apolloprogram.com.