WE TAKE PRIVACY VERY SERIOUSLY
At Dstillery we take consumer privacy very seriously. As a data science company, we are interested in patterns of web browser IDs and mobile application IDs in order to understand consumer behaviors. The data we collect via our technology is generally considered pseudonymous in most places we operate.
HOW ADVERTISING KEEPS WHAT’S ON THE INTERNET FREE
Think about TV. These days, if you want to see the really great television series and movies uninterrupted, you have to pay for them. What if you had to pay for all the great websites and apps?
Dstillery is helping keep the Internet free by enabling marketers to target their ads to the right audience in a way that protects the privacy of users. We’ve created technology that drives the performance of online ads while knowing as little about the user as possible. It’s privacy by design. Our technology does not capture personally identifiable information like name, postal address or email address, nor build profiles that enable us to ascertain who you are.
The result for any given user is more relevant advertising. And for all users a robust, free Internet!
If you would like to remove and/or opt out of Dstillery’s cookies, you can do so by clicking on the opt-out button below.
By clicking opt-out you will no longer receive targeted advertisements from Dstillery on this browser.
Dstillery uses proprietary social targeting technology to deliver relevant ads to consumers. To accomplish this, Dstillery, like many other Internet advertising technologies, uses “cookies” and similar tracking technologies, including those offered by most mobile operating systems. Mobile operating systems (e.g., iOS and Android) offer opt-out choice mechanisms applicable to mobile applications and these choice mechanisms may be found via your mobile device settings. More information about the choice mechanisms available on mobile devices may be found here.
- Clear them manually from your browser using the method specified by that browser (Internet Explorer, Firefox, etc.)
- Use the automated Dstillery process listed on this site as Opt-out of Dstillery ad targeting on websites.
- Visit Digital Advertising Alliance’s (DAA) website and use the opt-out procedure, which can be used to opt-out from the use of data for interest-based advertising purposes from digital advertising companies, including Dstillery. To access this service, please visit the DAA at: http://www.aboutads.info/choices/.
If you have additional concerns, questions, complaints, or wish to communicate with Dstillery for any reason, please feel free to call us or use our contact form.
LAST UPDATED October 25, 2023
THE TYPES OF DATA PROCESSED BY DSTILLERY
Dstillery thinks about the data we process in terms of whether or not the data may be used by Dstillery to identify a data subject. Accordingly, we place the data we process into two categories: identifiable personal data and pseudonymous personal data. We recognize that identifiable personal data and pseudonymous personal data are considered personal data under the applicable privacy or data protection laws in many places. However, we believe that data that may not be used to identify an individual is inherently less risky. Accordingly, Dstillery endeavors to use pseudonymous personal data via our Technology in most places and we use data minimization and de-identification techniques in places like the European Union and United Kingdom.
Identifiable personal data such as a name, a postal address, a telephone number or an email address is personally identifiable information (“PII”) in that can be used to identify or locate a particular person or entity.
Pseudonymous personal data such as a mobile ad ID, a cookie ID or an IP address is not personally identifiable (“Non-PII”) in that it cannot be used by Dstillery to identify or locate a particular person or entity.
We believe that distinguishing the data processed on the basis of whether it is identifiable is an important privacy distinction.
WEBSITE PRIVACY PRACTICES
Personally Identifiable Information (PII)
Dstillery collects Personally Identifiable Information (“PII”) from its website, www.Dstillery.com, when you choose to provide it to us. For example, you may choose to send PII about yourself in an email, or by completing a form on this website. Dstillery uses this information only to contact you to respond to your inquiry. Once collected, Dstillery will store your PII for a reasonable time for record keeping purposes.
Non-Personally Identifiable Information
Dstillery also collects Non-PII from visitors to this Website, including your IP host address, pages viewed, browser type, Internet browsing and usage habits, Internet Service Provider, domain name, the time/date of your visit to this website, the referring URL and your computer’s operating system. Non-PII also includes PII that has been hashed so that it may not be used to identify someone. As noted above, in some places, such as the State of California and the EU, certain Non-PII such as cookie IDs and IP addresses are considered personal information.
Cookies and other Tracking Technologies – Ad Choices
Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at privacy@Dstillery.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Third Party Websites
The Dstillery website may contain links to and advertisements for websites operated by third parties whose privacy practices may differ from Dstillery’s policies. While the company endeavors to associate only with reputable entities, Dstillery cannot guarantee the privacy practices of other websites will reflect ours; we encourage you to check the privacy policies of all websites that you visit.
ACCESSING / UPDATING / DELETING YOUR PII
Upon request Dstillery will provide you with information about whether we hold any of your PII collected via the website. If you’d like to update, correct, delete, port or deactivate any PII that you have provided to the company on this website, please send your request to firstname.lastname@example.org, and Dstillery will process your request. We will respond to your request to access within a reasonable timeframe as governed under applicable law. UK, EEA and California data subjects have additional privacy rights as described below.
DSTILLERY’S TECHNOLOGY PRIVACY PRACTICES
Dstillery is in compliance with the Digital Advertising Alliance Self-regulatory Code in the United States. Our technology collects non-PII (defined above) from mobile apps and websites, including this website and utilizes that information to deliver interest-based advertising. We also may allow other third-party advertisers to collect Non-PII from this website and utilize it to deliver relevant ads and for other purposes in accordance with industry standards. You may opt-out from interest-based advertising by clicking onto the DAA opt-out mechanisms.
Dstillery’s technology uses “network neighbor” data to help our clients deliver relevant digital advertisements on websites and mobile apps. “Network neighbors” are generally two or more people that visit the same website pages, utilize the same wifi network or use the same mobile apps. For example, a network neighbor might be someone whose social networking profile page you’ve visited, used the same mobile application you’ve used or someone that visits the same website that you visit. Network neighbors are likely to share many similar interests, hobbies, and other key demographic characteristics with you, although we don’t typically know what (if any) interests or hobbies are shared by any group of network neighbors. Rather, Dstillery believes that if you’re interested in a particular product or service, your network neighbors are likely to also be interested in that product or service. Therefore, by understanding whom your network neighbors are and what they like, the company’s proprietary technology will do a better job determining the digital ads that are likely to be of interest to you.
Dstillery’s technology collects information about the website(s) that you visit (including this website), the mobile apps that you use and the ads that you see. We also obtain data from third-party partners. When we receive de-identified data, we won’t attempt to identify any of the data subjects in the de-identified data set. And where we can reasonably infer that a particular computer or device belong to the same household (e.g., where multiple computers or devices use the same IP address), we may extend our advertising and targeting capabilities across multiple devices. You may encounter our technology when: Dstillery or one of our clients purchases digital ads on a website that you visit or a mobile app that you use or when one of our clients places a web beacon on a website that you visit. Dstillery doesn’t operate our pixel technology in the European Union or UK and we take steps to block any personal data from EU data subjects prior to ingestion into our systems. Rather, we focus on our ID-Free Customer AI service in the EEA and UK.
ID-Free Custom AI
TYPES OF INFORMATION WE COLLECT VIA OUR TECHNOLOGY
Non-Personally Identifiable Information
With the exception of ID-Free Customer AI, we collect pseudonymous personal information (“Non-PII”) via our technology, including but not limited to browser type, operating system, Internet Service Provider, IP address, and basic ad serving information such as the time and date an ad is served, the name of the mobile app or URLs from the web page visited. This type of Non-PII is also considered personal information when collected from California consumers. We collect IP addresses and pseudonymous mobile advertising identifiers created by the mobile O/S manufacturers to help our systems recognize a computer or device over time and to help us synch data with our customers and partners. The technologies we use to collect this data include cookies and pixel tags on our customers’ websites.
We also work with device identity platform partners to enable our clients to bring their online and offline data into our systems for use by our technology. The data collected by our technology is pseudonymized prior to being used for ad targeting.
Retention of Data Collected
For information gathered via our website, we store PII such as email address or billing details so long as you continue to have a business relationship with Dstillery for record keeping purposes. You may ask us to delete that information by following the instructions below.
For information gathered via our technology, Dstillery retains some data collected via its technology in its original form for up to 30 days in order to ensure that our technology is functioning properly. After 30 days, the original raw data set is deleted and a de-identified data set is stored for up to two years; pseudonymous data may be stored for up to one year for research purposes. We also store Non-PII in cookies, which expire no later than 60 days from the last time our systems have encountered a particular computer or device. For the ID-Free product, the raw data set is stored for up to two years.
CONTROLLING THE USE OF YOUR INFORMATION
Opting Out from Interest Based Advertising (our “Choice Mechanism”)
Computers and Web Browsers
If you’d like to opt out from having Dstillery use your information to target advertising, please click here. When you opt out, Dstillery will attempt to place an opt-out cookie on your computer or device. The opt-out cookie tells our technology not to use your data to target ads on websites from that computer or device. The opt-out cookie also tells our technology that California data subjects have opted out from Dstillery’s sale of their personal information. Please note that if you delete, block, or otherwise restrict cookies, or if you use a different computer or Internet browser, you will need to renew your opt-out choice. Also, when our systems are able to detect that do not track has been set on a browser, we treat that user as having opted out from Dstillery as well.
Mobile operating systems (e.g., iOS and Android) offer opt-out choice mechanisms applicable to mobile applications and these choice mechanisms may be found via your mobile device settings. More information about the choice mechanisms available on mobile devices may be found here. And Dstillery participates in the DAA AppChoices mobile opt-out application as part of honoring the DAA Code for the Mobile Environment. Where our systems detect that a user of a device has opted out via their mobile operating system, our technology won’t use your data to target ads on mobile applications for that device. Similarly, when our systems indicate that a user of a device has opted-out from Dstillery via AppChoices, our technology won’t use your data to target ads on mobile applications for that device. We also use mobile operating system opt-outs and AppChoices opt-outs as a way for data subjects to opt-out from our sale of their personal information as required under applicable law. Also, when we can see that a website or mobile app publisher or an internet browser has sent us a signal indicating that a particular User has proactively asked to opt-out from sales, profiling and/or targeting advertising, we will honor those signals in accordance with applicable law.
Please note that these opt-out choice mechanisms only apply to the particular device that has opted out and does not opt you out of being served advertising. You will continue to receive ads, but those ads will not be targeted via our technology.
Dstillery is phasing out its receipt of precise location data such as lat/long. If you’d like to adjust your choices regarding the use of precise location data by other third parties, you may do so via your device settings. Also, most mobile applications that collect precise location information offer choice mechanisms. A helpful description of many leading mobile platform choice mechanisms may be found here.
Data Integrity, Purpose Limitation
We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use as described above.
Access or Deleting your Information
Although Dstillery doesn’t collect PII via our technology, if you’d like the company to update, correct, delete, or deactivate any PII that you have provided on the website, please send your request by clicking here, or clicking the link entitled “data subject access request” at the bottom of this page.
The security of your information is important to us, including but not limited to the PII collected via the website and the Non-PII collected via our services. Dstillery has implemented reasonable security measures to protect the information, both during transmission and once it is received. This includes but is not limited to the use of firewalls and encryption. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while the company strives to use commercially acceptable means to protect your information, it cannot guarantee absolute security. If you have any questions about these security practices, please email privacy@Dstillery.com.
U.S. Data Subjects in certain states
Certain U.S. States (e.g., California, Colorado, Connecticut, Nevada, Virginia and Utah) have enacted privacy laws specific to data subjects in those states. For example, the California Consumer Privacy Act (CCPA) provides additional privacy protections for California data subjects, including: a) the right to see what data we have about you, your computer or device (i.e., the right to know), b) the right to delete the data we have about you, your computer or device (i.e., the right to delete), c) the right to correct data we have about you, your computer or device, , d) the right to port data about you, your computer or device to a different provider, and e) the right to opt-out of the sale of data about you, your computer or device to certain third parties (i.e., the right to opt-out from sales of your information). We do not discriminate against you if you exercise any of the above rights. Please note that our Platforms mostly process pseudonymous personal data that doesn’t allow Dstillery to identify your directly. So if you provide us with identifiable personal data such as your name and email address, it is unlikely that our systems will be able to connect that identifiable data with the pseudonymous data processed by our Platform. Moreover, we may not be able to honor a right if doing so would violate applicable law.
If you are a Customer or partner of Dstillery and have questions about your ability to see the data used to login to our systems, we ask that you direct your question to the person that owns the business relationship. If you are a consumer and want to see what data we may have on behalf of one of our customers, kindly reach out to that individual customer.
Regardless of where you reside, you may access certain rights with respect to Dstillery by clicking here, clicking the link entitled “data subject access request” in the footer at the bottom of this page, or calling our California privacy helpline at 1 (888) 914-9661 and use PIN 598 312 when prompted. As a U.S. data subject, if you make a subject access request as set out in this policy, we will confirm your request within 10 business days and make a good faith attempt to fulfill your request within 45 days.
The number of CCPA requests to know that Dstillery received, compiled with
whole or part and denied in 2022: 3, 2 and 1
The number of CCPA requests to delete that Dstillery received, compiled with whole or part and denied in 2022: 7, 7 and 0.
The number of CCPA requests to opt-out that Dstillery received (not including requests made via Dstillery’s cookie based opt-out mechanism) compiled with whole or part and denied in 2022: 64, 58 and 6.The median number of days within which Dstillery substantively responded to requests to know, requests to delete and requests to opt-out in 2022: 40, 1 and 31.
Applicable U.S. state privacy law define personal information broadly and as such, it includes pseudonymous identifiers such as cookie IDs and mobile advertising IDs. Under the CCPA and other applicable U.S. state privacy laws, your request to see the personal information that we have about you may include: (1) specific pieces of personal information that we may have about you; (2) categories of personal information we have collected about you; (3) categories of sources from which the personal information is collected; (4) categories of personal information that we sold or disclosed for a business purpose about you; (5) categories of third parties to whom the personal information was sold or disclosed for a business purpose under the CCPA; and (6) the business or commercial purpose for collecting or selling personal information.
We may take reasonable steps to verify your request. We will fulfill requests we are able to verify so long as we are not prohibited from doing so by applicable law and/or the information is not essential for us for billing, fraud prevention or security purposes. We will share our reason(s) for denying your request in the event that we are unable to fulfill your request. Some U.S. states (e.g., Colorado and Virginia) provide you with a right to appeal if we deny your request and enable you to complain to the Attorney General in your state. Please send any appeals to email@example.com.
You may make an access or deletion request via an authorized agent by having such agent follow the process outlined above. Please note that we will request any authorized agent demonstrate that they have been authorized by you to make a request on your behalf. And we will attempt to verify your request. We require any authorized agents to provide us with contact details such as an email address and phone number so that we may ensure a timely response.
The United Kingdom (UK) and European Economic Area (EEA)
As an EEA, UK or Swiss data subject, you have the right – partly under certain conditions:
- to request information about the processing of your data free of charge, as well as the receipt of a copy of your personal data;
- to request information on the purposes of the processing, the categories of personal data being processed, the recipients of the data (if they are passed on), the duration of the storage or the criteria for determining the duration;
- to correct your data. Should your personal data be incomplete, you have the right to complete the data, taking into account the processing purposes;
- to delete or block your personal data. Reasons for the existence of a cancellation/blocking right can be, among others, the revocation of the consent on which the processing is based, the data subject objects to the processing, the personal data were processed unlawfully;
- to restrict the processing of your personal data;
- to object the processing of your personal data;
- to revoke your consent to the processing of your personal data in the future, and;
- to complain to the competent supervisory authority about inadmissible data processing.
As an EEA, UK or Swiss data subject, you may access those rights with respect to Dstillery by clicking here, clicking the link entitled “data subject access request” in the footer at the bottom of this page.
Although we don’t process personal data via ID-Free, we nonetheless take the position that our legal basis for processing data on the ID-Free platform is our legitimate interest. Where we rely upon legitimate interest, we have assessed the processing is not high risk, does not involve the processing of sensitive data or the creation of intrusive profiles. In almost all instances, our processing will not involve personal data at all.
We may receive certain personal data from the personnel of our clients and partners where such personnel are located in the EEA or other places outside of the United States. For example, some clients and partners may provide email and login credentials to login to our systems. We encourage the personnel of such partners to first reach out to the person that manages the business relationship between Dstillery and your organization. You may also make a request by clicking the link entitled “data subject access request” in the footer at the bottom of this page.
Information Relating to Children, Sensitive and Special Category Data
Dstillery’s products and services are designed for those 18 years of age and older. Dstillery does not knowingly collect PII from anyone under the age of 18. If the company is made aware that it has received PII from someone under 18, it will use reasonable efforts to remove that information from its records.
We don’t generally collect sensitive or special category data such as ethnicity, religion, sexual interest, sensitive health data including protected health information or data from minors as defined under applicable law. We may obtain certain sensitive data in an employment context which is covered under a different policy. We ask our customers not to send this type of information to us.
Disclosure of Information to Third Parties, Onward Transfer
Dstillery processes data in the United States. To the extent that our processing requires the transfer of personal data out of the UK, EEA or Switzerland, we typically use transfer mechanisms such as the Standard Contractual Clauses to effectuate such transfers safely.
Dstillery does not rent, sell or share your PII with non-affiliated third parties without your consent. The company may, however, share data with trusted third-party service providers and contractors who provide certain services for us, The services provided by these third-party service providers and contractors include: a) cloud computer, data storage and file storage providers, b) email marketing providers, c) website and b2b sales analytics providers, d) customer relationship management, contact database vendors, data hygiene vendors, survey vendors and project management software providers, e) customer billing systems vendors, f) login authentication providers to ensure that the logins to our systems are working efficiently, g) outsourced computer programmers helping ensure our systems are operating properly, h) auditing, debugging and security vendors. These agents work on our behalf and use data only as directed by us under written agreements which outline how they may use such data and require that such third-party agents provide at least the same level of privacy protection as we do.
Dstillery also transfers Non-PII to our advertising clients and their agents, which includes ad networks, advertising technology platforms, ad agencies, website and mobile app publishers and other companies that facilitate the delivery of advertising via digital media. These transfers may be considered a sale under California law.
The company may also share aggregate data collected on the website or via its technology with unaffiliated third parties. For example, Dstillery may disclose that digital ads offering ‘country music’ ring tones receive more clicks than those offering ‘classic rock music’ ring tones. This information cannot be used to contact or identify any person individually.
Dstillery may be required to disclose your information to third parties when obligated to do so by law and in order to investigate, prevent, or take action regarding suspected, or actual prohibited activities, including transfer reasonably intended to meet national security or law enforcement requirements, or when we believe in good faith that disclosure is necessary to protect our rights, including but not limited to fraud and situations involving potential threats to the physical safety of any person.
Finally, Dstillery may transfer information, including any PII or Non-PII, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If Dstillery is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
For questions, concerns or complaints relating to privacy, please email privacy@Dstillery.com. Dstillery’s data protection officer may be contacted at firstname.lastname@example.org. Dstillery’s UK representative is UK Representative Service for GDPR Ltd. who may be contacted via the address below. Dstillery is not currently operating its technology in the EEA or Swiss marketplace
7 Savoy Court
London WC2R 0EX
Alternatively, you may contact us at the address below:
Attn: Privacy Officer
470 Park Ave S., Floor 17S, New York, NY 10016