Privacy Policy

Effective date: December 11, 2019

Privacy at district m

At district m, personal data usage is limited to the bare minimum to conduct business. Therefore, we collect as little as possible, by design.

To find out what personal data we collect on our Website and why, click here.

To find out what we collect from our clients on our Client Facing Platforms and why, click here.

To find out what we collect from internet users on our Advertising Technology Platforms and why, click here.

Privacy on our website

What personal data we collect and why

district m sets cookies that identify your computer to make our website work, understand visitor preferences and traffic patterns and to enable ad retargeting for our services.

We use:

  • Session cookies. They are limited to one visit. They tell us how visitors use our website, which pages you visit and how you arrived at our website. We use this information to improve our website.
  • Persistent cookies. They stay after the session and are used to recognize a visitor across sessions. We use this information to adapt content, understand traffic patterns, measure advertising campaign efficiency and enhance overall user experience.
  • Retargeting cookies. They record visits and navigation on our website and are used to potentially retarget visitors on subsequent visits to other digital properties such as search, and social platforms or other digital ad supported content.

You can opt out by disabling cookies, but some features of the site may no longer work.

To opt-out, go to your browser and follow instructions. Some browsers support a “Do Not Track” feature that is intended to be a signal to websites that you do not wish to be tracked across different websites. Our website does not currently change the way they operate based upon detection of a “Do Not Track” or similar signal.

We also use forms you submit to conduct business through the generation of leads in our Customer Relationship Management (CRM) software.

To see all categories of data we collect from you, click here.

Data Sharing

district m only shares website personal data with its service providers that assist in operating the website. This personal data is limited to cookie identifiers.

To see all categories of data we share, click here.

Data Retention

district m never retains personal data from the website for longer than 60 days.

Data security

While district m never retains personal data from the website for longer than 60 days, it may share website personal data with its service providers that assist in operating the website. district m uses service providers who guarantee industry standard security safeguards.

Accessing your personal data

Wherever you reside, in the United States, Canada or the European Union, you have the right to access the personal data we collect, use and share about you. You also have the right to not receive discriminatory treatment for exercising your access right.

To submit a request or designate an authorized agent to make a request, please contact us by email at [email protected] or by mail at Legal Department, District M Inc., 5455 Gaspe Avenue, Suite 730, Montreal, Quebec, Canada H2T 3B3

Since we never keep data from the website, we may no longer have it – if we ever had collected it. Still, we will reply within of 30 days to give you access or to let you know that we do not have any of your personal data.

Deleting your personal data

Wherever you reside, in the United States, Canada or the European Union you have the right to request that we delete your personal data. Again, since we do not retain website data, it is most likely that we do not have it. Still, once we receive and confirm your request, if we do have your personal data, we will delete (and direct our vendors and service providers to delete) your personal data, unless an exception applies. In that case, we will provide justification. You also have the right not to receive discriminatory treatment for exercising your deletion right.

To submit a request or designate an authorised agent to make a request, please contact us at [email protected] or by mail at Legal Department, District M Inc., 5455 Gaspe Avenue, Suite 730, Montreal, Quebec, Canada H2T 3B3.

Data storage

We transfer personal data to the US through Microsoft, Amazon and Google. They are all certified for compliance with privacy obligations under the EU-US Privacy Shield and the ISO Standards 27018 on privacy on clouds. While they offer the highest security safeguards, you should know that when your personal data is transferred to another country, it becomes subject to the laws of that country.

Children privacy

Our website is intended for business. We do not knowingly collect personal data from children.

If you think we have received personal data from children, please contact us immediately at [email protected] or or by mail at Legal Department, District M Inc., 5455 Gaspe Avenue, Suite 730, Montreal, Quebec, Canada H2T 3B3.

Your California Privacy Rights

We do not share personal data with third parties for their own direct marketing purposes without your consent. You provide consent when you accept cookies. We only share personal data when there is evidence of that consent.

To make any request to exercise your California Privacy rights please use the following contact

Email: [email protected] or 

Mail at Legal Department, District M Inc., 5455 Gaspe Avenue, Suite 730, Montreal, Quebec, Canada H2T 3B3.

Third party collection

Our website may include links to and from our partners, if you follow a link to any of these websites, please note that these websites have their own privacy policies, different from ours and you should review their privacy policies to understand the privacy practices of their services.

Changes and updates

district m will update this policy if we change any of our privacy practices. If we make changes to this privacy policy, we will post the changes here. If we make a change that significantly affects your rights, we will notify you by way of a prominent posting on our website, prior to the change becoming effective.

Questions? Concerns?

If you have any questions or concerns regarding the protection of your personal data at district m, please contact us at [email protected] or by mail at Legal Department, District M Inc., 5455 Gaspe Avenue, Suite 730, Montreal, Quebec, Canada H2T 3B3. For your protection, we may need to verify your identity before assisting with your request, such as verifying that the information you use to contact us matches the information that we have on file.

If you still have concerns about the protection of your personal data at district m, you have the right to file a complaint with the privacy or data protection authority of your country.

Privacy on our client facing platforms

What we collect and why

When you register to become a member of our platforms, we need some information to provide you access. We need to collect your business contact information, including your full name, mailing and/or billing address, email address, company name, and website URL and financial information to provide you our services.

District m uses this information to service its accounts and respond to inbound inquiries related to sales or technical support requests. Communications to business users are related to the Advertising Exchange. Our Exchange User Interface (UI) also uses analytics service providers to monitor traffic on the UI. We hold all such information submitted in strict confidence and as prescribed by applicable laws.

district m sets cookies on the Camp, Boost and FLO platforms.

We use:

  • Session cookies. They are limited to one visit. They allow clients to login and gain access to their account for the duration of their session.
  • Persistent cookies. They stay after the session and are used to recognize a client across sessions. We use this information to understand traffic patterns, optimize the platforms and enhance overall user experience.

You can opt out by disabling cookies through your browser but some features of the applications may no longer work, Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different  websites you visit. Our Platforms do not currently change the way they operate based upon a Do Not Track or similar signal.

To see all categories of data we collect, click here.

Data Sharing

district m does not share personal data from its client facing platforms.

We do not sell, supply, or otherwise make user personal data available to any third party under any circumstances, unless ordered to do under lawful authority.

Data Retention

district m will delete data pertaining to accounts as soon as they have been terminated or as requested by the user, except where the law requires us to retain it for a set period of time.

Accessing your personal data

You have the right to access your personal data we collect or use about you. You also have the right to not receive discriminatory treatment for exercising your access right.

To submit a request or designate an authorized agent to make a request, please contact us by email at [email protected] or by mail at Legal Department, District M Inc., 5455 Gaspe Avenue, Suite 730, Montreal, Quebec, Canada H2T 3B3.

We will reply within 30 days to give you access to your personal data unless we are prohibited from doing so, for example if providing you access would compromise the privacy of another individual.

If for any reason we cannot provide you access to your personal data, we will explain why.

Deleting your personal data

You have the right to request that we delete your personal data, subject to some exceptions. Once we receive and confirm your request, we will delete (and direct our vendors and service providers to delete) your personal data, unless an exception applies. In that case, we will provide justification. You also have the right not to receive discriminatory treatment for exercising your deletion right.

To submit a request or designate an authorised agent to make a request, please contact us by email at [email protected] or by mail at Legal Department, District M Inc., 5455 Gaspe Avenue, Suite 730, Montreal, Quebec, Canada H2T 3B3.

Data storage

We transfer client facing app data to the US through Amazon Web Services, Google Cloud or Salesforce. They are all certified for compliance with privacy obligations under the EU-US Privacy Shield and the ISO Standards 27018 on privacy on clouds. While they offer the highest security safeguards. You should know that when your personal data is transferred to another country, it becomes subject to the laws of that country.

All data collected, processed and ultimately stored by district m is fully encrypted in transit and at rest and access is managed through role-based access using secure protocols.

Children privacy

Our Platforms are for business, not for children. We do not knowingly collect personal data from children.

If you think we have received personal data from children, please contact us immediately at [email protected]  or by mail at Legal Department, District M Inc., 5455 Gaspe Avenue, Suite 730, Montreal, Quebec, Canada H2T 3B3.

Your California Privacy Rights

We do not share personal data with third parties from our Platforms.

To make any request to exercise your California Privacy rights please contact [email protected]  or by mail at Legal Department, District M Inc., 5455 Gaspe Avenue, Suite 730, Montreal, Quebec, Canada H2T 3B3.

Third party collection

Our website may include links to and from our partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies, different from ours and you should review their privacy policies to understand the privacy practices of their services.

Changes and updates

district m will update this policy if we change any of our privacy practices. If we make changes to this privacy policy, we will post the changes here. If we make a change that significantly affects your rights, we will notify you by way of a prominent posting on our website, prior to the change becoming effective.

Questions? Concerns?

If you have any questions or concerns regarding the protection of your personal data at district m, please contact us at [email protected]  or by mail at Legal Department, District M Inc., 5455 Gaspe Avenue, Suite 730, Montreal, Quebec, Canada H2T 3B3.

If you still have concerns about the protection of your personal data at district m, you have the right to file a complaint with the privacy or data protection authority of your country.

Privacy on advertising technology platforms

With a variety of platforms, district m provides solutions for business, to optimize ad placement online. Here we explain how we respect privacy in the context of our operations.

What we collect and why

In the context of its operations as an advertising technology provider, district m collects personal data from internet users visiting the websites of district m‘s  clients in the form of cookie identifiers, as well as facilitating the synchronisation of these cookies with other advertising technology partners.

This is what we do:

  • We target advertisements to users of digital media sites;
  • We evaluate and assess the advertisements and campaigns; and
  • We view and enforce user opt-out choices.

We use cookies to associate information that does not directly identify an individual user with browsers and devices, so that we and our clients can then use the information to optimize ad placements and campaigns for delivery via our Ad Exchange platform.

We engage in cookie syncing, which is the matching of our cookie IDs with that of our clients and partners. We collect and store IDs from a variety of domains, stored in either our domain or our client’s domain.

In the context of these operations, district m may collect and process the following information that is considered Personal Information under the laws of Canada (PIPEDA), Quebec (Privacy Act), Europe (GDPR) or California (CCPA) as part of its service offering to publishers using its advertising technology platforms to sell advertising on their sites:

  • Cookie identifiers;
  • Mobile device identifiers;
  • Browser and device information;
  • IP addresses and associated geo location data; and
  • Precise location data obtained from a device.

 

Industry self-regulation

IAB

District m strictly enforces the Interactive Advertising Bureau (IAB) Consent Framework for managing GDPR consent for data collection and processing in the European union. This means we do not process any personal data unless the consent string, meaning a code that signals consent status, shows that the user has consented to receive personalized advertising. District m also strictly enforces the IAB CCPA Compliance Framework for technology companies to manage data collection and processing in California.

district m has adopted the necessary policies, processes, practices and contractual clauses to comply with the European General Data Protection Regulation (GDPR) as outlined in this document and the California Consumer Privacy Act (CCPA) as outlined in this Privacy Policy.

DAA  

district m adheres to the Digital Advertising Alliance (DAA) Self-Regulatory Principles for Online Behavioral Advertising. For more information, please visit http://www.aboutads.info/. 

DAAC 

district m adheres to the Digital Advertising Alliance of Canada (DAAC) Self-Regulatory Principles for Online Behavioral Advertising. For more information, please visit http://youradchoices.ca/choices. 

TAG

District m is a member in good standing of the Trustworthy Accountability Group (TAG). 

Opt-out

To opt-out from our advertising technology platforms, click here.

You can also opt out from third party platforms for marketing purposes at the following addresses:

Data Sharing

Data Sharing is limited to real time transactions for the sale of advertisement to district m buying partners using the Open Real Time Bidding protocol, using the data listed above.

By contract, buying partners are required to offer the same level of compliance enforced at district m

Additional data shared with all partners is only offered in aggregated and anonymized form for financial and performance measurement reasons.

Data Retention

district m retains a database of synchronized cookie identifiers with their buying partners for up to 30 days, unless a user opts out.

district m does not store any personal data in transaction logs except for troubleshooting reasons where raw data may be extracted, analyzed and destroyed in the course of 24 hours.

All other retained data is anonymized and aggregated for analytical and reporting purposes.

Accessing your personal data

You can ask to access your personal data at district m at [email protected] or by mail at Legal Department, District M Inc., 5455 Gaspe Avenue, Suite 730, Montreal, Quebec, Canada H2T 3B3. We will reply within 30 days to give you access to your personal data unless we are prohibited from doing so, for example if providing you access would compromise the privacy of another individual.

If for any reason we cannot provide you access to your personal data, we will explain why. 

Data storage

We transfer data from advertising technology platforms to the US through Amazon Web Services or Google Cloud. They are all certified for compliance with privacy obligations under the EU-US Privacy Shield and the ISO Standards 27018 on privacy on clouds. While they offer the highest security safeguards, you should know that when your personal data is transferred to another country, it becomes subject to the laws of that country.

All data collected, processed and ultimately stored by district m is fully encrypted in transit and at rest and access is managed through role-based access using secure protocols.

Changes and updates

district m will update this Policy if we change any of our privacy practices.

Questions? Concerns?

If you have any questions or concerns regarding the protection of your personal data at district m, please contact us at [email protected] or by mail at Legal Department, District M Inc., 5455 Gaspe Avenue, Suite 730, Montreal, Quebec, Canada H2T 3B3. If you still have concerns about the protection of your personal data at district m, you have the right to file a complaint with the privacy or data protection authority of your country.