Privacy Practices for the Website


The Website is used for providing business information to prospective clients and business partners. It also serves as a marketing vehicle for Division-D. Division-D is committed to respecting your privacy and conducting business matters that follow all policies as required by law.



Collection and Use of “PII” (Personally Identifiable Information) on the Website




Collection and Use of “Non-PII” (Non-Personally Identifiable Information)


Division-D also collects Non-Personally Identifiable Information (“Non-PII”) from visitors to this Website. Non-PII is information that cannot by itself be used to identify a particular person or entity, and may include 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.


This Website uses Google Analytics to help analyze how users use the Website. The tool uses “cookies,” which are text files placed on your computer, to collect standard Internet log information and visitor behavior information in an anonymous form. The information generated by the cookie about your use of the Website (including IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the Website and to compile statistical reports on Website activity for Division-D.



Cookies and Other Tracking Technologies


Division-D and our partners use cookies or similar technologies to analyze trends, administer the website, and track users’ movements around the website. Users can control the use of cookies at the individual browser level. For more information about cookies, please visit https://www.allaboutcookies.org/cookies/.


We work with a third party to manage our advertising on other sites which is sometimes based upon your visit to this Website and other sites. Our third party partners may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. Sometimes this practice is referred to as interest based advertising. If you wish to opt out of interest-based advertising from our partners, click here. Please note you will continue to receive generic ads.



Privacy Practices for the Network


Division-D operates a virtual advertising network (the “Network”) where we direct 3rd party technology platforms (our “Partners”) to help advertisers (our “Clients”) find the right digital audience and to help website and mobile application publishers (our “Publishers”) do a more effective job monetizing their content. Division-D does not physically store any data via our Network. Rather, we purchase media on behalf of our Clients and engage our Partners to serve the ads and provide additional services pursuant to ensuring the media we buy for Clients from our Publishers. We adhere to the Digital Advertising Alliance Code to the extent that it is applicable to our business.



Collection of Information via the Network


Division-D doesn’t physically store information directly via the Network. Rather, information is collected and processed by our Partners pursuant to their privacy policies. We encourage you to read our Partners’ privacy policies. Generally, these partners collect Non-PII 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. Some Partners work with us and our Clients to enable our Clients to bring their offline data into our systems for use by our technology.



Cookies and Tracking Technologies


Our Partners generally use cookies, mobile advertising IDs and similar tracking technologies in order to more effectively run ad campaigns on our behalf. Division-D does not generally use cookies in connection with the Network.



Choice Mechanisms


While Division-D doesn’t directly process data via the Network, many of our Partners provide choices regarding how information is collected or used on the Network. Each of these opt-out mechanisms are designed to enable you to exercise choice as is applicable for each Partner:


Zedo - https://zutils.zedo.com/tools/zedo_optout.cgi

Appnexus - https://www.appnexus.com/en/company/platform-privacy-policy#choices

Oath - https://policies.oath.com/us/en/oath/privacy/adinfo/index.html

LKQD Platform - https://ad.lkqd.net/optout/optout.html

SpringServe - https://springserve.com/opt-out/


In general, in order for any of these tools to work on your computer, your browser must be set to accept third party cookies. If you buy a new computer, change web browsers or delete this cookie, you will need to perform the opt-out task again.


You may also visit the 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 many of our Partners. To access this service, please visit the DAA at: https://www.aboutads.info/choices/.


The NAI also provides a mechanism to opt out of its member networks here: https://www.networkadvertising.org/managing/opt_out.asp and the European Digital Advertising Alliance opt-out page may be found at https://youronlinechoices.com/.


If you are looking to exercise choice regarding your mobile device, please visit the NAI’s Mobile Choice information page at https://www.networkadvertising.org/mobile-choice/ and follow their instructions.



Onward Transfer of Information


We do not share PII collected via the Website with anyone outside of Division-D, unless specifically stated otherwise. Division-D does not sell, rent or lease such PII collected on the Website to non-affiliated third parties without your consent. We don’t generally share PII provided from Clients, Publishers or Partners other than with our agents and service providers who are bound by confidentiality provisions. In cases of onward transfer to third parties of the personal data of EU and Swiss individuals received pursuant to the EU-US and Swiss-U.S. Privacy Shield, Division-D is potentially liable.


Division-D may share information for the following purposes: (i) to enable third party service providers to assist or facilitate in the services Division-D provides; (ii) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information Division-D receives, whether or not a response is required by applicable law, and to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Access, or as otherwise required by law; (iii) for law enforcement or national security purposes including sharing data of EU and Swiss individuals in response to lawful requests from public authorities to meet national security and law enforcement requirements; (iv) to enforce an agreement or to protect Division-D’s rights; with any parent, affiliated or successor entity; (v) in connection with any asset sale, transfer, divestiture, bankruptcy or liquidation; (vi) in connection with strategic alliances, partnerships or other business arrangements to permit the offering of products or services Division-D believes may be of interest to you or where Division-D has determined that the information will be used in a responsible manner by the third party; or (vii) as permitted under any agreement with you. Division-D may also share aggregated data with others.


While our Partners may provide Division-D, our Publishers and our advertising Clients with reports pertaining to advertising campaigns, neither Division-D, our Publishers nor our Clients have access to IP addresses, cookie IDs or other forms of pseudonymous data via the Network, although Publishers and Clients may obtain this data independent from the Network. To the extent that our partners may transfer data across international borders, they are required by law to have an appropriate data transfer mechanism such as membership in the Privacy Shield program.



Children’s Information




Data Subject Access Rights




Security Measures


Division-D uses appropriate measures to ensure the security of all information, including the use of passwords, firewalls, encryption and remote servers, and routinely evaluate our practices to identify security threats or opportunities for the improvement of our services. No transmission of information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. You acknowledge and agree to assume this risk when communicating with us.



Other Notices


We reserve the right to modify this privacy policy at any time in the future. Please note that the use of information that we gather is subject to the privacy notice in effect at the time of use.



European Economic Area



While Division-D does not physically store personal data in the context of our Network, we do have Clients located in the EU and we do place media buys on behalf of Clients which may collect data from data subjects located in the EU. Our Clients and Publishers direct us to process data under their general instructions but we may direct our technology Partners to adjust advertising campaigns where we feel appropriate. We rely on the consent of the individual to process personal data in some instances (for example, when the user inputs personal data onto a web form of our Website). On other occasions, Division-D may process personal data when needed to fulfill a contract with a Client or partner or where required to do so by law.


We may also process data when it is in our or our Clients’ legitimate interests to do this and when these interests are not overridden by the individual’s data protection rights (which may vary based on an individual’s jurisdiction). Certain Publishers, Clients and Partners choose not to operate in the EU and/or collect data from EU data subjects – and each has a process to ensure they are not collecting personal data from the EU on the Network.



Privacy Shield


Division-D complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield.  Division-D has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Division-D is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.



We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you. If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.



Third-party Websites


Division-D is not responsible for the methods by websites or applications that contain links on the Website or are linked to its website nor the contact and information presented therein. Third-party Internet websites and services accessible through Division-D have separate privacy and data collection practices, independent of Division-D. Division-D has no responsibility or liability for these independent policies or actions. The collection and use of that data is governed by the privacy policy and legal terms of the data collector and the website using the data; it is not governed by Division-D.






Attn: Privacy Officer


602 Fay Street

Suite 101

Columbia, MO 65201