Privacy Policy

Last Updated: June 9, 2023

Tredio is committed to protecting your privacy and treating your personal information with transparency, care, and respect.

This Privacy Policy (Policy) explains how we collect, use, and share (collectively, Access) your personal information, personal data, or the equivalent terminology in your region (collectively, Data). For reference, Data refers to any information that may directly or indirectly identify you. The Policy also explains how you can exercise your rights under applicable data protection and privacy laws, including data protection and privacy laws in California, Europe, and Brazil.

Any reference in this Policy to “Tredio”, “we”, or “our” refers to Coresibo Ltd. dba Tredio., and its direct and indirect global subsidiaries.

1. ABOUT US

Tredio is a global digital advertising platform. Our technology (the Tredio player and exchange) helps our clients deliver advertising to you. The Tredio Platform hosts digital auctions that help our clients buy and sell online ads (collectively, our Platform Services). These ads can be found on websites, mobile applications (apps), or video programming services, such as streaming apps on Smart TVs (collectively, Digital Properties).

As with any exchange platform, we act as an intermediary between buyers and sellers. Throughout this Policy, we refer to our clients that sell ad space as Publishers. Publishers own or operate the Digital Properties you may use or visit. We refer to clients that buy ad space (e.g., advertisers) as Buyers. Buyers may include Demand-Side Platforms (DSP), Data Management Platforms (DMPs) and other partners (collectively, Demand-Side Partners). Demand-Side Partners act as additional intermediaries in the digital advertising supply chain that connect advertisers to Tredio to serve relevant ads to you on the Publisher Digital Properties you visit. Demand-Side Partners liaise with other Buyers, which also include advertisers (e.g., brands), advertising agencies, and ad networks (collectively, Ad Partners). In summary, Tredio and Demand-Side Partners act as intermediaries that connect Ad Partners with Publishers to deliver relevant digital ads to you.

This Policy describes Tredio’s Data practices. It does not apply to information or Data collected by third parties, including those of Publishers or Buyers. We recommend that you consult the privacy policies of the Digital Properties you use in order to become familiar with their privacy practices.

Please note, Sections 1-10 of this Policy provide information about the Data we Access in the provision of our Platform Services to our clients. For information on our corporate Data collection practices, please refer to our Corporate and Careers Privacy Policy under Section 11.

We recommend that you read this Policy in full.

2. HOW WE ACCESS YOUR DATA

Tredio may Access your Data in different ways depending on the way you interact with us. Please find below an overview of how we may Access your Data.

Platform Services: Tredio Accesses your Data when you visit a Publisher’s Digital Properties. Tredio Accesses your Data only to provide our Platform Services if we have permission from Publishers to do so. The Data we Access is limited to digital identifiers (e.g., cookies, device information, IP address).

Corporate: If you interact with us in a business capacity, we Access your Data as part of our business relationship with you, either pursuant to a written agreement, or because of our legitimate interest.

Website: If you accept cookies, when you visit our corporate website, www.tredio.io or any international, affiliated Tredio websites (Website(s)), Tredio receives Data including your IP address and information about your browsing behavior on our Website(s). If you fill out a form to connect with Tredio over email (for example, to hear more about our products and services), we collect and store your name and email and use this Data to communicate with you for the express purpose described when you provided this Data; we also associate this Data to the Data Tredio previously received from the cookies on our Website(s) (noted in the previous sentence). You can revoke your consent at any time and exercise your other privacy rights as outlined in Section 10 below). Tredio also uses cookies on our Website(s) for website function and to enhance your user experience. 

More information on these three categories can be found below.

3. TYPES OF DATA WE ACCESS

Below is a list of Data we may Access solely for the provision of our Platform Services to our clients. We may not receive all of the information listed below every time we provide the Platform Services; the information we receive is predominantly determined by each Publisher with which you interact.

1. DIGITAL IDENTIFIERS
   1. Online identifiers (IDs) – these are digital identifiers that may indirectly identify you and include:
      1. Cookies – small text files/code stored on your browser that allows us to collect information. More information on our cookies can be found within our Website and Cookie Notice.
      2. Pixels – HTML code snippets loaded when you visit a website that allows us to collect Data.
      3. Third-party online identifiers – IDs that belong to third parties. Third-party IDs may be associated to broad aggregate audience segments and shared with Buyers to serve more relevant ads to you based on your interests (e.g., ads related to sports or fashion).
         1. Our handling of your Data includes a process known as user matching. In this process, we match our cookies to the third-party IDs of our partners to provide more effective ways to deliver relevant ads to you.
   2. Browser information – information including, but not limited to, the type and version of your browser, browser settings (such as language and local time), user agent, and your IP address.
   3. Device Information – as applicable, general information including, but not limited to: device type (e.g., laptop, mobile, TV), model, manufacturer, operating system, time zone, telephone carrier information, network information (e.g., WIFI), and mobile application information. Mobile device information includes standard mobile advertising identifiers located on every mobile device. These are:
      1. IDFA – advertising identifier used on Apple’s iOS devices; and
      2. Google Advertising ID (AAID or GAID) – advertising identifier used on Android devices, to track your use of mobile apps on your device(s).
   4. Location information – geolocation information such as city, country, zip code/postal code, and/or longitude/latitude. We may receive location information from Publishers that is referred to as precise geolocation data.

A note on Cross Device Linking: Cross device linking is the process of tracking a user across multiple devices, for example, across a Smart TV, mobile, and/or website. Tredio does not directly participate in cross-device linking. However, some of our partners may engage in cross device linking to serve you more personalized advertising.

Tredio also does not measure click through rates, your browser history, or engage in retargeting, reidentification, or audience segmentation; however, some of our partners may engage in these practices.

4. HOW WE USE YOUR DATA

We Access your Data to provide our Platform Services. Please find described below the business purpose(s) for which we process Data, and our legal basis for doing so:

1. FOR OUR BUSINESS PURPOSES

We Access your Data (per Section 3 above) for the following business purpose(s):

1. Ad delivery – to deliver ads to you on Publishers’ Digital Properties.
2. Ad reporting – to verify an ad was delivered to you with accuracy.
3. Troubleshooting, optimizing, and product improvement – to improve our Platform Services and ensure ads are delivered correctly to you.
4. Ad vetting – to prevent fraud, malware, and other unacceptable behaviour.
5. Privacy Rights – to view and enforce your opt-out choices, and honour your privacy choices/rights. For example, we may Access your Data if you make a request to delete your Data.

1. LEGAL BASES FOR ACCESSING DATA

International law, such as European data protection law, requires us to have a legal reason for Accessing your Data. Tredio Accesses your Data under one or more of the following legal bases:

1. Consent – Tredio may Access your Data if you provide Publishers with the consent for us to do so. This means, for example, if you visit a website that has a cookie banner and click “Accept All”, Tredio will receive a technical signal confirming that you are providing us with the consent to Access your Data.
2. Legitimate Interest – we may also Access your Data if we have a legitimate reason to do so. For example, we Access your Data to provide our Platform Services. Such Platform Services allow you to view the free online content in which you may be interested (e.g., a news website or blogs). Tredio will not override your privacy and/or fundamental rights and freedoms to exercise our legitimate interests.

5. HOW YOUR DATA IS SHARED WITH OUR PARTNERS

We may disclose, share, or sell (collectively, Share) your Data with the following partners for the purpose of delivering ads to you:

1. BUYERS: As noted above, we connect Publishers with Buyers of ad space. Buyers include Demand-Side Partners (other intermediaries) and Ad Partners (advertisers and ad agencies). We Share your data with Buyers to source ads that may be relevant to your interest(s). Buyers may Share your information with their clients and partners for the provision of their services. Each Buyer processes and Shares Data in accordance with their own privacy policies.
2. IDENTITY PARTNERS: On the instruction of Publishers, your Data may be Accessed and Shared by Identity Partners. These are independent companies that use online identifiers to group you into broad based, aggregated audience segments (i.e., age 25-35; interests: cars), which they have collected independently of Tredio. Tredio does not actively collect any audience segments about you, however our technology facilities the delivery of these audience-based identifiers to Buyers.
3. QUALITY VENDORS: We may send your Data to third-party vendors that help maintain the integrity of our Platform Services; for example, by preventing malicious software (e.g., viruses, trojans), or traffic from non-humans (i.e., bots), from loading on the websites you browse.
4. LEGAL REASONS: We may be required to disclose your Data to comply with our legal obligations, or in cases where we believe in good faith that such disclosure is required by law.

How we protect your Data: If we Share your Data with another company, it becomes subject to their privacy practices which may differ from the information found in this Policy. To help protect your Data, Tredio contractually requires Buyers to comply with applicable data protection and privacy laws and implement user-centric privacy practices.

6. INTERNATIONAL DATA TRANSFERS

Tredio is a global company. To provide our Platform Services, we may transfer your Data internationally to any of our data center locations, or to any Buyer’s international data center locations. We respect the security and confidentiality of your data while effecting these international transfers as described below:

1. EUROPEAN DATA PROTECTION REGULATIONS

We ensure any international transfers of your Data are compliant with the laws of that region, including the European General Data Protection Regulation (GDPR). Specifically, with respect to the European Economic Area (EEA), we ensure appropriate legal protections are in place when we transfer Data outside of the EEA to the United Kingdom (UK), Switzerland, or any other country, as provided for under European data protection legislation. These protections include using technical measures, such as encryption of Data, or a legal mechanism, such as the Standard Contractual Clauses (SCC), which are approved by the European Commission. The SCCs standardize the protections for any international transfers of your data from the EEA to other countries, thus providing you with assurance that your will be able to access your rights for the protection of Data in a manner consistent with European data protection law. In the event of any conflict between the terms of this Policy and such transfer mechanism, the terms of the transfer mechanism will govern.

1. CONSUMER COMPLAINTS

Tredio will investigate and attempt to resolve any privacy-related complaints or concerns within forty-five (45) days of receipt. If you have an unresolved complaint or concern that we have not addressed satisfactorily or in a timely manner, you may contact the International Centre for Dispute Resolution/American Arbitration Association (“ICDR/AAA”), a US-based, third-party dispute resolution provider (free of charge). 

7. CALIFORNIA RESIDENTS

As a California Resident, you have the following rights under the California Consumer Privacy Act (CCPA):

1. You have the right to know and access:
   1. the categories of personal information and specific pieces of personal information we have collected,
   2. the categories of personal information we have disclosed for a business purpose to third parties in the preceding 12-months,
   3. the categories of sources from which we collect personal information,
   4. the business or commercial purpose for collecting, sharing, or selling your personal information, and
   5. the categories of third parties with whom we disclose, sell, or share personal information with;
2. You have the right to request deletion of personal information that we have collected, subject to certain exceptions;
3. You have the right to request correction of inaccurate personal information;
4. You have the right to opt out of the sale or sharing of your personal information; and,
5. You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the CCPA

8. EXERCISING YOUR PRIVACY RIGHTS

Please find details on how you can exercise your privacy rights below.

1. ACCESS AND DELETION DATA

You can access or delete the Data we may have about you by emailing privacy@tredio.io.

1. DATA PORTABILITY

When you submit a request to access your information, Tredio will provide your Data to you in a pdf document.

1. CORRECT YOUR DATA

You have the right to correct your Data. However, please note that any such correction is subject to our practical limitations. The Data we Access is in the form of technical identifiers and changing it can be impossible/impractical. If you feel the Data we have about you is incorrect and would like us to rectify it, please contact us at privacy@tredio.io for assistance or at the address in the “Contact Us” heading below.

1. OBJECT TO ACCESSING

The ads you see on Publisher Digital Properties may be tailored to your interests. Tredio offers options to opt-out of (“stop” or “object to”) ‘interest-based’, or ‘personalized’ advertising. This ensures you will not receive advertising based on your personal interests. Kindly note, opting-out of personalized advertising does not mean you will no longer see online ads, it simply means you will not see ads tailored to your personal interest

1. Web Browser Option to Opt–Out
   1. To opt-out of the Accessing of your Data for personalized advertising, please visit the National Advertising Initiative’s opt-out page: https://optout.networkadvertising.org/?c=1.Please note that when you opt-out, a cookie will be stored in your web browser signaling your opt-out preference to Tredio. If your browser is configured to block third-party cookies, then the opt-out cookie may not work. If you delete your browser cookies, you will need to opt-out again. The opt-out will only apply to the specific browser in which you set it, and the opt-out Access must be repeated for each different browser.
2. Mobile Opt-Out
   1. Please find below information on how to opt-out of the Accessing of personalized advertising on your mobile device.
      1. Option 1: Visit http://www.aboutads.info/appchoices, download the Digital Advertising Alliance’s AppChoices mobile app, and follow the instructions provided in the AppChoices mobile app.
      2. Option 2: Adjust the advertising preferences on your mobile device:
         • In iOS – please visit Settings > Privacy > Advertising > Limit Ad Tracking;
         • In Android – please visit: Settings > Google > Ads > Opt out of interest-based ads.
   2. More information on your mobile opt-out choices can be found here: https://www.networkadvertising.org/mobile-choice.
3. Television & Digital Video Programming Opt-Out:
   1. Digital video programming devices (such Smart TVs and apps on Smart TVs) may give you the ability to opt out of the use of your Data for advertising purposes. To determine if your device has these options, please visit your device’s setting menu(s). You may wish to consult the following guidance for consumer choice mechanisms on various connected devices: https://www.networkadvertising.org/internet-connected-tv-choices/.
4. California – Do Not Sell my Personal Information:
   1. To submit a request to opt-out the sale of your information, please visit this link.

1. RIGHT TO LODGE A COMPLAINT – EUROPE

Tredio complies with our obligations under European data protection laws and makes every effort to ensure your rights are protected and respected. If you have any questions or complaints regarding our Data processing, please contact us directly or through our Data Protection Officer (DPO), using the details provided under the “Contact Us” section.

You have a right to lodge a complaint with your local Data Protection Supervisory Authority if you wish to dispute the way we Access your Data. Please see the contact details of supervisory authorities below:

1. EU Data Protection Authorities: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm
2. The Swiss Data Protection Authority: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html
3. UK Information Commissioner’s Office: https://ico.org.uk/for-the-public

9. DATA SECURITY

The security, integrity, and confidentiality of your Data are extremely important to us. We implement technical, administrative, and physical security measures to protect your information from unauthorized access, disclosure, use, and modification. Such measures include but are not limited to: (a) encryption, (b) controls that limit the access of your data, both technically and at our physical data center locations, and also (c) by enabling information security practices such employee training on the safe handling of Data. We regularly review our security procedures to ensure the protection of your information. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. If you have reason to believe your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

10. DATA RETENTION

We retain your Data for the time needed to provide our Platform Services, or as otherwise required or permitted by law. Our maximum retention period is thirteen (13) months, after which we de-personalize Data by aggregating it, and these aggregate datasets cannot be traced back to individuals.

11. CORPORATE AND CAREERS PRIVACY POLICY

The information in this Section 11 describes how Tredio Accesses information applies to your interactions with us in a business capacity only. For example, if you are a client or business and you are engaging in a business relationship with Tredio or if you are a candidate applying for an employment opportunity at Tredio, Section 11 applies.

Such business-related activities include when you: (a) register to become a member on the Tredio client user interface; (b) attend an Tredio sponsored event; and/or; (d) participate in a business relationship with Tredio that requires the submission of your identifiable information to Tredio (i.e., negotiating your business relationship with us, providing responses to our company surveys, etc.). Collectively, these are our Commercial Purposes for collecting your information. Tredio may also collect your professional and academic background when you send us your CV/resume to work with us (Employment Purposes).

1. TYPES OF INFORMATION WE COLLECT

Tredio may collect your full name, mailing and/or billing address, email address, company name, job title, department or job role, and similar contact data (your Identifiable Data) in the course of our business relationship with you.

We collect information about you in connection with Employment Purposes. Categories of information we may collect about you include, but are not limited to:

1. Contact information – name, address, telephone or mobile number, email address, and other contact information,
2. Employment and education – cover letter, résumé, CV, work experience, relevant experience, educational background, information from professional licensing and certification bodies,
3. Government issued ID or similar ID – citizenship, residency, and work permit status,
   References – information from your previous employers or other references,
4. Background checks – information related to a background check,
5. Publicly available information – information you’ve made public such as a public profile on a career or networking site,
6. Assessments – mandatory assessment information such as interviews and skills tests, and
7. Voluntary Data – information you choose to provide voluntarily such as a voluntary opt-in candidate experience feedback survey.

1. PURPOSES AND LEGAL BASES FOR USING IDENTIFIABLE DATA 

Listed below are the purposes and legal bases for which Tredio may Access your Identifiable Data in the course of our business relationship with you.

1. Management of the contractual or pre-contractual relationship: Tredio uses your Identifiable Data to service accounts and respond to inbound inquiries related to sales or technical support requests and for billing purposes. This may include sharing inviting you to provide feedback to us using a third-party service provider. We may internally use Identifiable Data for analytical purposes, for example, to improve our UI or the services we provide to you. We may also use your Identifiable Data in the assessments of your CVs/resume and to manage our recruitment processes.
2. Legitimate interest: As applicable, we may use Identifiable Data to send you marketing and promotional communications (for clarity, this is not for Employment Purposes), to evaluate and improve our internal services, and to build our relationship with you.
3. Consent: Kindly note, you provide us with consent to use your Identifiable Data for the above Purposes and Employment Purposes when you participate in a business relationship with Tredio.

We process information related to Employment Purposes to:

1. Process your application – we use your information to review and process your application,
2. Assess qualifications and suitability – we use information to assess your skills and qualifications,
3. Contact you – we may contact you for a current or future opportunity, to schedule interviews, and otherwise communicate with you relating to your application,
4. References, background checks, and as legally required – if you are offered a role, we use information to verify information you or others provide to complete background checks, verify eligibility to work in the country you applied for a role in, or check your references, and
5. Other purposes with consent.

1. TRANSFERS OF IDENTIFIABLE DATA

We may be required to disclose your Identifiable Data to comply with our legal requirements, or in cases where we believe in good faith that disclosure is required by law.

We may transfer your Identifiable Data internationally to any of our data center locations globally, ensuring that any international transfer of your Data is compliant with the laws of that region. When we transfer Identifiable Data outside of the EEA, we ensure that appropriate legal protections are in place under European data protection legislation. These protections may include technical measures, such as encryption, or a legal mechanism such as the Standard Contractual Clauses approved by the European Commission. For example, as part of the recruitment process, your information may be transferred to a member of our HR team located in another country.

1. YOUR PRIVACY RIGHTS

You retain your rights to access, correction, erasure, limitation, and objection of the processing of your Identifiable Data. You have the right to revoke consent granted to Tredio at any time and to file claims with appropriate Data Protection Authority. Please not that all other rights described in this Policy also apply. For example, California Residents should review sections 7 and 8 of this Policy to better understand their rights and how to enforce them.

For more information and/or to exercise your rights, please contact us at privacy@tredio.io. If you do not wish to contact us by email, please see the “Contact Us” section below for additional details.

1. DATA RETENTION

Tredio will only retain information for as long as it is necessary to carry out our intended Purposes as described herein. Any of the Identifiable Data you provide us through the channels will be deleted once it is no longer necessary to manage our business relationship with you. Any Identifiable Data retained is in compliance with our legal obligations and will only be shared if there is a legal obligation for us to do so, based on a request from the appropriate authorities.

1. DATA SECURITY

We implement technical, administrative, and physical security measures to protect your information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to ensure the protection of your information. Please be aware, despite our best efforts, no security measures are perfect or impenetrable. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately in accordance with the “Contact Us” section below.

1. OTHER

Please note that all other sections of this Policy may also be applicable to the processing of your Data (for example, the Cookie and Website Notice below will also apply if you visit one of our websites).

12. WEBSITE AND COOKIE NOTICE

This Website and Cookie Notice explains how Tredio uses cookies. Cookies are text files that store small pieces of information. They are stored on your device when the website is loaded on your browser. On our Website, cookies help us make our Website function properly. On our Platform, cookies help our clients deliver personalized advertising to you.

For ease, this Policy breaks down Tredio’s use of cookies in two sections:

1. WEBSITE COOKIES (on www.tredio.io and all of our international sites)
2. PLATFORM SERVICES COOKIES

The information below outlines how Tredio uses cookies in our interactions with you.

1. WEBSITE COOKIES

Use of cookies on our Website:
Our website uses first-party and third-party cookies. First-party cookies belong to us and are necessary for website functioning (e.g., the pages loading correctly). Third-party cookies belong to website service providers (such as Google Analytics and marketing platforms) and help us understand how the website performs.

We use Google Analytics to assess your use of the website and provide reporting on website activity to Tredio. The retention period for these cookies is 26 months. You can review Google’s privacy policy at https://policies.google.com/privacy.

Please note that we are not responsible for the operation of third-party cookies such as Google Analytics. The data collection, use, and sharing practices of these third parties is governed by their privacy policies and differ from those found in this Policy.

1. TREDIO PLATFORM

As noted previously, the Tredio Platform is our technology that helps our clients deliver advertising to you. The Platform uses the following first-party cookies to facilitate the delivery of advertising. Please note that cookies are limited to websites only. They are not applicable to mobile or digital video programming apps that you visit.

Ad-Serving Cookies	Purpose	Duration of Processing (the amount of time the cookie remains on your browser)
CMID	Unique cookie identifier which links your browser to an internal Tredio user file.	1 year (renewed every time you visit a Publisher’s Digital Property)
CMO	Provides a signal to us if you have opted-out of using any online behavioral advertising opt-out tools (such as the NAI opt-out above).	5 years
CMPS	Identifies the profile server for load-balancing and quick responses to your webpage page.	90 days (renewed every time you visit a Publisher’s digital property)
CMPRO	Identifies the profile server for load-balancing and quick responses to your webpage page.	90 days
CMTEST	Confirms if we can create cookies.	1 hour
CMTS	Identifies the back-up server for load-balancing and quick responses.	90 days
CMRUM3	Contains a mapping table that matches user IDs with those of Buyers.	1 year
CMDD	Measures how many unique pages engaged with on a web property.	1 day
CMGO	Identifies the primary server for load-balancing and quick responses.	Expires when you close your browser

 

How can you control the cookie preferences?

If you decide to change your preferences through your browsing session, you can click on the “Privacy & Cookie Policy” tab on your screen. This will display the consent notice again enabling you to change your preferences or withdraw your consent entirely.

In addition to this, different browsers provide different methods to block and delete cookies used by websites. You can change the settings of your browser to block/delete the cookies. To find out more about how to manage and delete cookies, you can visit: www.allaboutcookies.org.

13. SELF-REGULATION INITIATIVES

Tredio supports efforts for self-regulation in the digital advertising industry. Tredio adheres to the best practices set forth for data privacy and security published by the Network Advertising Initiative (NAI); and the Interactive Advertising Bureau (IAB); all of which help set industry standards for the ethical processing of your Data.

14. CHANGES TO THIS POLICY

We may change this Policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. The date at the top of this Policy reflects the most recent changes made. If we make material changes to this Policy, we will post the revised Policy on our website and may take additional measures to inform you, as required by applicable data protection and privacy laws.

15. CONTACT US

PRIVACY TEAM AT Tredio

If you have any questions, concerns, or complaints related to our privacy policy or how we process your personal data, please contact us by e-mail at privacy@tredio.io or at the following address:

Attn: Tredio c/o Privacy

47 Aluf David St

Ramat Gan, Israel 5223209