Privacy Policy

Last Updated: June 1, 2018



Introduction

This is Coastal Digital Group Inc.’s (“CDG”, “we”, “us”, or “our”), along with its divisions High Tide Media and Neptune Platform (from here on out referred to under Coastal Digital Group Inc.), privacy policy. It applies to our websites visitors (the “Website”), users of CDG’s creative management platform (“Neptune Platform”, or the “Platform”), and the end users of digital advertisements that are created/trafficked through the Neptune Platform (“End User”). By using our Website or Platform, you acknowledge that you have read, and agree to, our privacy practices.

This document will provide the necessary information about the way we use information that is shared with us. Also to ensure that you fully understand what information is collected with your permission, and what we do and do not do with that information. As members of the IAB Canada, we follow the strict guidelines set out in regards to data collection.




Non-Residents of European Union

Personal Data – Will relate to any data that may be used to contact, locate exactly, or identify a person, such as name, address, email, and telephone number.

Non-Personal Data - Will relate to all information that is collected but not included in the personal data definition. Examples of such non-personal data are browser and device type, ad interaction movements, and IP address and Advertising ID’s (AAID/IDFA).



Residents of European Union

Personal Data – Will relate to any data that relates to an identified or identifiable person. An identifiable person is someone who can be identified, indirectly or directly, by an identifier such as a name, ID number, location data, or and identifier to one or more factors specific to the economic, cultural, physical, genetic, social identity, IP address, and Advertising ID’s (AAID/IDFA) of the person.

Non-Personal Data - Will relate to all information that is collected but not included in the personal data definition. Examples of such non-personal data are browser and device type, ad interaction movements, and generic ad information like time spent on unit.



What is Collectable Information?
How do we use the collected information?

On our Website, we collect only contact information that has been provided to us by the visitor through the “Contact Us” form. Such information may include your name, email, job title, or organization/company name. This information may be used for communication with you for promotional and marketing purposes via emails, which at any time can be stopped. All communication will come with the option to unsubscribe to future communication.

On the Neptune Platform, information may be collected for multiple purposes: (1) to improve the overall service of the Platform and CDG to you, (2) information that is mandatory in order to use the Platform, and (3) information from interaction with the Platform from an End User of the digital advertisement. The above information we collect may be transferred, stored, used, and/or processed as follows:


Billing Information

To use Neptune Platform’s services, you will be required to provide additional information in order to complete the sign up. This information will be use solely for processing payments, and may include credit card number, billing address, and similar information. CDG uses third-party service providers who will manage the credit card processing, and are not permitted to retain, store or use such information except for the sole purpose of the credit card processing.

Interaction Information

As the End User, you would have interacted with the digital advertisement that was created and served by the Platform. This information may be collected on behalf of CDG’s clients. As outlined in Non-Personal Data, information such as video views, advertisement click, IP address, GPS coordinates, Advertising Identifiers, and other information about your interaction may be collected. With this data, CDG is acting as a data manager on behalf of our customers. Our customers are the controllers of your data and may use it to their lawful advertising purposes. CDG may also use this data internally to improve our overall Platform and service.

Activity Information

Through the use of the Neptune Platform, user’s activity data may be collected. This information may include page visits, time spent on pages, IP address, browser and language, and other similar user data related to your use of the Platform. We may use this data to improve the Platform and the overall user experience. If the activity information falls under certain region’s Personal Data guidelines, we process and comply with the applicable laws.



What Personal Data can be disclosed?

At your direction or as written out below, we may share your information.


CDG’s Clients

We share Interaction Information (listed above) with our clients, who in turn may use this information for their lawful advertising purposes.

Third-Party Service Suppliers

The Platform relies on some third-party providers for support in our service. We may share your information with these third-party providers in order for us to operate, such as billing our clients, provide technical support, hosting services, and other operational support. We ensure that all third-party providers are contractually required to protect your Personal Data all the time.

Law Compliance

CDG may disclose information if required by law to do so and to the extent we are required to, such as to courts, law or government authorities, or authorized third parties.

Other

In the case where CDG is involved with any acquisition, sale of assets, bankruptcy, and other insolvency event, we may sell or share all assets, including your Personal Data. However, notification will be sent before any Personal Data is moved and a new policy is put in place. CDG may also disclose under circumstances that are not listed, with prior consent of the person that submitted the information to us.

Security

CDG has in place reasonable technical security measure to ensure all Personal Data is safeguarded while being submitted through website or the Platform. However, we cannot control the actions of third parties that you choose to share your Personal Data with, nor can we accept liability for improper use and access to such data. There is no guarantee that the information you share will not become publicly available.



What are Cookies and the options to disable them?

A cookie is a small text file that is fired every time the user’s browser loads the webpage. This triggers the call from a web server to the user’s browser back to the web server. This file is placed on your computer or device until it expires or you delete it. We do not sell or distribute the information collected by cookies.

In digital advertising, cookies generally store a unique identifier that may contain information like what ads were recently seen, how long the cookie has been created, and other simple attributes. Cookies can also store your preferences and enable a website to recognize you when returning (through the unique identification number).

CDG’s websites may place cookie files on your web browser. We utilize cookies to provide analytics and store preferences. We may also use third-party cookies to help analyze your activity on a deeper level, such as new or returning user, demo interactions, and usage statistics of our website. CDG does not collect any of your Personal Data through cookies, nor do we provide any Personal Data to the third-party cookies used.

Neptune Platform, it’s service, and its customers, may use cookies to customize your experience as an End User. CDG clients may use cookies to tailor digital advertisements to you and help track and measure the success of such digital advertisement. Cookies that are placed by the Platform on behalf of CDG’s clients, will exist for no longer than 60 (sixty) days, however can be refreshed every time you are shown the digital advertisement. CDG’s clients may use the information collected in the cookies with other information that they have independently collected. These third-party collectors will have their own privacy policies.


Disabling Cookies

You may instruct your browsers to stop allowing cookie collection from particular websites. All changes will be made in your browser’s settings. Please refer to the help page on how to disable the cookies. Some popular browser’s instructions are here:

Chrome | Safari

For cookies generated by advertisers, you have the option to disable them as well. You may go to the following self-regulatory program opt-out pages:
http://optout.aboutads.info/?c=2&lang=EN
http://optout.networkadvertising.org/?c=1#!/
And if you are in the EU: http://www.youronlinechoices.eu/


For Mobile users, you may wish to block or opt-out of interest-based advertisement.
iOS users = https://support.apple.com/en-us/HT205223
Android users = https://support.google.com/ads/answer/2662922?hl=en


We are committed to ensuring that all your information is secure. Internally we have set up physical and electronic safeguards to secure information and prevent unauthorized access or disclosure. Our cookie policy applies to cookies that are collected from our website only, and not third party sites. Please refer to their policies. You can find more information about cookies here: http://www.allaboutcookies.org/



European Union Data Subjects

The General Data Privacy Regulation (“GDPR”) provides additional rights to any EU data subjects. These rights came into effect on May 25, 2018. If you do reside in the European Economic Area, you have the following rights in terms of data that CDG is the Data Controller:


Request

You have the right to request access to Personal Data that we hold about you, at any time. Depending on the processing of such request, a fee may be applied that is specified by law. All requests will be responded to within a reasonable time frame. If CDG is not the Data Controller, we will direct you to the client acting as the Data Controller. Any declined requests from CDG will be accompanied with a written notice as to the reason of the refusal.

Delete

You have the right to ask us to remove any Personal Data that we may have about you. All removal will be to the guidelines of the law, and where in some cases data may not be deleted due to applicable law.

Update

You have the right to ask us to update and correct any Personal Data that we may hold about you. CDG will take all steps necessary to reasonable correct information to be up to date and accurate.

Complaint

You have the right to file a compliant with your local Data Protection Authority about the processing of your Personal Data done by CDG.


If you are a EU data Subject and believe that CDG is processing your Personal Data and would like to exercise any of the above rights, please send an email to privacy@coastaldigitalgroup.com and we will respond to all requests within a reasonable time frame.



Other Data Information

CDG’s websites and platform are not intended for children under 15 years of age, and must be older than that age to use the platform. If the age requirement is not met, please do not provide Personal Data or use the platform. We do not knowingly collect Personal Data from any child under 15 years of age. For the removal of data, please contact us at privacy@coastaldigitalgroup.com

Our website and digital advertisements on served through the Platform on behalf of CDG’s clients, may link to external websites. We encourage you to review the privacy policy of such websites as is may be different from ours. CDG will assume no liability or responsibility for the information collected and disclosed from any external website. The Neptune Platform and our Website may also use social media features, operated by such third parties as Facebook, Instagram, Twitter, etc. If you are signed in at the time of using the features, than such third-party might be able to link information from your use of these features. These features are governed by the privacy policy of the third-party providing the feature, which is why we encourage you to read the providers privacy policy.



Contact Information

If you have any questions regarding the Privacy Policy, cookie uses, or policies on collection and disclosure of Personal Data, please contact us at:

Data Controller
Coastal Digital Group Inc.
12 Venice Drive
Toronto, Ontario, M6L2Z4
privacy@coastaldigitalgroup.com

For all EU data subjects, if you are not satisfied with our response or believe we are not following the law while processing your Personal Data, you have the right to lodge a complaint to a supervisory authority in the Member State of your place of work, alleged infringement or residence.



Changes to the Privacy Policy

We reserve the right to modify this policy from time to time. Please review it frequently. Any updated versions will be posted here, along with the effective “Last Updated” date. It is for that reason we recommend reading the privacy policy on a regular basis.