Publisher Policy

Below sets forth Upwave, Inc.’s (the “Company”) policy with respect to information collected from all third party publishers (each a “Publisher”) when executing Services for mutual clients (“Clients”). Capitalized terms not defined herein shall have the meaning ascribed to such terms in the Company’s Privacy Policy available here. Publisher Data (“Publisher Data”) refers to all first party Publisher data, including cookies and Device IDs that are shared with, pushed to, or otherwise utilized by Company in connection with Services provided to Clients. Publisher Data shall not include any survey results (“Survey Results”) generated by Company utilizing Publisher Data or Survey Results generated to complete Services (including any Services retargeting Publisher users), and Company shall retain all right, title and interest in and to such Survey Results.

Data Disclosure

Other than as set forth hereunder, Company will not sell, transfer, or distribute Publisher Data unless expressly clarified to Publisher in writing in order to execute Services. Notwithstanding the foregoing, Publisher Data may be compiled and analyzed on an aggregated basis, and Company may share this aggregated data with is affiliates, agents and business partners. Company may disclose Publisher Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Company, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
Publisher Data will be anonymized when disclosed to all third parties except Clients in accordance with executing Services.
Publishers shall retain all ownership rights, title and interest in and to their Publisher Data.
Company does not collect any Personally Identifiable Information from Publisher Data or Publisher users. Publisher users’ IP addresses are used to determine approximate geographic location only and are never shared with 3rd parties. Company does not run surveys across our Network that ask for any Personally Identifiable Information via a survey question. Company is not responsible for any special handling of Personally Identifiable Information that Publisher users submit unsolicited via a “free response” survey question on the Network.
Data Security

Company takes reasonable steps, including the implementation of organizational, technical, and administrative measures to protect Publisher Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet transmission is ever fully secure or error free. Publisher should keep this in mind when disclosing any Publisher Data to Company via the Internet.