Last Updated: May 1, 2016
Attn: Privacy Officer
229 West 28th Street
New York, NY 1001
33Across, Inc. and its corporate group affiliates (collectively, “33Across”) provides online publishers and marketers (our “Clients”) with a suite of products and technologies (“Products”, or “Technology”) that provide insights into how content is consumed and shared on their web sites, monetize this content, and drive incremental traffic.
33Across provides Products that enable Clients to gain insights into how their content is being consumed and shared by end-users. Using browser cookie technology, end-user data is collected across multiple websites to provide these insights and consists of behavioral information regarding the web pages they visit and/or the actions they take on websites, such as copying or sharing content, clicking on hyperlinks or advertising on the page, or signing up for products or services offered by our Clients. We use the collected information to target and display advertisements that may be of interest to users.
Some of our Products insert advertising from our partners on our Client websites. We record information that an ad was requested or shown, and any user interactions with the ad or the page where the ad appears. This information is used for analysis, reporting and troubleshooting.
We categorize website visitors with similar characteristics or interests into non-personally identifiable data segments and offer these segments to our Clients, improving their ability to deliver more relevant advertising or analytics. For example, if a person expresses an interest in comedy films by visiting a page with related content, our Technology would help our Clients characterize other people who are likely to enjoy comedy films based on similarities in browsing or sharing behavior.
We do not knowingly use information that comes from what we consider to be sensitive health information. We may use health-related segments that are inferred from data we collect but are not derived from sensitive health data. Click here for a list of the standard health-related segments that may be used by our platform.
When we refer to Personally Identifiable Information (“PII”) in this policy, we mean any information used or intended to be used to identify a particular individual, including name, address, telephone number, email address, financial account number, and government-issued identifier. We do not collect PII through Client websites via our Technology.
33Across collects only Non-Personally Identifiable Information (“Non-PII”) from the web pages where our Clients deploy our Products. When we refer to Non-PII in this policy, we mean information that does not use a commonly recognized identifier such as name, address, email, or telephone number to identify a particular person. Non-PII includes, but is not limited to, the Internet Protocol (IP) address that your device used to connect to the internet, browser type (for example Internet Explorer or Mozilla), operating system (for example Windows or Macintosh), the URL of Client website pages or sections that you visit, the data you copied or shared, etc. Keep in mind that in certain contexts and jurisdictions, some information that we in this policy regard as Non-PII, such as IP addresses, may be regarded as “personal data” under data protection legislation in the European Union and elsewhere. We do not, however, record IP addresses for visitors to Client websites from EU countries.
We collect PII exclusively on the 33Across Websites: our main company site (33across.com) and our publisher portal (platform.33across.com), when you choose to provide it to us. For example, you may choose to provide us PII about yourself by sending us an email, by completing an online form, or by registering for a login and password for the Products we offer. We use this information only to contact you to respond to your inquiry or manage your registered account.
33Across automatically receives and records certain Non-PII from all visitors to our Websites, including your IP host address, pages viewed, browser type, the time/date of your visit to this Website, and the referring URL and your computer’s operating system. 33Across uses this Non-PII to help diagnose problems with its server, analyze trends and administer the Website. However, keep in mind that some of this Non-PII could be regarded as “personal data” under the data protection legislation in the European Union and elsewhere.
We use non-personally identifiable browser session cookies and persistent cookies in our Products and on our Website to provide, monitor, analyze, and improve our services. For more information about cookies please visit allaboutcookies.org.
We try and set cookies for first-time visitors to any of the sites that deploy our Technology or Products. If our cookie is already set on your browser, we know you are a returning visitor and log data using your existing cookie. You are always free to configure your browser to decline to receive cookies or clear your cookies, which will result in us treating you as a new visitor every time you encounter our Products on our Client websites. However, in order to stop data collection by 33Across, you have to explicitly opt-out, as described in the next section of this document.
We do not combine information collected through cookies with other PII information you may have provided to us when you registered for our Products or submitted a form through our Website.
Some of our business partners (for example, Google Analytics) or Clients may set or use their own cookies on our Website or through the Products we provide. However, we have no access to or control over these cookies. Some of our business partners may engage in cross-device mapping. In other words, our business partners may link the cookie data we gather to device identifiers concerning the same user. Our business partners may then share the cross-device mapping or other user data with us, for the purpose of personalized advertising.
We use persistent cookies to manage your opt-out status.
You may visit http://optout.33across.com to opt-out of data collection from 33Across. The 33Across Opt-out Tool is cookie-based. In order for the Tool to work on your computer, your browser must be set to accept cookies. Be advised that if you use multiple computers or browsers, you will need to repeat this process for each computer and each browser. If you buy a new computer, change web browsers or clear your 33Across cookies, you will need to perform the opt-out task again.
Opting out does not mean you will no longer receive online advertising. It does mean that 33Across will no longer collect any data associated with your activities on any of our Clients’ websites.
Additionally, 33Across is a member of the Network Advertising Initiative (NAI) and adheres with the NAI’s Self-Regulatory Principles. You may visit optout.networkadvertising.org to find out more about the NAI’s Self-Regulatory Program and to opt out of 33Across and other NAI member company advertising programs.
33Across is a participating company in the European Digital Advertising Alliance and adheres to the Interactive Advertising Bureau (IAB) Europe’s EU Framework for Online Behavioral Advertising. Learn more about online behavioral advertising, additional choices regarding the collection and use of data for online behavioral advertising, and how to file any consumer feedback or complaints with the national advertising Self-Regulatory Organization at http://www.edaa.eu and http://www.youronlinechoices.com.
You may also exercise your right to review, rectify or delete the personal information about you that is stored in our systems, or object to its processing for the purpose of personalized advertising, if such rights are conferred by applicable law. If you wish to exercise these rights, contact us, detailing the right you wish to exercise, through our address provided at the end of this policy or via email: firstname.lastname@example.org. In order to process your request, we may require additional information or corroborative documents from you, to verify or confirm your identity.
Once we complete processing your request, we will delete your information from our systems (if so requested). However, be advised that following such deletion, some information, though not accessible in the ordinary course of business, may still be retrievable from back-up copies or may still residually reside in our systems.
The security of your information is important to us. We take security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include firewalls and encryption, internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems. We restrict data access to a subset of 33Across employees, contractors and agents who need to know that information in order to operate, develop or improve our Products and services. These individuals are bound by confidentiality and data security obligations and may be subject to discipline, including termination, if they fail to meet these obligations.
No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.
We retain contact information submitted by Clients as long as they are actively registered for our Products. Data about users who contact us via our Website is retained as long as their interaction with us is active. Data about inactive Publishers or Website users may be deleted as space requires or in the normal course of business. You can request that your data be removed from our records by contacting us at email@example.com.
We retain non-personally identifiable user activity data collected through our Products for 90 days. Statistical summaries and data aggregations across many users’ activities may be kept for longer periods.
The following disclosure is made pursuant to the California Online Privacy Protection Act: When you use our Website or websites of our Clients, other parties, such as Google, may collect PII about your online activities over time and across different websites or online services.
The Website and Products are hosted in the United States. If you access the Website or Products from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of the Website or Products, you are transferring your PII and non-PII to the United States and you consent to that transfer. Additionally, you understand that your PII and non-PII may be processed in the United States. We are prepared to comply with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679 to the extent required for the conduct of our activities when the GDPR commences.
Protecting the privacy of children is very important to us. We do not knowingly collect any information from anyone under the age of 13 and no part of our Website or Products are designed specifically to attract people under the age of 13. If we are made aware that we have received any information from anyone under the age of 13, we will use reasonable efforts to remove that information from our records.
We do not rent or share your PII with non-affiliated third parties without your consent. We may, however, share your PII with trusted third party contractors who provide services for us. These third party contractors are prohibited from using the information we provide for purposes other than performing services for us.
We may share Non-PII collected on the Website or via our Technology with unaffiliated third parties. For example, we may disclose that our online advertisements offering ‘sports car’ test drives receive more clicks than those offering ‘Mini Van’ test drives.
We may disclose your information to third parties when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to, fraud and situations involving potential threats to the physical safety of any person.
Finally, in the event we are acquired by or merged with a third party entity or undergo another change of control, we reserve the right to transfer information, including any PII and non-PII, to a successor entity. You understand that we may not be able to control how your information is used in the event of such a change of control.
Attn: Privacy Officer
229 West 28th Street, 12th Fl.
New York, NY 10001
Effective date of policy: [November 15, 2017]
Chief Executive Officer & Co-Founder
Eric is the Chief Executive Officer and co-founder of 33Across, a publisher monetization and traffic platform. He's a seasoned start-up entrepreneur and a pioneer in digital advertising, with a proven track record in creating products for marketers and publishers that increase revenue and uncover actionable insights. Under his leadership, 33Across has achieved numerous accolades, such as being named the 70th fastest growing companies in America and the 7th fastest growing company in New York by Inc. Magazine in 2013. 33Across has also been an AlwaysOn Media Top 100 Company for 4 consecutive years. Prior to 33Across, Eric was the CEO of Neo@Ogilvy and Executive Director of Ogilvy Interactive North America. Under his leadership, Ogilvy Interactive's revenue grew five-fold from 2003-2007. Eric was COO of Carat Interactive and co-founder and President/COO of Lot21, the award-winning digital agency that sold to Carat in 2002. Eric holds a BA in Political Science and Philosophy from Boston University.
Chief Operating Officer
David is the Chief Operating Officer of 33Across. Prior to joining 33Across, Jacobs held several senior management roles at AOL. As senior vice president and general manager, he was responsible for the launch of AOL's Marketplace, a global supply side platform. In this role, his responsibilities included managing third-party publisher partnerships and leading operations, sales, and account services teams in North America, Europe, and Japan. Previously he led the Advertising.com Publisher Network, which was the number one network for 60 consecutive months, as measured by ComScore. He also led Advertising.com’s earliest efforts in the programmatic space, overseeing its first Real-Time Bidding (RTB) platform partnerships and integrations. David is actively involved in the advertising community, having held leadership roles in key industry trade organizations. David holds a B.S. in Business Administration from Penn State University.
Chief Revenue Officer
Miles is the chief revenue officer of 33Across, where he leads global agency and client relationships. With a proven track record to drive business performance and build highly motivated sales teams, he brings more than 15 years of extensive experience as an entrepreneur, sales executive, investor, and advisor to adtech and emerging media companies. Miles co-founded Trivu Media where he spearheaded their sales and business development efforts to Global 500 advertisers and agencies, which was then acquired by Ad Knowledge/ Adparlor where he was CRO. Previously, he held senior sales positions at publishers IDG and CNet and vice president of sales for digital video startup Tremor Media. As senior vice president of sales for DoubleVerify, Dennison helped establish the online media verification company DoubleVerify as a worldwide market leader. As CRO of BLiNQ Media, he helped grow the company and was instrumental in its sale to Gannett, Inc. He holds a BS in Communications from Southern Vermont College.
Chief Financial Officer
Raviv Shefet, a veteran in the finance field in the high tech industry, joined 33Across as the Chief Financial Officer with extensive financial experience. Prior to joining 33Across, Raviv was the Chief Financial Officer at WebCollage where he oversaw the financial and business operations functions. Upon growing WebCollage’s financial stability, he played a key role in their successful acquisition. Raviv also served as the Chief Financial Officer at Selway Partners/SCP and its portfolio companies, where he managed their finance and operations. During his tenure at Selway Partners, he lead two IPOs. Raviv earned a BA from The College of Management, Tel-Aviv and holds an MBA from Pace University.
Chief Technology Officer
Shyam is the Chief Technology Officer at 33Across, bringing over 20 years of software development and research experience and more than 12 years in engineering and technology leadership. Prior to 33Across, Shyam spent over six years at Yahoo! leading engineering teams responsible for many display advertising products and platforms, including ad servers, user data stores, Smart Ads, behavioral and contextual targeting, yield optimization, and ad inventory forecasting and management systems. Prior to Yahoo!, Shyam also held engineering management and software development roles at Tele Atlas (formerly Etak, now part of TomTom). He has patents awarded or pending in the fields of behavioral targeting and digital mapping automation and various publications. Shyam holds a BTech. in Electronics and Communications Engineering from the University of Calicut, India and an MS and a PhD in Electrical Engineering from the University of Maryland.
GM, Global Data Solutions
Paul is the GM, Global Data Solutions at 33Across, bringing over 15 years of extensive digital media and data experience. Bell joined 33Across as CRO in 2015. Prior to joining 33Across, he was vice president, head of digital sales and channel management at IXI, a division of Equifax. There, he was responsible for building and managing client relationships by helping clients improve their digital marketing tactics to build profitable brands. During his tenure, he led a sales team to consistently achieve 50 percent year-over-year revenue growth. Prior to IXI, Bell was vice president of sales and business development at Divorce360.com, where he tripled site revenue within five months. His previous positions include sales roles at Bankrate.com, Credit Suisse and Bear Stearns. Paul holds a BS in Management from University of Massachusetts- Amherst.
First Round Capital is an early-stage venture capital firm. As seed-stage investors, we often provide a company's first outside capital – and typically invest alongside angel investors. Our typical initial investment in a company is around $500,000 – but we've gone both higher and lower. We're not afraid of investing in pre-revenue companies, and we understand the challenges of launching a new product. That's why we like to take an active role in the companies we invest in. First Round Capital invests nationally and has offices in San Francisco, New York and Philadelphia.
Flybridge Capital Partners is an early-stage venture capital firm whose mission is to assist entrepreneurs in growing innovative, global companies. With $560 million under management, the firm is focused on investing in consumer, energy, healthcare and information technology markets and is led by a team with domain expertise and more than half a century of combined experience in venture capital.
Greycroft Partners is a venture capital partnership, formed to invest in promising digital media companies. It serves the founders and investors who have chosen us as their partners, and help them to build large, successful businesses. Greycroft Partners portfolio companies benefit from active, hands-on assistance in all phases of expansion, including marketing, finance, and management development. With offices in New York and Los Angeles, Greycroft Partners also leverage an extensive network of media and technology industry connections to help its investees gain visibility, build strategic relationships, and successfully bring their products to market.
Metamorphic Ventures is a venture capital fund that invests in start-up and early-stage businesses exclusively in the digital media and transaction technology sectors.These technology companies tend to be cutting edge leaders in a highly focused market. Its digital media practice is primarily directed toward online and mobile advertising technologies, analytics, and tech enabled services. Metamorphic Ventures financial technology practice is primarily based on transaction processing services. It assists our entrepreneurs in many aspects of the venture needs, often from the founding stage onward, building their company to become profitable in a capital efficient manor while realizing excellent growth potential.
Invests in passionate entrepreneurs building leading companies in life sciences and technology. Founded in 2005 as the successor to the venture capital program of JPMorgan Partners, they take a hands on, highly collaborative approach to investing, bringing to bear the team’s extensive operating and investing experience to each portfolio company. The firm is managed by a seasoned group of life sciences and technology investors who collectively possess over 140 years of investment and industry experience. In addition to their extensive investing experience, they possesses broad experience as executives, entrepreneurs, engineers, and physicians. This collective experience a powerful combination of technical, entrepreneurial, operational, and transactional expertise to help foster the development of their portfolio companies.
QED Investors actively supports high-growth businesses that use information to compete – and win. While our support is tailored to the specific needs of each portfolio company, we typically provide a combination of both capital and capability. With operationally-oriented skills that we believe are both fundamentally applicable and broadly transferable, we enjoy working closely with a small set of carefully selected companies that range in size and style. But common to all of our partnerships is a shared conviction that information plays a decisive role in the success of the company, a mutual desire for a high degree of direct engagement, and a shared enthusiasm for xperimentation and learning.
Pelion Venture Partners (formerly UV Partners) established in 1986 in Salt Lake City, Utah, is a leading early stage private equity investment group. Pelion helps entrepreneurs develop early-stage concepts into tomorrow's industry-leading Information Technology and Life Science companies. The partners possess diverse but highly complementary industry and investment backgrounds. They share a hands-on approach and work collaboratively on each portfolio company over the life of an investment thereby providing each company with a broad range of resources, experience, and knowledge.