Privacy Policy

Effective: May 25, 2018


1. Introduction

We are updating our Privacy Policy to make it easier for you to understand what information we collect, why we collect it, and how we protect it. Nothing is changing about how your information is collected or processed. We are improving our processes to safeguard your information and how we explain your options to update, export, and delete your personal information.

We are making these changes to support new data protection regulations in Europe, but our improvements will benefit all users.

At Attribution, LLC (“Attribution”), we do our best to protect your personal information. In this document we will explain why and how we collect it on our own website (“Site”), how we may collect it from our clients, and use our tracking service (“Services”) on their websites (“Customer Sites”). We will also explain your rights over your personal information, and how we store and use this information. This Privacy Policy does not govern the use, handling, or actions of any other website or company.

Please contact us at if you have any questions or concerns regarding our Privacy Policy and practices. We may modify this Privacy Policy as necessary to reflect changes in applicable laws and our privacy practices. All users, including our direct Customers and our Customer’s end users, are encouraged to periodically review our Privacy Policy and to check the effective date at the top for the most recent version. As we make changes to our Privacy Policy, we will notify you on our Site.

2. Terms of Service

Use of Attribution’s Site or Services is subject to our Terms of Service (“Terms”) found at, which is incorporated into this Privacy Policy. The use of our Site or Services acknowledges your agreement to be bound by our Terms.

3. Why We Collect Your Information

We collect information to provide services to our clients, including for direct marketing purposes and fraud prevention. The information we collect depends on your use and privacy controls. Our Services assist our clients in understanding their advertising spend and improving their marketing. We use the information we collect to enhance our products and services, improve our Site and Services administration, carry out the legitimate commercial interests of our Customers, and comply with applicable laws or law enforcement activities.

4. What Information We Collect

We collect information, including personal information, from the browsers and devices you use. The information we may collect directly from you includes unique identifiers, browser type and settings, device type and settings, connection type and settings, device operating system, network information including IP address, ISP or carrier name, geo-location, phone number, system activity, usage details, referrer URL, and other relevant information that may be captured.

We may also collect your personal information from trusted partners, including our Customers who provide your information, and security partners who provide us with information to prevent fraud. We make every effort to never receive or collect any sensitive personal information, but cannot guarantee that it has not been provided to us. Our internal policies do not include reviewing the information we’ve received to determine its categories.

If you are a Customer, you are responsible for gathering and maintaining the consent for any individual personal information that you share with us. The sharing of your end customer’s personal information must be made with their informed and unambiguous consent.

5. Collecting Your Information Through Cookies

Our Site and Services use “Cookies” and other unobtrusive technologies. Cookies are small files that are placed on your hard drive to identify you and/or your device. Other technologies may collect the browser type and language, IP address, and links clicked. By using our Site and Services, you are agreeing to the use of Cookies and other technologies for the purposes described in this policy. Visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using our Site and Services. Certain features may not function properly without the aid of cookies. The method for disabling Cookies may vary by device and browser.

Our Site and Services do not respond to browser "Do Not Track" (DNT) features that tell the sites you visit that you do not wish to be tracked. Our Customer Sites determine and respond to any DNT features of your browser.

6. Sharing Your Information

Attribution will not sell or share your personal information except as provided below.

Our Customers. Attribution collects and processes your personal information for the purposes identified above. We also merge your information into group data that is shared with our Customers to fulfill our contract. We do not aggregate or share information to third parties other than our Customers.

Acquisition. If Attribution, or substantially all of its assets, are acquired, your personal information may be transferred or acquired as part of that transaction. Any acquirer may continue to use your personal information as set forth in the Privacy Policy in effect when you provided your personal information.

As Required by Law. We reserve the right to disclose your personal information as required by law and when we believe that disclosure is necessary to enforce our policies and practices, comply with existing laws or a court order, or in response to legal process served on us.

Emergency. We also reserve the right to disclose your personal information when we believe it’s necessary to prevent imminent and serious bodily harm to a person, to prevent fraud, or to protect our rights or property.

7. Public Forums

We may offer blogs or similar public forums where you and other users of our Site and Services may communicate. The protections described in this Privacy Policy do not apply to information you provide in connection with your use of these public forums. Any information you share in a public forum is public information and you should have no expectation of privacy. It may be seen or collected by anyone, including third parties that do not adhere to our Privacy Policy. We are not responsible for the information you post publicly, or any event arising from the information you choose to publicly post or share through our Site or Services.

8. Our Processing

We process personal information you provide us directly, i.e., browsing detail, device information, etc., as a Data Controller, and the information we receive from our clients as a Data Processor.

9. Protecting Your Information

All data collected through our Site and Services are stored at Amazon Web Services. We use data processing agreements to govern the processing and security of your information.

In addition to our Amazon Web Services (“AWS”) data processing agreement for information we do not host, we have adopted reasonable administrative, physical, and technical safeguards to protect against accidental, unauthorized or unlawful access, disclosure, loss, modification, processing or use of your information. Unfortunately, no communication or storage of personal information comes with “guaranteed security”.

10. Links to Third Party Sites

Our Site and Services may contain links to other third party websites (“Other Sites”) that we do not control. You acknowledge that Attribution has no control over Other Sites, their content, or privacy practices. Accordingly, you acknowledge and agree that access to any Other Sites is at your own risk and you indemnify Attribution for any event arising from your visit.

We not responsible for the accuracy, reliability or completeness of any information, data, opinions, advice or statements made on Other Sites. We may provide these links as a convenience and do not endorse, sponsor, or recommend any Other Site, or its products and services.

Other Sites have their own privacy practices and policy independent of Attribution. We highly recommend you review these for each website you visit.

11. Children Under Age 16

Our Site and Services are not directed to, or permitted for use by, persons under the age of 16. We have no actual knowledge that personal information is collected from anyone under the age of 16. If we learn that information has been collected from a child under age 16, we will delete it promptly and without notice. If you believe that we might have any information from or about a child under 16, please contact the Privacy Officer as described below.

12. Storing Your Information

We will retain your personal information for as long as necessary to fulfill the purpose(s) for which it was collected and comply with all applicable laws. In that regard, your consent to such retention of your personally identifiable information by Attribution may remains valid after termination of our relationship. However, you may request to have your personally identifiable information deleted by contacting the Privacy Officer as described in Section 14 below.

13. Your Rights

We respect that the personal information we collect and process is yours and you may have legal rights.

When we process personal information as a Data Controller, you may have certain rights under law. Please work with our Privacy Officer if you have any questions about your rights or how to exercise them.

Your right What Attribution does to protect your rights
The right to be informed

We are updating this Privacy Policy to keep you informed of our privacy practices and your rights as we strive to be transparent about how we use your information.

The right to access

You have the right to access your personal information. Please contact our Privacy Officer if you wish to access the personal information we have about you.

The right to rectification

You have the right to request us to rectify any of your personal information that is inaccurate or incomplete. We will extend this responsibility to any third parties with whom we have shared your personal information. Please contact our Privacy Officer if you need us to rectify your personal information.           

The right to erasure

You have the right to request us to erase all of your personal information that we do not have a legal reason to continue to process and hold it. Please contact our Privacy Officer if you would like us to erase your personal information.

The right to restrict processing

You have the right to restrict how we process your personal information. However, we may have a legal reason for denying your request. This means we may be permitted to store the information, but no longer process it. If this is necessary, we may keep just enough information to make sure we are able to respect your request in the future. Please contact our Privacy Officer if you want us to restrict the processing and use of your information.

The right to data portability

You have the right to obtain and reuse your personal information for your own purposes. Please contact our Privacy Officer if you need help porting your data.

The right to object

You have the right to object to our processing of your personal information. Please contact our Privacy Officer if you wish to object.

The right to withdraw consent

If you have given us your consent to process your personal information, you have the right to withdraw your consent at any time. We will stop processing any of your information where our use is based on your consent. Please contact our Privacy Officer if you want to withdraw your consent.

The right to complain to the appropriate Data Protection Authority

If you are located in a Member State of the European Union, you have the right to complain to the appropriate Data Protection Authority if you feel that we have not responded to your request to exercise a right listed here. Please contact our Privacy Officer if you have questions about your Data Protection Authority.

14. Contacting Us

We have a Privacy Officer responsible for all matters related to privacy and your personal information. If you have any questions, comments, or complaints regarding this Privacy Policy or to exercise any of your rights listed in section 13, please contact our Privacy Officer. Our Privacy Officer's contact information is:

Attn: Privacy Officer
Attribution App
145 Corte Madera Town Center #445
Corte Madera, CA 94925


15. Changing Our Privacy Policy

This Privacy Policy is effective as of the date above. We reserve the right to make changes to this Privacy Policy from time to time. We will update the effective date posted at the top of this webpage and post an updated Privacy Policy for any changes we make. Any changes to this Privacy Policy are effective immediately after being posted. We recommend that all visitors and users of our Site and Services review this Privacy Policy page periodically to learn of any update to our privacy practices or changes to this policy. Your continued use of our Site and Services constitutes an act of acceptance of any changes to this Privacy Policy.

16. Acceptance & Terms of Use

We deem your independent decision to access and use our Site and Services an act of acceptance to this Privacy Policy and its incorporated Terms. The Terms are accessible by hyperlink at the bottom of our Site’s home page and govern your use of our Site and Services. The Terms contain important provisions disclaiming and excluding our liability regarding your use of our Site and Services, and provisions determining the applicable law and exclusive jurisdiction for the resolution of any related disputes.