Lupon Media provides our customers (“Publishers” of websites or content creators) with the technical ability to generate revenue through digital advertising (referred to as “Interest-based Advertising”) and/or affiliate marketing, to you, the “Reader.”
As a data broker, we also sell data to advertisers, brands, retailers, and other businesses who use the data to support their own commercial purposes.
Our products are used on websites and other internet-connected services (such as smart TV’s and mobile devices). A more in depth description of our services can be found at our https://luponmedia.com/publishers site.
The Lupon Media Services that collect information from users are:
Lupon Media is a data broker. As a data broker we may share your information with other parties. For more information for California Residents, see “Personal Information we sell to third parties”, located under “Information for California Consumers” in the “Country and State Specific Disclosures” section, below. Other Lupon Media Services collect information about Publishers as described in our Publisher Agreements.
Lupon Media Services contain links to websites or content operated and maintained by third parties over which we have no control. We encourage review of the privacy policies of such third-party websites and content before disclosing any information to them.
Our goal is to be transparent about our business by describing our technology and services in simple terms. If unsure about any of the information provided, please reach out to [email protected].
Lupon Media supports industry self-regulation and endorses industry best practices and self-regulatory standards.
Lupon Media follows and adheres to the industry Self-Regulatory Principles of the Digital Advertising Alliance (“DAA”).
Lupon Media also adheres to the Interactive Advertising Bureau (“IAB”) Code of Conduct, and actively participates in the IAB Europe Transparency & Consent Framework (TCF 2.0). We comply with IAB’s Specifications and Policies under vendor identification number 13.
The information we collect allows us to see browsing habits at an individual level, but we do not attempt to identify the exact individual who is browsing. Read more about the types of information used in Interest-Based Advertising, as well as what to expect when visiting our Site.
Lupon Media Services and Site collects both Personal Information and Non-Personal Information. Lupon Media does not collect personally identifiable information (“PII”) about Readers such as names, email addresses, physical addresses, or phone numbers, unless provided to us through the Site when requesting materials or information from us.
The following provides more detail into the types of Personal Information we collect (and in some instances purchase from partners) and use in conjunction with the Lupon Media Services and Site:
A randomly generated identifier (created by Lupon Media) that is stored on a browser and allows us to understand Reader browsing behavior, without knowing the exact identity of the individual. Also known as a third-party cookie.
An identifier typically constructed of a Reader’s hashed and salted email address that will recognize user identity across different platforms. The Universal ID is created by an identity provider, rather than each individual third party, as in the case of cookies, and is also known as first-party data.
Device information can include your browser agent, browser type, operating system, device type, use of ad blocking tools, and information about the possible relationships among different browsers and devices.
Hashing is a way of making a piece of data, like an email address, into a hexadecimal string so that it is no longer readable. Each email address has its own unique hexadecimal string that remains consistent no matter where the email address is used.
An Internet Protocol address (IP address) is a numerical label assigned by an Internet Service Provider (ISP) to each device connected to a computer network that allows the device to communicate on the Internet. Most IP addresses are dynamic, meaning they change every time the device is restarted.
General location information
Using your IP address and third-party services, we may collect general location information such as your country, city or state. Collecting this information not only supports our services, but helps us to understand your data rights.
Mobile advertising ID
In mobile apps, we use identifiers provided by the mobile device’s operating system that can be reset by users. Typical advertising IDs are AdID (Android) and IDFA (Apple). Mobile advertising IDs allow developers and marketers to track activity associated with a specific device for advertising purposes. They’re also used to enhance serving and targeting capabilities.
Personally Identifiable Information (“PII”)
PII such as first/last name and email address may be required for some inquiries through the Site. Lupon Media will only collect PII you voluntarily provide.
Precise location information
Precise location information may include, for example, data obtained from cell tower or Wi-Fi triangulation techniques, or latitude-longitude coordinates obtained through GPS technology, if such data is sufficiently precise to locate a specific device.
Cookies are widely used in digital advertising to gather information about our website and its performance. Neither us, advertisers or our advertising partners can gain personally identifiable information from these cookies.
Most web browsers will allow you to turn off cookies. To do this, look at the “help” menu on your browser. However, switching off cookies may restrict your use of the website and/or affect the way in which it performs. We should add that opting out of advertising cookies will not mean you won’t see ads, just that they won’t be tailored to you. The cookies installed on luponmedia.com are as follows:
Google Analytics User
This cookie is used by Google Analytics, a marketing tool and service provider, to identify a user for purposes of reporting and analytics on visits to Lupon Media sites.
Google Analytics User Settings
This cookie is used by Google Analytics, a marketing tool and service provider, to control the frequency of requests to the Google Analytics service.
Google Analytics User
This cookie is used by Google Analytics, a marketing tool and service provider, to identify a user for purposes of reporting and analytics on visits to Lupon Media sites.
We collect Personal Information submitted to us voluntarily, such as name and contact information. For example, when signing up to receive our newsletter, we collect your email address. When contacting us via email, we will collect the email contents.
Both session cookies (which expire once the web browser is closed) and persistent cookies (which stay on a device until deleted) are used to collect viewing and search behaviors.
The information we gather about browsing preferences and purchasing behaviors using cookies helps us provide Lupon Media Services to our Publishers, which in turn provides meaningful Interest-based Advertising to Readers.
We set cookies (where allowed) at the first visit to any of the Publisher sites that deploy Lupon Media Services. If our cookie is already set on a browser, we recognize a returning Reader and log data using the existing cookie. Readers have the option to use tools provided by browsers to decline to receive cookies or to clear cookies, which will result in us treating the Reader as a new visitor when encountering Lupon Media Services. However, in order to stop Interest-based Advertising by Lupon Media, individuals must explicitly opt-out as described in the “How to Opt-Out” section.
Lupon Media Services may use both session cookies (which expire once the web browser is closed) and persistent cookies (which stay on a device until deleted).
Some of our business partners (for example, Google Analytics) may set or use their own cookies on our Publisher websites or through Lupon Media Services where Lupon Media has no access to or control over these cookies.
We collect Publisher payment information from those who purchase Lupon Media Services. Lupon Media provides a third-party service to manage revenue payments to Publishers. This service also provides transactional information to Lupon Media for financial reporting purposes.
We may also collect and categorize information about the content on Publisher pages integrated with Lupon Media Services and link this information to Personal Information collected through the delivery of Lupon Media Services. A Publisher may also choose to provide us with log-in credentials for accounts with third-party services such as online advertising providers, in order for Lupon Media to provide services such as reporting and analytics, based on information from those third-party services.
Publishers may choose not to provide us with certain Personal Information, but this may limit the features of the Lupon Media Services available for use.
Web pixels are electronic images that may be used on Publisher website(s) or in emails sent in Publisher campaigns. We use tracking pixels to deliver cookies, count visits, understand usage and effectiveness of offers.
We may receive Non-Personal Information and/or Personal Information about you from other sources and combine it with the information that we collect through Lupon Media Services, or Site. Sources may include information conveyed to us by telephone or fax, information that we receive from third-party data providers, or information provided to us by third parties through the Lupon Media Publisher network.
We use Personal- and Non-Personal Information collected through Lupon Media Services and Site to support our commercial interests (Interest-based Advertising, affiliate marketing, and data brokerage), internal business operations (such as improving the Services, fraud prevention and security), and business intelligence.
Commercial interests are activities that allow Lupon Media and/or our customers and business partners (such partners include data services and data resellers) to earn revenue.
* 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.
We may also use political-affiliation segments that are inferred from data we collect but are not derived from specific voter registration information.
A list of the health-related and/or political-affiliation segments that may be used by our platform may be viewed on our Audience Segments page.
Internal business operations are activities that allow us to meet obligations to Publishers, Readers, and third-party partners (including regulatory bodies). Internal business operations do not directly benefit any one person or entity.
Business intelligence allows us to analyze and report on the performance of Lupon Media Services and Site, as that performance relates to Publisher campaigns.
We may collect Non-Personal Information through Lupon Media Services or we may create Non-Personal Information from Personal Information by removing identifying information (such as email address or device identifiers).
We may use Non-Personal Information for a variety of purposes to operate and improve the Lupon Media Services, such as testing our IT systems, analyzing usage patterns, market research, data analysis, and developing new products.
We may also use Non-Personal Information on Readers’ activities collected from Publisher websites (such as page views, use of ad blocking technology, and search queries) to provide aggregate information to Publishers so that they can improve their offerings.
We may use and disclose Non-Personal Information for any purpose in our discretion, to the extent permitted under applicable law. If we are required to treat Non-Personal Information as Personal Information under applicable law, then we may use or disclose it for all the purposes for which we use and disclose Personal Information.
Lupon Media shares the Personal Information collected through our Services and Site with the following:
Lupon Media supports various opt-out mechanisms, where each option provides different results related to targeted advertising. While using these mechanisms may prevent Interest-based Advertising or the sale of your Personal Information, there are no mechanisms for preventing advertising altogether.
Readers can choose to opt out of Lupon Media’s Interest-based Advertising activities on their browser(s) or device(s). For more information on how to opt-out of the sale of personal information, please see the section, “Exercising California Consumer Rights” located under “Information for California Consumers” in the “Country and State Specific Disclosures” section, below or our Privacy Center.
Your opt-out choice will apply to the browser or device where you make the choice. This means that Lupon Media will not deliver Interest-based Advertising to this browser or device and we will not otherwise use or transfer data collected on this browser or device for Interest-based Advertising.
Readers who wish to opt out of Lupon Media’s collection, use, or transfer of such data from a browser for Interest-based Advertising purposes can visit https://www.aboutads.info/ to learn more about Interest-based Advertising and to exercise opt-out choice with respect to Lupon Media and other companies participating in the DAA’s self-regulatory program.
Readers who wish to opt-out of Lupon Media’s collection, use, or transfer of such data from apps on a mobile device for Interest-based Advertising purposes can download the DAA’s AppChoices app.
When using DAA’s opt-out tools, choice will be effective only on the browser or device where choice has been exercised. If using a different device or browser, the opt-out choice(s) will need to be renewed for the new device or browser. Our opt-out tool for browsers is cookie-based, so that an opt-out choice can only be honored if a browser is set to accept third-party cookies. If the opt-out cookie is deleted, then the opt-out choice(s) must be renewed.
Opting out also will not stop advertising from appearing in a browser. After opting-out, Readers may receive advertising from Lupon Media Services when visiting websites of a Publisher who uses our Services, but that advertising will not be interest-based. After opting out of Lupon Media’s Interest-based Advertising, Readers may also continue to receive Interest-based Advertising through other companies.
Lupon Media Services are designed to respect ‘Do Not Track’ (or “DNT”) signals from your browser, such as ad blockers.
Unsubscribe instructions will accompany each promotional email we send. Alternatively, contact us directly to change promotional email preferences at [email protected].
Regardless of your promotional communication preferences, we will send Publishers messages related to our business relationship or transactions.
For any questions regarding a Lupon Media Publisher account, please contact [email protected].
Lupon Media does not knowingly collect personal information from or direct Lupon Media Services to children under the age of 16.
We will keep Publishers’ Personal Information according to the terms and conditions of our business relationship. This includes maintaining Publishers’ Personal Information after our relationship ends to protect ourselves from legal claims, to comply with law, or to administer our business.
Personal Information collected about Readers through Lupon Media Services is generally retained for a maximum of eighteen months. However, laws, legal claims or other particular circumstances may require us to keep certain Personal Information longer.
We may retain Non-Personal Information for our business purposes, at our discretion or as permitted by law.
Lupon Media has put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the Personal Information we collect.
If located in the European Union, Switzerland, Norway, Lichetenstein, Iceland, or the United Kingdom (the “European and UK Countries”), individuals have certain rights and protections under applicable law regarding the processing of Personal Information.
If located in one of the European and UK Countries, Lupon Media may act as a “controller” as defined under applicable law when processing Personal Information. Lupon Media may also act as a “processor” as defined under applicable law to the extent that we process Personal Information on behalf of and at the instruction of another party, for example a Lupon Media client.
Lupon Media’s legal basis for processing Personal Information depends upon the specific context in which it is collected or used. We rely on data subject consent (as defined under applicable law) to process Personal Information for Interest-Based Advertising, which we require Publishers using Lupon Media Services to obtain on our behalf. In some cases, we may rely on our legitimate interests to collect and use Personal Information, except where our interests are overridden by data-protection interests or fundamental rights and freedoms. For example, we will process Personal Information collected from Interest-Based Advertising in order to improve the Lupon Media Services for our Publishers. Additionally, we may have a legal obligation to process Personal Information (such as for fraud prevention).
Individuals may be entitled to exercise certain data subject rights available under applicable laws. These rights may include the right to request access to Personal Information we hold. Individuals may also have the right to object to, or request that we restrict, processing of Personal Information, such as profiling we perform for the purposes of direct marketing and interest-based advertising. Individuals may also have the right to ask that your Personal Information be corrected, erased, or transferred to another party. Where we have asked for consent to process data, consent may be withdrawn.
Anyone afforded any of these rights may exercise them by contacting [email protected].
These rights may be limited in some situations–for example, where we can demonstrate that we have a legal requirement to process data. In some instances, this may mean that we are able to retain data even if consent is withdrawn. In other instances, we may provide the requested information with some portions redacted in order to adhere to obligations of confidentiality to others.
Where we require Personal Information to comply with legal or contractual obligations, provision of Personal Information is mandatory; in all other cases, provision of requested Personal Information is optional.
Lupon Media is a global company headquartered in UAE, Fujairah, with data centers located in Europe and the United States. By visiting Publisher’s sites who are using Lupon Media Services, Personal Information may be transferred to, stored, and processed by us, our affiliates, and by those third parties with whom we may share your information, some of which are located outside of the European and UK Countries.
These countries (including the United States) may have data protection or other laws that differ from those in European and UK Countries. We ensure that where Lupon Media or third-party service providers receive Personal Information outside of the European and UK Countries, appropriate safeguards are in place under European and UK data protection legislation.
Lupon Media may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Lupon Media supports and encourages our clients to use the IAB Europe Transparency and Consent Framework (the “IAB Industry Framework”) to provide data subjects with dynamic transparency into and choice about the various vendors our clients use to serve ads, including Lupon Media Services. When visiting a website, the IAB Industry Framework is designed to allow a Publisher the means to choose which registered vendors they wish to allow to access a device and process Personal Information, and provide dynamic transparency and choice about each of these vendors (either an opportunity for an individual to consent to the vendor or opt out of data processing by the vendor, depending on that vendor’s legal basis and processing activities).
Individuals located in one of the European and UK Countries who have questions or concerns about how we process Personal Information may contact our Data Protection Officer at [email protected]. If we are not able to resolve the issue, individuals have the right to lodge a complaint with their local data privacy authority. For contact details of local Data Protection Authorities, please visit the European Data Protection Board member list.
IT Governance Europe Limited acts as our EU representative. If you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR), or have any queries in relation to your rights or general privacy matters, please email [email protected] Please ensure to include our company name (“Lupon Media”) in any correspondence.
This section contains disclosures for Readers required by the California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.). This section applies to the collection, use, and disclosure of “personal information” collected from California “consumers” (as those terms are defined by the CCPA) that are subject to the CCPA. (Publisher personal information is not “sold” under the CCPA and is otherwise exempt from the CCPA at this time.)
Personal Information we collect about consumers, and from Publishers, service providers, affiliates not under the Lupon Media brand, or consumer data resellers:
Personal information we disclose for business purposes in performing Lupon Media Services:
We disclose each category of personal information identified above to the following categories of recipients: service providers; affiliates not under the Lupon Media brand; and advertising networks and other partners (such as Demand Side Platforms (DSPs) who buy ad space from Publishers).
Personal Information we sell to third parties:
We sell each category of personal information identified above to the following categories of recipients: advertising/marketing companies; advertising networks; marketing data companies; data analytics providers; social networks; consumer data resellers; and publishing product companies.
California consumers may opt-out of the sale of their personal information at any time. Please see “Exercising California Consumer Rights” below for more information.
Lupon Media does not knowingly sell the personal information of minors under 16 years of age.
California consumers have certain rights with respect to the personal information collected by businesses. California consumers may exercise the following rights regarding personal information, subject to certain exceptions and limitations:
To exercise any of the above rights, please contact us [email protected] providing the requested information.
We may require additional information to verify a consumer’s identity or understand the scope of the request, depending on how we are contacted. We will only ask for information needed to verify a consumer’s identity, such as a different email address, mobile identifier, or cookie ID.
Consumers may designate an authorized agent to exercise California data rights under the CCPA on your behalf by (i) verifying the consumer’s identity and (ii) providing evidence of the consumer’s written permission authorizing an agent to make a request on their behalf.
Lupon Media will respond in good faith to all privacy inquiries but may not be able to provide complete information if the request requires Lupon Media to release confidential information of third parties, or otherwise imposes an undue burden or expense.
Lupon Media - U.A.E Headquarters
Consolidated Website and Service Privacy Policies, reordered sections, and updated internal links.
Information We Collect
Added ‘Universal ID’ to the list of Personal Information types