California privacy notice
This section applies to California residents and supplements the other information on this page. Terms such as personal information, consumer, business, service provider, contractor, sell, share and sensitive personal information have the meanings given to them under the California Consumer Privacy Act, as amended.
More information about California consumer rights is available from the California Department of Justice CCPA page and CalPrivacy.
Categories of personal information
Depending on the relationship, product and service involved, Menarlo may collect or process the following categories of personal information:
| CCPA category | Examples relevant to Menarlo |
|---|---|
| Identifiers | Name, email address, IP address, cookie ID, mobile advertising ID, device ID, pseudonymous ID and hashed identifier |
| Customer-record information | Business contact information, account information and payment-related records |
| Protected classifications | Attributes included in a lawfully sourced dataset where permitted and subject to appropriate controls |
| Commercial information | Purchase, transaction, product-interest or intent information |
| Internet or electronic activity | Website, application, content, advertising and interaction data |
| Geolocation data | Broad, approximate or IP-derived location and, only where specifically permitted, more precise location |
| Professional information | Employer, job title, business role and professional profile |
| Inferences | Audience classifications, interests, preferences, characteristics and predicted behaviour |
| Sensitive personal information | Information treated as sensitive under California law, where lawfully processed and subject to applicable restrictions |
| Communications | Enquiries, support requests, correspondence and meeting information |
Menarlo does not collect every category in every context.
Sources
These categories may be obtained from:
- Consumers directly;
- Customers and business partners;
- Data owners and suppliers;
- Publishers, retailers, media owners and application providers;
- Advertising and technology platforms;
- Service providers;
- Publicly available business sources; and
- Online interactions and devices.
Business and commercial purposes
We may use these categories to:
- Provide, manage and improve services;
- Communicate with customers and partners;
- Authenticate users and protect systems;
- Onboard and evaluate data sources;
- Develop, distribute and maintain data products;
- Provide audience insights, enrichment, activation and measurement;
- Perform analytics and quality assurance;
- Comply with privacy choices;
- Detect fraud and misuse;
- Administer contracts and payments;
- Comply with legal obligations; and
- Support corporate transactions.
Disclosure for business purposes
We may disclose relevant categories of personal information to service providers, contractors, group companies, technology partners, professional advisers, platforms and other organisations for the business purposes described above.
Sale and sharing
California law defines sale and sharing broadly. A transfer may qualify even where no money is exchanged.
Depending on the product, service and role of the relevant Menarlo entity, identifiers, internet activity, commercial information, approximate location and inferences may be made available to platforms, marketplaces, agencies, brands or technology partners in a manner that constitutes a sale or sharing under California law.
California residents have the right to direct us not to sell or share their personal information.
Menarlo also recognises qualifying browser-based opt-out preference signals, including Global Privacy Control, where required by law. Where technically feasible, our website will provide an indication that the signal has been recognised.
An opt-out applies to the browser, device or identifier through which the preference was communicated unless the request is associated with a verified account or additional identifiers.
Sensitive personal information
Where Menarlo processes sensitive personal information, we limit its collection, use, disclosure and retention to purposes that are reasonably necessary and proportionate, or provide the right to limit its use and disclosure where required.
California consumer rights
Subject to applicable exceptions, California residents may have the right to:
- Know the categories of personal information collected;
- Know the categories of sources;
- Know the purposes for collection, use, sale or sharing;
- Know the categories of third parties to whom information is disclosed;
- Access specific pieces of personal information;
- Correct inaccurate personal information;
- Delete personal information;
- Opt out of sale or sharing;
- Limit certain uses and disclosures of sensitive personal information;
- Receive information in a portable format; and
- Receive equal service and pricing without retaliation for exercising a privacy right.
How to exercise California rights
A request may be submitted using:
Or email: privacy@menarlo.com
We may need to verify the request. The information required for verification will depend on the request and the information involved.
Because many advertising products use pseudonymous identifiers, we may ask for information that enables us to locate the relevant record, such as:
- A cookie identifier;
- A mobile advertising identifier;
- A device or platform identifier;
- The email address used in an interaction;
- A hashed version of an identifier; or
- Other information reasonably required to match the request.
We will use verification information only for handling the request, preventing fraud and maintaining the records required to demonstrate compliance.
An authorised agent may submit a request on behalf of a California resident. We may request proof of the agent’s authority and may contact the resident directly where permitted.
California data-broker requests
California residents may use the California Delete Request and Opt-Out Platform, known as DROP, to submit a deletion request to registered data brokers.
Where the relevant Menarlo entity is registered and a request matches information held by that entity, the request will be processed in accordance with the California Delete Act and applicable regulations, subject to lawful exemptions.
Information for registered data brokers is available on the official DROP for data brokers page.
Privacy rights in other US states
Residents of certain US states may have additional rights under their state’s privacy law.
Depending on the state and applicable exemptions, these may include rights to:
- Access personal data;
- Confirm whether personal data is being processed;
- Correct inaccuracies;
- Request deletion;
- Obtain a portable copy;
- Opt out of targeted advertising;
- Opt out of the sale of personal data;
- Opt out of profiling in furtherance of decisions producing legal or similarly significant effects; and
- Appeal a refusal to act on a request.
Requests can be submitted using our Privacy Request Form.
Where an appeal right applies, instructions for appealing our response will be provided with the decision.