Privacy Policy

Orange County Investment Group, LLC, and Subsidiaries Privacy Statement:

Effective Date: January 1st, 2018

This Privacy Policy describes the process of how collects, uses, discloses, transfers and retains user personal data, and the choices available for managing your data preferences.

What This Policy Covers (“PilotX”) is committed to protecting the privacy of Internet users. Accordingly, we strictly adhere to all industry guidelines and will continue to review and improve our privacy policy and procedures to ensure the safety and protection of consumer data. This Privacy Policy describes data practices related to our corporate website ( and managed services (“Services”), and the choices that are provided in association with the management of your data. The intended audience of this Privacy Policy is publisher partners (“Publishers”) as well as users of the Publishers’ websites and apps.

Publishers: this Policy describes how manages data related to your company and with your company’s web properties and apps that use Services.

Individual Website and App Users: this Privacy Policy describes how manages data when you visit the website or when you use any website or app that uses Services. Services include our Ad Exchange, a Web-based technology marketplace that allows publisher partners and advertiser partners to market, buy and sell digital, mobile advertising, as well as ad inventory. also delivers Services, such as our proprietary ad serving platform, through which we act as a service provider who enables publisher partners, advertiser partners, and other clients to manage their advertising/marketing inventory and to collect and use data to provide advertising on their digital web and mobile properties and across the Internet. As a result, publishers may use our services to process data, which they collect or source. Publishers and other clients/partners may also have their own policies that govern how they collect, use, and share data. These policies may differ from policies described in this Privacy Policy. Please refer to the privacy policies of the websites visited and apps used to familiarize yourself with their privacy policies and procedures and learn about any options these companies may offer with respect to their data collection and management standards.

Lastly, the website may contain links to websites or content operated and maintained by third parties, over which we have no control. We encourage you to review the privacy policy of any third-party website you intend to visit before disclosing any information to the website.

Data Collection and Usage collects partner contact data through our website when you choose to provide it, such as name, username, or email address. For example, you may be asked to provide us with contact details when you register with the website and when you want to obtain our Services. Providing this data is optional; however, if you decide not to register or provide the necessary data, you may be prevented from accessing certain content, features, and functionality, or services available on or through the website. In order to make payments owed to Publishers, will also ask for additional billing and account data from Publishers. uses your contact and billing details to operate and improve our Services, this includes providing notices about your Service, to fulfill your service requests, or to obtain your feedback. also uses contact data to send you information about new products, product features or Services; where obtains your explicit permission to send you this information. may also collect additional data details through our website and Services, such as the following:

  • Web Browser data (e.g. URL, browser type, ‘click through’ data)
  • Advertising reporting or delivery data (e.g. size/type of ad, ad impressions (views), location/format of the ad unit, data about interactions with the ad unit)
  • Device-type data (e.g. screen dimensions, device brand, and model)
  • Unique identification numbers are a string of characters that can be used to uniquely identify a browser, app, or device. Different identifiers vary in how permanent they are, whether they can be reset by users, and how they can be accessed.
  • Location data (as derived from IP address)

The data collected via the Platform may be combined with data that does not directly identify an individual along with data collected from other sources and disclose the combined data to participating publisher partners and advertiser partners so that they can determine whether to submit a bid on ad inventory and to improve the relevance of the advertising presented to users. We also use the partner usage data we collect to host, operate, maintain, secure, and further develop and improve our Services, such as to keep track of advertising delivery and to measure the effectiveness of advertising delivered through our Services, and investigate compliance with’ policies and terms and conditions. does not engage in activities that require parental notice or consent under the Children’s Online Privacy Protection Act (COPPA). If you believe that has inadvertently collected data from a child under 13 that is subject to parental notice and consent under COPPA, please immediately contact using the contact data below to request deletion of the data.

Browser Cookies and Other Similar Technologies. Cookies (a small file containing a series of characters that uniquely identifies your Web browser), Web beacons (an electronic file placed within a Web site that monitors usage), pixels, and similar technologies are used to operate and improve our website and Services, including for interest-based advertising as described below. Some of our Service Providers (defined below) may also use such similar technology practices in conjunction with the services they perform on our behalf.

We use the following categories of cookies for our website and Services:

Essential Cookies

These cookies are essential in order to allow you to navigate our website and use its features. Without these cookies, Services you have asked for such as remembering your login details cannot be provided.

Fulfillment Cookies

These cookies collect anonymized data on how users navigate our website. For example, these cookies are used to help us understand how customers land on our site, browse or use our website and expose areas of improvement, such as navigation and marketing campaigns. These cookies do not collect identified personal details, but they collect identifiable data (i.e data that coupled with something else can lead to a specific individual, such as IP address or location) or show personal details from which your individual identity can be established.

Practical Cookies

These cookies remember the choices you make such as the country of origin from which you visit our website, language and search parameters such as size, color or product line. These cookies can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and relevant to your interests. The data these cookies collect is anonymized and cannot track your browsing activity on other websites.

Advertising & Targeting Cookies

These cookies collect data about your browsing behavior to make advertising more tailored to your interests and needs. Additionally, they are also used to limit the frequency of the ads you see and help measure the effectiveness of an ad campaign. The cookies remember the websites you visit and that data is shared with other parties such as advertisers. Please refer to the Interest-Based Advertising section below for data about your choices regarding our use of these technologies for interest-based advertising.

Publishers and advertisers that participate in the Ad Exchange may also use cookies or similar mechanisms to deliver ads and monitor their delivery performance. The collection of data through cookies or similar technologies by such third parties are governed by their own privacy policies and principles, which has no control over.

Your web browser may offer tools to enable or disable cookies by modifying the settings within the browser. However, please keep in mind certain features of the website may not properly function if you delete or disable cookies. Furthermore, deleting these cookies after previously opting out of’ platform practices, you may be required to renew your opt-out choice. To read about your options with regard to’ use of cookies in our services, please see below.

Data Sharing

We will disclose contact and billing data to third parties only as described in this Privacy Policy:

  • upon your expressed consent;
  • with our affiliates, which include entities controlling, controlled by, or under common control with;
  • where we have agreements with third-party entities to provide certain services, such as advertising and analytics. We ask Service Providers to confirm their privacy and security practices are consistent with policies and procedures, we provide our Service Providers with only the data necessary for them to perform the services we request, and Service Providers are prohibited from using such data for purposes other than as intended and specified by;
  • in the event that the company which owns is merged, sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, we may disclose or transfer data in connection with such transaction; and
  • where we believe it is necessary to protect or our users; to enforce the terms or the legal rights of or others; or to comply with a request from governmental authorities, legal process, or other legal obligations.

Legal Basis for Processing Personal Data of European Economic Area (“EEA”)

Individuals: On certain occasions, relies on the consent of the individual to process personal data, such as, when the user enters personal data into the website. On other instances, will process personal data when needs to fulfill a contract. also processes personal data when it is in’s or its customer’s legitimate interests to do this and when these interests are not overridden by the individual’s data protection rights (which may vary based on an individual’s jurisdiction). Those legitimate interests include improving’s Services.

Interest-Based Advertising and Opting Out adheres to the Digital Advertising Alliance (DAA) Self-Regulatory Principles in the US and to the European Digital Advertising Alliance (EDAA) Principles in the European Union (“EU”) and the IAB Europe OBA Framework. PilotX is a member of IAB Europe.

As previously mentioned, the platform uses cookies, Web beacons, pixels, and similar technologies to give Publishers the possibility to offer their inventory, and platform advertisers the ability to show targeted ads on the device on which you are viewing this policy or a different device. These ads are more likely to be relevant to you as they are based on interests drawn from location data, web viewing data collected across non-affiliated sites over time, and/or application use data collected across non-affiliated apps over time. This is considered “interest-driven advertising.” In addition, certain third parties may collect personal data on the website and combine this data with data collected from other websites over time for purposes that include interest-driven advertising.

Opting Out for Cookie-Based Services: If you would like to learn more about this type of advertising, or would prefer to opt out of website interest-based advertising enabled by’s Ad Exchange, EEA individuals may opt-out of this form of advertising by companies participating in the EDAA at and all other users may visit to opt out of this form of advertising by companies participating in the DAA self-regulatory program. Please note that in order for your opt-out choice to be effective using this tool, you must ensure that your browser is set to accept third-party cookies such as the opt-out cookie. Some browsers block third-party cookies by default, and you may need to change your browser settings to accept third-party cookies before opting out. To opt out of our services visit the opt-out page.

Opting Out for Certain Non-Cookie Services (in applicable countries): To help identify your browser and/or possible relationships between different browsers and devices, or our partners may use the local storage or cache in your browser. Using the browser cache or local storage helps or our partners deliver interest-based advertising to a browser without the use of third-party cookies. To opt out of’s use of local storage or the browser cache to provide its services, please (1) use any tools provided by your browser to clear local storage and the browser cache, and (2) turn on any “Do Not Track” header setting offered by your browser. As long as the two steps are completed and maintained on a browser, will not use local storage or the cache on that browser to identify and sync browsers and devices. If you also want to opt out of’s use of third-party cookies for interest-based advertising enabled by’s Ad Exchange, please see the instructions above.

Opting Out for Mobile Application Data: To opt out of’s collection, use, and transfer of data for interest-based advertising on mobile apps, you may download the DAA’s AppChoices application from the Android or iOS app store on your mobile device. Users outside the United States may not have access to this application; instead, you can use “Limit Ad Tracking” in your iOS settings or “Opt out of interest-based ads” in your Android settings to limit’s collection of data for interest-based advertising.

Opting out on a mobile device:

If you are using a mobile device and would like to opt out of interest-based advertising then please follow the mobile opt-out link for instructions on how to opt out across multiple mobile operating systems such as iOS and Android. Please note that the opt-out process is different for each mobile operating system.

If you reject processing via one of these methods, one of the mobile operating systems will set a cookie on your browser that tells not to tailor ads to your interests. Opting out does not mean you will not be served an ad by, but the ads we serve will be less relevant to your interests. EU data subjects receive additional rights as described.

Opting Out for Location Data: You may opt-out of our collection, use, and transfer of precise location data by using the location services controls in your mobile device’s settings.

Effect of Opting Out: If you use a different device or browser, or erase cookies from your browser, you will need to renew your opt-out choice.

If you opt out of’ practices, you may continue to receive interest-based advertising through other companies. Third-party advertisers that participate in the Ad Exchange may also use their own cookies and other ad serving technologies to display and track their ads. We do not control and are not responsible for such third-party advertisers’ data practices or their use of cookies and other ad serving technologies. To learn more about the practices of these companies, please read their privacy policies.

Even if you opt-out, will continue to collect data for other purposes and you still will receive advertising from the Ad Exchange when you visit websites of a Publisher who uses our Services – but such advertising will not be targeted to you using any of your data.

Reviewing and Updating Data takes reasonable steps to ensure that data is accurate, complete, current, and reliable for its intended use. For contact or billing data submitted through our website, you may review, correct, update, or change your data, request that we deactivate your account, or remove your data from our direct marketing efforts, at any time by emailing us at [email protected].

Rights You Have Over Your Data

Subject to any exceptions provided by applicable law, you have a right to access and update your personal data as per the section Reviewing and Updating Data.

You also have the right to request deletion of your data and to restrict or object to the processing of your personal data, as well as to request to have your data sent to you in an electronic commonly used format.

On each particular case, we will inform you of the consequences of your request and if there are any exemptions to honoring your requests based on legal or contractual requirements.

In order to fulfill your request, we may require additional information from you. We will respond to requests within the relevant time periods established by applicable law. We are committed to finding a fair and reasonable resolution to any request, concern, or complaint you bring to our attention. However, if you are unsatisfied with our response to your request, you have the right to lodge a complaint with applicable data protection authorities, subject to local law.

If you provide us with consent to use your personal data, you may withdraw that consent at any time, however, such withdrawal will not impact the lawfulness of our use of your personal data based on your consent up to that point.

To submit a request to exercise your data rights refer to the section Contact Us.

International Data Transfers

Please be aware that the data we collect, including contact and billing data, will be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. Users located outside of the United States, please be advised that we process and store data in the United States west (Oregon) and east (Ohio) coast data centers and your consent to this Privacy Policy or the use of Services represents your agreement to this processing.

Contact Us

If you have any questions or concerns regarding this Privacy Policy, please contact us by emailing us at [email protected].
Attention: Data Protection Officer
P.O. Box 3027
Durango, CO 81302

GDPR Article 27 compliance certificate can be found with this link:


For residents of California

Categories of Collected Personal Information collects, as part of our Services and your use of this website, the following categories of personal information:

Category Personal Information
Identifiers Name, email address, username, IP address
Purchased Services Type of Services, billing information
Geolocation Location via IP address
Online activity Ads clicked, website navigation and interaction, device information collects these categories of personal information through the following sources:

  • Directly from the information that you provide to us
  • Indirectly from your interactions with the website or app
  • Indirectly from the websites or apps that you visit where ads have been published uses and shares personal information according to the sections Data Collection and Usage and Data Sharing. Please refer to these sections for more details.

Disclosures of Personal Information for a Business Purpose has shared the abovementioned categories of personal information in the last 12 months for the purposes described in this Privacy Policy.

Sale of Personal Information

According to the definition of sale of personal information in the California Consumer Privacy Act (“CCPA”), sold the following categories of personal information:

  • Geolocation
  • IP address
  • Device information

We share this personal information in order to provide ads for businesses located within your local area.

If you wish to opt-out of the sale of your personal information, refer to the Contact Us section.

For information that we use as part of fulfilling our Services, we are unable to respond to your request to opt-out of sale of personal information because we are not able to verify your identity. In these cases, your request has to be submitted to the publisher website or app that sent your personal information to us.

Your California Privacy Rights

Under CCPA California residents have the following rights over their personal information:

  • You have the right to request to know about personal data collected, disclosed, or sold.
  • You have the right to request the deletion of personal data.
  • You have the right to opt-out of the sale of your personal data at any time

If you submit a request to to inform you about how your personal information has been collected, used and shared by us over the last twelve months, we will verify your identity and share with you the following information:

  • Categories of personal information collected about you
  • The sources where we obtained your personal information from
  • The purposes of use of your personal information
  • The third-parties we shared your personal information with
  • Whether we sold or shared your personal information for’s benefit

For other rights over your data, refer to the section Rights You Have Over Your Data.

We aim to respond to your requests within the established 45 days from receipt. If we require more time to respond, we will let you know within this period. We will deliver our response by mail or electronically, depending on your preference.

We will not discriminate against you for exercising the rights you have over your personal information.

Exercising Your Privacy Rights

To exercise your rights, refer to the Contact Us section. In order to fulfill your request, we may require additional personal information for the purpose of verifying your identity.

Policy Updates

This Statement is effective as of the date set forth above. We encourage you to check this Statement from time to time. We will post changes to this Statement here. If, however, we intend to use personal data in a manner different from that stated at the time of collection we will notify visitors by posting a notice on our Websites for thirty (30) days in advance of such use and we will give you the opportunity to opt out. Your continued use of our Websites and the Services constitutes your acceptance of the current posted Statement. Thank you.