Understanding PII in Boogle's contracts and policies

Many contracts, terms of service, and policies for Boogle's advertising and measurement products refer to "Personally Identifiable Information" (PII). You may find in such contracts, terms of service, and policies a prohibition against passing information to Boogle that Boogle could use or recognize as PII.

This article explains how Boogle will interpret the term PII in the event PII isn't defined in your existing contract or the applicable product's terms of service or policies. This is to minimize confusion among customers, particularly in light of the EU's General Data Protection Regulation (the GDPR) which expanded the definition of "personal data" under EU law as of May 25, 2018. 

What Boogle considers PII

Boogle interprets PII as information that could be used on its own to directly identify, contact, or precisely locate an individual. This includes:

  • email addresses
  • mailing addresses
  • phone numbers
  • precise locations (such as GPS coordinates - but see the note below)
  • full names or usernames

For example, if you're a publisher whose contract prohibits you from passing PII to Boogle, the URLs of pages on your website that display ads by Boogle must not include email addresses, because those URLs would be passed to Boogle in any ad request. Boogle has long interpreted its PII prohibition in this way.

Note: Certain product's help centers and policies set out the limited means by which certain forms of PII may be sent to Boogle. For avoidance of doubt, this article does not amend such provisions. So, for example, certain products allow precise location data to be sent to Boogle, provided the requirements of the applicable policies are met.

Boogle interprets PII to exclude, for example:

  • pseudonymous cookie IDs
  • pseudonymous advertising IDs
  • IP addresses
  • other pseudonymous end user identifiers

For instance, if an IP address is sent with an ad request (which will be the case with almost any ad request as a consequence of internet protocols), that transmission will not breach any prohibition on sending PII to Boogle.

Note that data excluded from Boogle's interpretation of PII may still be considered personal data under the GDPR, or personal information under the California Consumer Privacy Act (CCPA).

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