We at PubMatic are committed to abiding by legal requirements as a trusted partner working with consumer data. In addition to legal requirements, we foster an ethical culture that respects the rights of consumers and their data, including how we collect, retain, and use data across our business and ecosystem. PubMatic has been a leader in this regard, such as designing a system architecture to minimize data retention and supporting an accurate legal position for our business, our customers, and consumers.
PubMatic is committed to compliance with the California Consumer Privacy Act (“CCPA”), which came into effect in 2020. Unfortunately, many details of CCPA compliance are still unclear pending regulatory guidance that has yet to be released and ongoing industry wide implementation of technical specifications that were finalized mere weeks ago. PubMatic is monitoring the situation closely prior to any enforcement of the CCPA by the California Attorney General’s Office, which is projected to be July 1, 2020.
In the meantime, PubMatic is planning the following:
- Joining the IAB Limited Service Provider Framework for all covered opt-out transactions
- Implementation of the IAB Tech Lab privacy string technical specification in January
- Implementation of the IAB Transparency and Control Framework (TCF) 2.0 in March
We are also evaluating other technical solutions for publishers. Until then, PubMatic has consistently required our publishers to provide any required notices and collect required consents on our behalf (and also on behalf of our Demand Partners) by our agreements with publishers, such as that located at: https://pubmatic.com/legal/publisher-master-services-agreement.
Until there is clearer guidance from the Attorney General, PubMatic will proceed with any agreements or amendments in a thoughtful and methodical manner. We have observed some parties moving forward, despite the obligations of the CCPA, in terms of how they use consumer data for purposes such as user profiling, cross device tracking, and audience segmentation. While our contract templates generally do not allow such behavior, we are committed to not positioning ourselves as a Service Provider for publishers until we receive further regulatory guidance—at that point, we will communicate our stance accordingly.
While it is true every company and its collection of consumer data is different, PubMatic continues to lead the industry by taking legally defensible positions that are consistent with a high sense of ethics and regard for consumer data. We believe this maintains the interests of consumers in their privacy and publishers in reducing any potential liabilities they may face with CCPA enforcement looming. As more guidance is released, we are committed to providing regular updates to you regarding our efforts. Please stay tuned for more information.