Last Updated: October 2017
For guidance on how you can opt-out of the delivery of advertisements which are based on your information / browsing preferences, please see the section headed “Opting Out and Your Privacy Rights” below.
Our commitment to privacy
Introduction to dataxu
Advertising supports free content and experiences we all love on the web, social media platforms, connected television platforms and on Internet-enabled mobile devices such as smartphones and tablets. dataxu’s goal is to make advertising more effective by helping to display content that may be of interest to you. Relevant advertising is less annoying and assists the services that depend on advertising because advertisers pay more for effective content.
To deliver relevant advertising to you, we may collect information about your activity across multiple third-party websites or mobile applications. We may use this information to predict the types of ads that may interest you and to display advertising to you based on that information (“Interest-Based Advertising”). For example, if you visit multiple websites that feature articles about travel or you use a travel app, we may display travel-related ads to you on another website or app.
To learn more about Interest-Based Advertising and your choices with respect to it, please please visit www.aboutads.info/consumers, https://www.networkadvertising.org/understanding-online-advertising/ and http://www.youronlinechoices.eu/.
PART II. INFORMATION COLLECTION AND USE
What information do we collect via the Website?
We do not collect any information that enables us to determine your actual identity (“Personal Information“) before, during or after your visit to our Website, other than Personal Information you voluntarily supply to us (e.g. by submitting information on our “Contact Us” page or leaving a comment and your name on our blog).
What information do we collect via the Platform?
dataxu is committed to respecting your privacy in the provision of our Platform. In particular, dataxu is a member of the Network Advertising Initiative (“NAI“) and complies with the 2015 NAI Code of Conduct and 2015 NAI Mobile Application Code.
dataxu also adheres to the Digital Advertising Alliance’s (“DAA“) Self-Regulatory Principles for Online Behavioral Advertising and related DAA guidance, as well as the European Interactive Digital Advertising Alliance’s (“EDAA“) principles.
dataxu does not collect health information or create data segments that are based upon sensitive information and we adhere to the codes and principles of the NAI, DAA and EDAA with respect to such activities. Outside of the European Economic Area, platform users may use general health-related segments which do not contain sensitive health data. Click here for a list of the standard health-related segments provided by third-party data providers.
We do not collect Personal Information such as your name, address, phone number, e-mail address, Social Security Number, credit card information, insurance plan numbers, financial account numbers or health related information. We do not link or combine Personal Information with Behavioral Information.
We appreciate that, in certain jurisdictions, an IP address may be considered Personal Information. As such, we take steps to ensure that the IP addresses which we process do not identify you.
What information do our customers / partners collect via the Platform?
Sometimes our customers include their own (or their partners’) pixels or similar technologies within advertisements that dataxu serves to websites. This is in order for our customers to set and read their own cookies (which are not subject to the control of dataxu).
dataxu is not responsible for and cannot control the data collection and use practices of its customers. You should read the privacy policies of the websites you visit and the online services and interactive ads that you use in order to understand the type of information companies collect and how they use that data.
How do we use Behavioral Information collected via the Platform?
We use Behavioral Information collected via the Platform for a variety of purposes, including to:
- deliver Interest-Based Advertising to websites and mobile applications on behalf of advertisers;
- enable our customers to determine which advertisement may be suitable to be delivered to you;
- to monitor the success of and manage advertising campaigns; and
- compile statistics, create reporting and analytics – all of which are done in the aggregate and without identifying you.
With whom do we share Behavioral Information collected via the Platform?
We may share and disclose Behavioral Information in the following circumstances:
- Customers and customers’ partners – we may share Behavioral Information with our customers and customers’ partners for lawful advertising purposes;
- Vendors, consultants and other service providers – we may share Behavioral Information with third party vendors, consultants and other service providers who are working on our or our customers’ behalf and require access to such information to undertake that work e.g. to provide data storage and processing services;
- Compliance with laws – we may disclose Behavioral Information to a third party where we are legally required to do so in order to comply with any applicable law, regulation, legal process or government request, including to meet national security or law enforcement requirements;
- Vital interests and legal rights – we may disclose Behavioral Information where we believe it necessary in order to protect the vital interests of any person, or to exercise, establish or defend our legal rights; and
- Business transfers – we may share or transfer Behavioral Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
PART III. WHAT TECHNOLOGIES DO WE DEPLOY TO COLLECT AND USE BEHAVIORAL INFORMATION?
We use a variety of technologies on our Website and our Platform including cookies, pixel tags and scripts to collect and use Behavioral Information.
dataxu cookies may be served from any of the following domains: dataxu.net, us.dataxu.net, www.w55c.net, cdn.w55c.net, tags.w55c.net, cti.w55c.net, cts.w55c.net, ads.w55c.net, and i.w55c.net. For more information on our operation of these domains, click https://www.w55c.net/.
Pixel tags are small, invisible images on a webpage or other document. Pixel tags allow the operator of the webpage or other document, or a third party who serves the pixel tag, to set, read and modify cookies.
Our pixel tags allow dataxu cookies to be set, read and modified when you visit the websites of our partners. Our pixel tags also allow our partners to better understand how you interact with their websites by observing which pages on their websites are visited.
Server to server technology with third parties
We may synchronize Behavioral Information with the behavioral information of third parties (including cross-device identifiers as described below). We do not control the privacy practices of these third parties.
Cross-device and cross-app technology
We and our customers may use technology that establishes deterministic or statistical connections among related devices (such as smartphones, tablets, and computers) to deliver more relevant advertising to you and for advertising analytics and reporting purposes. For example, dataxu or its partners may match your devices if you log into the same online service on multiple devices or web browsers, or if your devices share similar attributes that support an inference that they are used by the same person or household. This means that information about your use of websites or applications on your current device may be combined with information from your other devices. This allows, for example, ads you see on your tablet to be based on activities you engaged in on your smartphone.
We may partner with third parties to provide such cross-device technology to our customers, and we may share anonymous identifiers (such as cookies or your mobile device’s IDFA or Google adID) with those third parties to make connections among related devices. We may also use your device’s IP address to infer connections among related devices within the same household. To opt out of dataxu’s use of such technologies for each web browser and on each of your devices, please follow the instructions for Opting Out in both web browsers and mobile applications, as described in the Opting Out section below.
We and our customers may collect information about your activity across multiple unaffiliated third-party mobile applications. We may share this information with our customers to help them predict the types of ads that may interest you and to display advertising to you based on that information. For example, if you use a travel app, we or our customers may display travel-related ads to you on another app. We or our customers may combine this information with a mobile advertising identifier (such as your mobile device’s IDFA or Google adID), and we may retain it for up to 13 months, as described in the Security and Storage section below. If you would like to opt out of Interest-Based Advertising practices in mobile applications, please follow the instructions in the Opting Out section below.
Do Not Track (“DNT”) and “Limit Ad Tracking”
DNT is a privacy preference that users may set in certain web browsers. It is intended to allow users another method of informing websites and services that they do not want certain information about their website visits to be collected over time and across websites.
Our technology does not respond to “do not track” (a/k/a DNT) signals or similar mechanisms transmitted by web browsers or mobile device operating systems. In the event that dataxu identifies the “Limit Ad Tracking” feature in Apple iOS version 9 and earlier, the device will be opted-out of advertising. To learn more about how you can exercise choices about the collection and use of certain data online for purposes of Interest-Based Advertising, please see the Opting Out section below.
PART IV. INTERNATIONAL TRANSFERS AND SECURITY
EU-US Privacy Shield
dataxu’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, dataxu remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless dataxu proves that it is not responsible for the event giving rise to the damage.
We have further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
If your complaint is not satisfactorily addressed, and your inquiry or complaint involves human resources data, you may have your complaint considered by an independent recourse mechanism: for EU/EEA Data Subjects, a panel established by the EU data protection authorities (“DPA Panel”). To do so, you should contact the state or national data protection or labor authority in the jurisdiction where you work. Dataxu agrees to cooperate with the relevant national DPAs and to comply with the decisions of the DPA Panel.
For residual disputes that cannot be resolved by the methods above, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. To find out more about the Privacy Shield’s binding arbitration scheme, please see: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
The Federal Trade Commission has investigation and enforcement authority over our compliance with the Privacy Shield.
Security and storage
We use appropriate technical, organizational and administrative measures to protect any Personal Information we process about visitors to our Website and/or users of our Platform.
We retain the information collected via the Platform for up to 13 months. Following that, we aggregate the information and retain it for analytical purposes.
PART V. OPTING OUT AND YOUR PRIVACY RIGHTS
You may opt out of dataxu’s Interest-Based Advertising by following the instructions below for web browsers and mobile applications.
Please note that web browsers and mobile applications operate using different identifiers. You must opt out separately in each web browser and for each computer or device that you would like to be opted-out on.
For example, if you would like to opt out on your computer browser as well as your mobile device browser, you will need to follow instructions for the “Web Browser Opt Out” in both your computer browser and your mobile device browser. If you would like to opt out in mobile applications, you will need to follow the instructions for “Mobile Application Opt Out.”
Web Browser Opt Out
To opt out of dataxu’s Interest-Based Advertising on your computer or mobile web browser, please click the link below:
If you choose to opt out by clicking the link above, dataxu will set a cookie that tells dataxu not to display Interest-Based Advertising. If you delete your cookies or change computers, mobile devices or browsers, you will need to repeat this process for each computer or device and in each browser. You may download a browser plugin that will help you maintain your opt out choices, even if you delete certain cookies from your browser, by visiting http://www.aboutads.info/PMC.
Once you have elected to opt out, our system may take up to twenty-four hours to refresh, but following the refresh, this will prevent the Platform from using any interest-based data associated with your browser for Interest-Based Advertising. Please note that you will continue to see generic advertising.
Mobile Application Opt Out
To opt out of dataxu’s Interest-Based Advertising in mobile applications if you are resident in the United States, you can download the AppChoices mobile application consumer transparency tool for your device operating system and set your preferences in the application.
Please note that if you use the settings on your mobile device to reset the mobile operating system advertising ID, you will also need to reset the preferences you select in AppChoices.
We will also provide an individual opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To limit the use and disclosure of your Personal Information, please submit a written request to email@example.com.
Update and access to your Personal Information
Where we hold Personal Information for our own account management, billing or marketing purposes, then we provide individuals with the opportunity to access, review, modify, and delete any such personal information that has previously been provided. You can send an email to: privacy @dataxu.com or call us on (857) 244-6200. If you make a request to access your personal information we may charge you a fee subject to a maximum specified by applicable law.
dataxu acknowledges that EU individuals have the right to access the Personal Information that we maintain about them. An EU individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
Unsubscribe from our mailing list
You may at any time ask us to remove you from any mailing list on which you previously asked us to include you by sending us an email at email@example.com, by calling us on (857) 244-6200 or by clicking “Unsubscribe” in any e-mail communications we send you.
PART VI. OTHER IMPORTANT INFORMATION
Our Services are not directed to individuals under the age of 13. We do not knowingly collect personal information from such individuals. If you become aware that a child has provided us with information, please contact us at firstname.lastname@example.org. If we become aware that a child under the age of 13 has provided us with personal information, we will take steps to delete such information.
How to contact us
Address: 281 Summer Street, 4th Floor, Boston, MA 02110, Attn: Legal Department