Privacy Policy
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- WEBSITE PRIVACY POLICY
- GENERAL SERVICES PRIVACY POLICY
Last Updated May 27, 2021
- WEBSITE PRIVACY POLICY
Scope
This Website Privacy Policy (the "Privacy Policy") applies solely to information collected by AVANGATE. on this website (the "Site"). This Privacy Policy provides information about how and why collects and uses the information provided to us on this Site.
For information on s range of services, how we use data across our different services, and your options, please refer to the General Services Privacy Policy located below.
Links to Third Party Sites
This Privacy Policy does not apply to the information collection and use practices of third-party sites including, but not limited to, client and affiliate websites, applications and websites on which we may place advertisements, and any third-party websites you may link to from our sites. does not endorse or make any representations about these third-party sites or applications, or any information, software, products or materials found there. We encourage you to review the privacy policies of these third-party sites to understand their data collection and use practices.
Information Collection, Use and Sharing
Information Collection
We collect two types of information from and about our Site Users: personal information (or "personal data in the EEA) that identifies you, which is collected when you provide it do us, and tracking data which is collected when you navigate the website.
Tracking data may include things like the Uniform Resource Locator ("URL") of the Site you visited before coming to our Site, the URL of the Site you visit after leaving our Site, the type of browser you are using and your Internet Protocol ("IP") address. We, and/or our authorized third parties, may automatically collect this information when you visit our Site through the use of electronic tools like Cookies and Web beacons or Pixel tags, as described below.
We use tracking data to troubleshoot, administer the Site, analyze trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities. We may also share this information with our authorized third parties to measure the overall effectiveness of our online advertising and content.
Personal Data. Personal Data means information from which you can be identified. It does not include anonymous or aggregated data that cannot be linked back to a specific individual.
Information Use
uses the information we collect at this Site to fulfill your requests, respond to your inquiries and provide news or updates. We may also use your information to make our Sites easier for you to use and to inform you of service and product updates, whitepapers, new products, market research opportunities and other related information from ", or to send you promotional messages regarding various products and services.
may use your tracking data to analyze trends, administer the Site, track users activities on the Site, help us understand the parts of our Sites visited most often and gather broad demographic information for aggregate use in improving our Site.
Information Sharing and Disclosure
may share your information with our affiliate companies and service providers for the purposes described in this policy.
We reserve the right to disclose your information as required by law, court order or other valid legal processes or in connection with the consolidation, sale of or other transaction related to our business. We also reserve the right to disclose your information if we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a valid government request.
Choices
Even if you choose to opt-out of our communications, will retain and use your information to comply with our legal obligations, resolve disputes, enforce our agreements and to maintain a record of your opt-out. You may also still receive transactional emails, such as registration confirmation, product updates and responses to direct requests you have made.
Cookie Policy
Cookies are small text files that store data using your web browser to make your browsing experience easier and faster. We, and our third-party service providers who assist with managing our Site, use cookies, web beacons and similar technologies on our Site to improve the performance of our Site, to make our Site more user-friendly and to track your use of our Site.
Types of Cookies used on our Site
Performance Cookies: These cookies collect information about how visitors use our Sites for web analytics purposes, for instance which pages visitors go to most often and error messages received. These cookies are only used to improve how our Sites work and your experience on our Sites; they do not track your browsing activity on other websites. By using our Sites, you agree that we can place these types of cookies on your device.
Functionality Cookies: These cookies allow our Sites to remember choices you make (such as remembering your username and password, language preference or the region you are in) and provide enhanced, more personalized features. These cookies may also be used to remember changes you have made to text size, fonts and other personalization. They may also be used to provide services you have requested, such as keeping you logged in to your account as you browse the internet. These cookies do not track your browsing activity on other websites. By using our Sites or by signing up for an account with us, you agree that we can place these types of cookies on your device.
Managing Cookies in Your Browser
You may be able to adjust your browser settings to manage your cookie preferences, such as setting your browser to notify you when you receive a cookie and give you the choice to decide whether or not to accept it. If you reject cookies, you may still use our Sites, but the functionality of some areas may be limited.
Below are links to information about managing your cookie preferences in common browsers:
Google Chrome Cookies
Mozilla Firefox Cookies
Internet Explorer Cookies
Safari Cookies
Google Analytics
Content Sharing Features
DATA RETENTION
We only retain the information we collect, including personal data, for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, as well as applicable legal requirements.
SECURITY
uses commercially reasonable safeguards to protect personal information against loss, misuse or alteration and to maintain the integrity and security of all information collected through the Site.
YOUR RIGHTS REGARDING PERSONAL DATA
You may have the following rights under applicable data protection laws in relation to your Personal Data, including:
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of personal information we hold about you.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete personal information. There may be some cases where, as allowed by applicable laws we may refuse to delete data. We may also anonymize data so that it cannot be related back to you instead of deleting it.
INTERNATIONAL DATA TRANSFERS
For users based in the European Economic Area (EEA) we may share your personal data within the Group or with external third parties. This may involve transferring your data outside the EEA, including (but not limited to) the United States or Asia.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
We may transfer data subject to specific contracts approved by the European Commission, which ensures that personal data the same protection it has in Europe regardless of where it is processed. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Do Not Track
Currently, various browsers “ including Internet Explorer, Firefox, and Safari “ offer a "do not track or "DNT option that relies on a technology known as a DNT header, which sends a signal to Web sites visited by the user about the user s browser DNT preference setting. does not currently commit to responding to browsers DNT signals with respect to the Company s Web sites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent.
Children s Privacy
This Site and the services we provide are intended for general audiences, and is not intended for use by persons under the age of 16. If we learn that we have inadvertently collected personal information from a child under the age of 16, we will delete it. If you believe that we have collected personal information from a child under 16, please contact us using the information below.
Updates to this Privacy Policy
We reserve the right to modify this privacy statement at any time. Note the date of the most recent update at the top of this page. If we make material changes to this policy, we will notify you here, by email, or by means of notice on our home page.
Contact Us
To ask questions about s Privacy Policy or to request more information on "s privacy practices, email us at [email protected]
2. GENERAL SERVICES PRIVACY POLICY
INTRODUCTION
"Is an advertising company that uses software and data about consumers to help advertisers reach selected audiences via online or in-app ads. collects and uses data about individual consumers in order to identify or predict the types of advertisements most likely to appeal to them. We use a lot of data, because more data points about a person s interests and purchase intent leads to more accurate advertising with a higher rate of return for advertisers. has various lines of service, as described below, and the way each works is different. But in general, the sole purpose for our collection and use of data is to match people to advertisements that are likely to interest them. That is our mission. We use data, software, and ingenuity to help advertisers reach people who want their products and services. Our business succeeds when we help advertisers achieve higher-than-average rates of response to ads”that is, people clicking on or forwarding an ad or ultimately making a purchase.
For all of our services the overall purpose of our data collection, use, and sharing is the same to match advertisements to people who have a propensity to engage with them and ultimately to increase sales for our advertiser clients.
All services may include some amount of "lookalike modeling", where we use data about known purchasers of a product or respondents to an ad to identify individual attributes that indicate a propensity to buy that product or respond to that ad. This allows us to create a profile of the attributes of a person most likely to respond to an ad, which is used to inform who a future ad will go to.
We do not provide services that include ads with illegal or adult content, nor do we advertise on adult sites or collect data about what adult sites people visit. We do not knowingly collect or sell personal information from children under 16. In the event that we learn that we have collected personal information from a child under the age of 16, we will delete it. We do not knowingly facilitate any advertising that is exploitative, discriminatory, hateful, deceptive, or abusive, and our process for doing this is audited annually.
The types of data we use are also the same across all our services:
(1) Data collected indirectly from you using cookies or other online or mobile technologies that allow us to identify certain sites that you visit or apps that you use online. Included is information about when and where you gave your permission to receive commercial email, your IP address, and visits you made to certain websites. We log these page views to help infer your interests in order to determine what sort of products or services might interest you. This data typically does not include direct identifiers (like name and address), but it can still be linked back to you via unique identifiers like a cookie ID, mobile ad ID.
(2) Data we have obtained from third-party data brokers or data partners. This may include data obtained from public records, but also data relating to purchases, interests, or likely interests that can be derived from a wide variety of sources. In some cases, we may obtain data from third parties in or close to real time in regard to a specific ad placement. This "just in time approach to obtaining data means that we collect and aggregate less data ourselves, while still being able to draw on third-party data sources to help make decisions about which ad to send to which person.
Our sources of data include:
You, when you give data directly to one of our websites, clients, or data sharing partners;
Advertisers who may provide us data they have collected from or about you to use in performing advertising services for them;
Data we or others collect using cookies or other online trackers;
Data brokers who supply data obtained from public records, or who resell data obtained from private sources.
is not a data broker in the sense that we do not simply sell data. The ways in which we share data with our clients are very limited. You will find more details on this in the sections below describing each of our services.
SERVICES WHERE COLLECTS AND USES DATA ON ITS OWN BEHALF
The Data Cloud is what we call the data related to identified people that collects and uses on its own behalf. The Data Cloud consists of several databases where we store data that we have obtained from the different sources described above. It also includes connections to other third-party sources of data (data brokers and data sharing partners) so that we can get data at or near real time in order to inform specific ad placements. This approach means that we are using the freshest, most up-to-date data we can obtain, and it also reduces the amount of data we need to gather into one place in order to provide our services. Our proprietary software, machine learning, and artificial intelligence tie all these sources of data together which enables us to make very complex decisions about which person is most likely to respond to a specific ad at any given time and deliver that ad to that person.
We may use data from the Data Cloud on a temporary, limited basis to evaluate potential data sharing partners. When we do one of these evaluations, it is subject to appropriate contractual terms that include that the company we are evaluating may not do anything else with the data and must delete any data that we share at the end of the evaluation.
CRM and Data Cloud Services. This service consists of loading a client s customer data onto a secure controlled server, and then using our software to compare the client s data with data in the Data Cloud. We can use that to generate insights that the client could not produce on their own, like which existing customers would be most likely to respond to a particular ad campaign. We may sell data to an advertiser as part of this service, in the form of interest categories and inferred purchase intent data that relates to the client s existing customers. In other words, we don t sell our clients lists of people, but we might provide the advertiser with additional information about its existing customers that it didn t previously have.
When you visit different sites on the internet, different companies place cookies on your device, and use these to obtain information about the sites you visit, the ads you respond to, and the online purchases you make. Through a process known as cookie matching different companies (data sharing partners) can either sell or exchange different bits of this data. By stitching together bits of data from lots of different sources, we are able to create a rich and up-to-date data set that enables us to make predictions about what ad is likely to appeal to a specific person, or which person is most likely to respond to a specific ad. The cookie-matching means that data could theoretically be linked to fully identifiable data.
Below are links to information about managing your cookie preferences in common browsers:
YOUR PRIVACY RIGHTS
Privacy laws around the world give individuals different versions of the following rights. allows any person to exercise the following rights no matter where they live. will not discriminate against you for exercising your privacy rights.
Data Deletion-you can ask us to delete data that relates to you. As allowed by applicable laws, there may be some cases where we will decline requests for deletion, but these are rare cases.
DATA SECURITY and PRIVACY BY DESIGN
uses commercially reasonable, industry standard practices to protect data. These include technical, physical, and organizational controls designed to prevent loss or unauthorized access to data. Our security measures are audited every year by an independent third party, and we are constantly evolving our approach to security to keep pace with emerging threats.
also follows the practice of Privacy by Design, meaning that we consider the privacy and legal implications of our products and services and ensure that they are built to standards that align to privacy requirements around the world. The Privacy office is headed by a Chief Privacy Officer and includes legal and non-legal resources with significant experience in the field. These professionals provide advice and guidance to s product designers, engineers, and other businesspeople on a regular basis.