1. What Does Netaktion Do?
Netaktion provides advertising technology products and services. We are headquartered in the U.S. For more information regarding our business, please visit the website link set out above.
2. What is Targeted Advertising?
Certain of our products and services involve the provision of targeted advertising. This involves providing tailored advertising to online users based on their interests and behaviors. Crucially, our targeted advertising is conducted at an "audience" or a "segment" level (e.g., males in Chicago aged 25-34 who like cars) and so does not directly identify individuals.
We do not intentionally collect information that identifies you (such as your name, address, phone number, or email address) as part of our targeted advertising activities, and we prohibit our partners from sharing this information with us. We act on behalf of our customers in providing any targeted advertising products and services.
3. What Personal Information Does Netaktion Collect and Why?
The personal information that we may collect about you broadly falls into the following categories:
- Information that you provide voluntarily
Certain parts of our Website or services may ask you to provide personal information voluntarily. For example, we may ask you to provide your contact details in order to register an account with us, to subscribe to marketing communications from us, and/or to submit inquiries to us. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
- Information that we collect automatically
When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g., country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.
Our Products and Services
We may collect browser-based information regarding how you interact with advertising placed via our products and services. This information may include the following: (i) technographic data related to the browser, operating system, and device, such as the name and version of your browser, (ii) connection data (such as the device’s current IP address), (iii) the current website visited, (iv) the website visited before the current website, (v) the title of the game for any in-game advertising, (vi) search terms, (vii) the date and time of the website visit, (viii) whether you have clicked on the advertising of our customer/our customer's website, visited the advertiser’s website, or undertaken a transaction with the advertiser, (ix) information like the aforementioned regarding the activity of users who share full length or shortened links via social media channels.
We may also collect from our customers/partners certain non-identifying demographic information about users such as their gender, approximate regional location (e.g., country and town), and age, or generic categories about users and their interests (e.g., "female sports fan").
We may collect general health related information in association with customized advertising campaigns. General health-related information that is not based on a precise medical treatment or condition can include, but is not limited to the following examples: acne, allergies, dental, vision, heartburn, cold and flu, sinus, headache, back pain, first aid, sore throat and cholesterol management. In addition, interest in subjects such as diet, nutrition, exercise, beauty, hair removal, health and fitness may also be collected. Note that such information is only collected/processed at an aggregate level and solely in the U.S. and Canada. This information is not collected in relation to individuals located in the European Economic Area.
Certain customers may choose to implement our Po.st technology, which facilitates the sharing of web content. When users use the Po.st services, we may receive information about which channel was used for sharing or receiving content (e.g. a social network or email). In addition, if a user uses Po.st to send an URL link to another user, and the user clicks on the sent URL link, we may also receive the above browser-based information related to this user.
If you are using our products/services via a mobile application, we may use the Apple IFA, Android Advertiser ID, or other device information that uniquely identifies a mobile device in order to match certain information that we collect via the mobile application.
In certain territories, advertisers may also elect to run Netaktion Surveys after their advertisements. "Netaktion Surveys" are short surveys that users can voluntarily elect to participate in and where such survey responses may be used to create lookalike models that are not tied to a specific user. Such survey questions are a way for advertisers to obtain information directly from users about their interests. Users might be asked, for instance, "Which of the following comedy programs do you watch?" with a drop-down menu of TV shows, or "How frequently do you travel for business?" with a drop down menu of different options. We may place cookies, or collect mobile device identifiers, associated with this survey information or inferences or data segments we create from it. We may use the information we collect from Netaktion Surveys in all of the ways we use the other information described in this Privacy Notice.
We use Google Analytics for aggregated, anonymized website traffic analysis. In order to track your session usage, Google drops a cookie (_ga) with a randomly-generated ClientID in your browser. This ID is anonymized and contains no identifiable information like email, phone number, name, etc. We also send Google your IP Address. We use GA to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving the user experience and determining site effectiveness. If you choose to opt out of this anonymized process please visit https://tools.google.com/dlpage/gaoptout
- Information that we obtain from third party sources
From time to time, we may receive personal information about you from third party sources (including BlueKai or LiveRamp), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
The types of information we collect from third parties include cookie and device IDs and we use the information we receive from these third parties to provide Targeted Advertising.
4. Cross-Application and Cross-Device Technology
We and/or our customers may use technology that establishes connections among related devices (such as mobile devices and desktop computers) both to deliver advertising that may be more relevant to you, as well as for analytics and reporting purposes. This means that information about your use of websites or applications on one of your devices may be combined with information from your other devices.
We may also partner with third parties to provide such cross-device technology to our customers, and in doing so, we may share anonymous identifiers with those third parties in order 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 our use of such technologies, please follow the instructions set out in the Opting-out of Cookies Usage section below.
5. Who Does Netaktion Share My Personal Information With?
We may disclose your personal information to the following categories of recipients:
- to our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. For example, partners like LiveRamp may place or recognize a cookie on your computer, device, or directly in our emails/communications, and we may share personal information with them if you have submitted such information to us, such as your name, postal address, email address, or device ID. Our partners may link the personal information we share with them to the cookie stored on your browser or device, and they may collect information such as your IP address, browser or operating system type and version, and demographic or inferred-interest information. Our partners use this information to recognize you across different channels and platforms over time for advertising, analytics, attribution, and reporting purposes.
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice; and
- to any other person with your consent to the disclosure.
6. Legal Basis for Processing Personal Information (EEA Visitors Only)
If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to provide our services and communicating with customers / users as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to queries, improving our services, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to Contact Us” heading below.
7. Cookies and Similar Tracking Technology
8. Opting-Out of Cookie Usage
You can opt-out of receiving our Cookies. Persistent Cookies may be removed by following your Internet browser help file directions. If you choose to disable Cookies, some areas of our Website may not work properly. If you opt out, your web browser will be associated with a generic "opt-out" cookie, which will prevent us from associating any non-personally identifiable information with your browser.
You can also opt-out of targeted advertising based on data collected via your browser by using (i) the NAI’s opt-out tool, which can be found here; (ii) the DAA’s opt-out tool, which can be found here; (iii) the DAAC’s opt-out tool, which can be found here; or (iv) the EDAA’s opt-out tool, which can be found here.
When you opt out, we will stop (a) collecting information about your interests via your browser and (b) serving you targeted advertising based on the data collected via your browser.
We will subsequently place a piece of data in your browser’s cookie that tells us that y ou have opted out - it does not contain any data about you except for the fact that you have opted out. We need this cookie in place so that we know not to collect information about your interests and serve you targeted advertising based on your interests in the future. Our "opt-out" cookie has a five-year expiration date.
Keep in mind that participating in our opt-out program does not prevent you from seeing advertising served by us, instead, the ads we serve to you will be generic and not be targeted to you based on your web browsing experiences.
9. How Does Netaktion Keep My Personal Information Secure?
We use appropriate technical and organizational measures to protect the personal information that we collect and process about you.
10. International Data Transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Specifically, our servers are located in the US and the Netherlands, and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.
However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law. Our Standard Contractual Clauses can be provided on request.
11. Data Retention
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (e.g., to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
We use personal information used for targeted advertising purposes for no more than 13 months. We maintain ad server log data and stored data for a period of up to 18 months in order to comply with audits, court order or law enforcement inquiries. After 18 months, all of the stored data is destroyed. Summarized data is kept indefinitely. Summarized data is aggregated statistical data (impressions, clicks, and conversions) used for financial reporting purposes.
Partners with whom we work, including platforms that we may integrate with to provide services, may set cookies or retain data for other, longer periods of time, which we do not control.
12. Your Data Protection Rights
If you are a resident of the European Economic Area, you have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by using one of the links below or by contacting us using the contact details provided under the “How to Contact Us” heading below.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to Contact Us” heading below.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to Contact Us” heading below.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Although certain of our technology honors “do not track” (DNT) signals and similar mechanisms transmitted by web browsers or mobile device operating systems, we are not responsible, and shall not be liable, for the acts of third parties, such as ad networks, with respect to such third parties’ tracking policies.
Our websites, products, and services are neither developed for, nor directed at, children under the age of 13. With respect to the Children’s Online Privacy Protection Act (“COPPA”), we do not knowingly collect personal information from nor employ or offer targeting towards children under the age of 13.
If you believe your child, who is under the age of 13, has provided us with personal information or registered at one of our websites, please contact us at the address below and we will use reasonable efforts to remove that information from our records.
15. Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the end of this Privacy Notice.
16. How to Contact Us
If you have any questions, concerns or requests please contact us at:
Attn: Privacy Agent
45 St. John Street
Goshen, NY 10924
Please address all notices to the “Privacy Agent” and write “Privacy Notice” in the subject line.
This document was last updated February 15, 2020.