LAST UPDATED: May 23, 2018
IgnitionOne is a member of the Network Advertising Initiative (“NAI”), which is a cooperative of online marketing and analytics companies committed to building consumer awareness and establishing responsible business and data management practices and standards. IgnitionOne complies with the 2015 NAI Codes of Conduct, the cross-industry Self-Regulatory Program for Online Behavioral Advertising as managed by the Digital Advertising Alliance (“DAA”) as well as the Digital Advertising Alliance EU (“eDAA”) and the Digital Advertising Alliance Canada (“DAAC”).
1.) The Services We Provide at IgnitionOne
Behavioral Advertising Services. We operate an online advertising service that helps advertisers customize, target and report on the advertisements we purchase on their behalf across third party websites and mobile applications. While purchasing these ads across third party websites and mobile apps, we collect information about the sites that you and others may visit, the mobile apps that you may use, the precise location of your mobile device such as the GPS coordinates (with consent), and the searches that you and others may conduct while online in order to serve advertisements that we believe are more relevant to your interests. Where we can reasonably infer that a particular computer and mobile device belong to the same user or household, we may extend our Behavioral Advertising Services and our advertising campaigns across those devices (sometimes called a device graph). Where we are able to make such an inference, we may serve advertising across multiple browsers or devices (sometimes called cross-device advertising). We also work with third-party data companies that help us tailor ads. If you want to opt-out from having your information used for our Behavioral Advertising Services, please visit the section of this policy entitled “Opt-out Choice” located below.
Optimization and Analytics Services. We also provide many of our customers with Optimization and Analytics Service, which help those customers (which are generally brands and other companies seeking to advertise online) manage their digital advertising programs. For example, we may help these businesses customize your experience when you visit their website, generate leads and manage their keyword search advertising programs. Where we can reasonably infer that a particular computer and mobile device belong to the same user or household, we may extend our Optimization and Analytics Services and our advertising campaigns across those devices. Because we undertake these activities on behalf of our customers and subject to those customers’ respective privacy policies, you should also consult our customers’ privacy policies to learn more about their practices.
2.) The Information We Collect and How it is Used
Non-Personal Information is information that does not reveal your specific identity. We and our third party service providers may collect Non-Personal Information from you in the course of providing the Services to our customers, including by placing cookies and using other tracking technologies such as “pixel tags,” “web beacons” or “clear GIFs.” Where we serve ads into mobile applications, we may utilize the advertising ID offered by the mobile operating system providers, and we may obtain precise location information (e.g., lat/long) of your device in accordance with the DAA Code. Please note that in certain places like the EU, some Non-Personal Information such as mobile ad ID and cookie IDs are considered personal data. For more information, please see the section below entitled “Special Data Protections for EU Data Subjects”.
Our Behavioral Advertising Services allow our advertisers to show you advertisements that are selected for you based on your past behavior on websites and mobile devices where we purchase advertisements on behalf of our customers. When you use one of the third-party mobile applications or visit a web page on one of the third-party websites where we purchase ads, we will serve advertisements that are tailored to your interests based upon information stored in our systems. We also collect data that allows us to infer that two devices (e.g., a laptop computer and a mobile phone) are likely to be part of the same household. This practice is sometimes referred to as creating a cross-device graph. Where we are able to make such an inference, we may serve advertising across multiple browsers or devices. This practice is sometimes called cross-device advertising. We collect information such as the URLs you visit, your browser type, your operating system, the date and time of your request and the duration of your visit to each page, and certain commercially viable keywords pertaining to the searches you conduct. As discussed above, when we provide Optimization and Analytics Services to our customers, we also collect information about your activities on our customers’ websites. The data contained in the IgnitionOne Audience Console is subject to the privacy policies of our customers. We generally keep the information we collect pursuant to our Behavioral Advertising Services separate from the information we collect pursuant to our Optimization and Analytics Services.
IP Addresses. We collect IP Addresses pursuant to the Services. Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites. We use IP addresses for purposes such as guessing your geographic location, providing our customers with geographic-specific reporting, helping diagnose server problems, and administering the Services. Please note that we treat IP Addresses, server log files, computer IDs and related information as Non-Personal Information, except where we are required to do otherwise under applicable law.
Personal Information. Is information that identifies you as an individual, such as your name, email address, postal address, telephone number and/or fax number. We do not collect Personal Information through the Behavioral Advertising Services and we do not merge or let our affiliates, customers or other third parties merge Personal Information with the Non Personal Information we use for our Behavioral Advertising Services. Please note that some jurisdictions such as the EU define Personal Information more broadly.
We collect Personal Information as part of our Optimization and Analytics Services and our Audience Management Services. For example, we may collect names, email addresses and postal addresses as part of an online lead generation campaign or an email marketing campaign on behalf of one of our customers. We don’t make independent use of such data, we use that information only as directed by our client, and ensure that this information is appropriately safeguarded and segregated from data collected pursuant to our Behavioral Advertising Services.
3.) Your Privacy Choices
Web based Opt-Out Choice Mechanism. You can opt-out of our web based Behavioral Advertising Services as follows:
- You can visit the IgnitionOne / Netmining opt-out page at https://ione.netmng.com/optout.php and follow the instructions.
You can visit the self-regulatory program opt-out pages at http://www.aboutads.info/choices/orhttp://www.networkadvertising.org/managing/opt_out.asp for the U.S., http://www.youronlinechoices.com/for the EU and http://youradchoices.ca/choices for Canada. If you select the “opt out” button there for IgnitionOne / Netmining, we will delete your existing netmng.com or IgnitionOne.com online behavioral advertising cookie(s) and try to place a new cookie that instructs us not to use data for online behavioral advertising or cross-device advertising on browsers where we detect that cookie and we will remove that browser from our device graph. If you are an EU data subject please seethe section below entitled “Special Data Protections for EU Data Subjects” for any additional rights you may have. If your browsers are configured to reject cookies when you visit our opt-out page, we cannot set our no-track cookie. Also, this choice mechanism is only applicable to the browser you are using, so if you subsequently erase your cookies, use a different computer or change web browsers, you will need to opt-out again.
Many of the advertisements we deliver via the Services will contain the advertising option Icon, a symbol that we license from the Digital Advertising Alliance. If you click onto the advertising option icon, you will see more information about behavioral advertising, including a mechanism that enables you to opt-out from IgnitionOne / Netmining and other DAA member companies.
Note: to the extent we and our affiliates and business partners recognize each other’s online behavioral advertising cookies, then opting out of either our Behavioral Advertising Services or their services may act as an opt-out of all services that recognize that cookie. However, that is not always the case. You can find out more information about other companies that provide opt-outs by visiting http://www.networkadvertising.org/managing/opt_out.asp, http://www.aboutads.info/choices/ or http://youradchoices.ca/choices.
Opt-out from our behavioral advertising services on mobile apps. We honor the mobile device settings for Android and Apple iOS devices. To exercise this opt-out, please visit the privacy settings of your Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android). For devices where we are able to see that such a selection has been made, we will not use data collected from that device for online behavioral advertising or cross-device advertising and will remove that device from our device graph. If you are an EU data subject please see the section below entitled “Special Data Protections for EU Data Subjects” for any additional rights you may have.
Precise Location Choices. If you’d like to adjust your choices regarding the use of precise location data by third parties such as IgnitionOne, you may do so via your device settings. For your convenience, we provide links to instructions for both Apple iOS and Android devices. Also, most mobile applications that collect precise location information offer mechanisms to control the collection and use of precise location information. Please note that these choice mechanisms won’t impact previously collected precise location information.
Opt-out from email messages from IgnitionOne Email Messaging Services. If you would like to stop receiving certain email marketing messages sent via the IgnitionOne Email Messaging Services, you may follow the opt-out instructions at the bottom of the email and/or forward the email in question to email@example.com.
Opt-out from SMS messages from the IgnitionOne Email Messaging Services. If you would like to stop receiving SMS marketing messages sent via the IgnitionOne Email Messaging Services, you may respond to the SMS message with the words “stop” or “quit”.
Do Not Track. A number of industry groups are attempting to develop a Do Not Track (DNT) standard. Currently, the standards regarding the DNT signals and appropriate responses are not defined. Accordingly, we do not assign a meaning to DNT signals.
Accessing, Changing or Suppressing Personal Information. While we don’t collect Personal Information in connection with our Behavioral Advertising Services, if you would like to change, suppress or otherwise limit our use of your Personal Information that has been collected pursuant to our Optimization and Analytics Services or via the IgnitionOne Audience Console, you may contact us by sending an email containing your request to firstname.lastname@example.org. For your protection, we will only implement such requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity and/or obtain more information from you before implementing your request. If you are an EU data subject please see the the section below entitled “Special Data Protections for EU Data Subjects” for any additional rights you may have.
In each event, you must clearly indicate the information that you wish to have changed, or suppressed or clearly indicate the limitations you wish to put on our use of your Personal Information. We will endeavor to comply with your request as soon as reasonably practicable and in no event more than 30 days from the date of a request from an EU data subject.. We may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records. We are not responsible for changing or suppressing information in our customers’ databases.
4.) Security, Data Retention and Other Privacy Issues
Sensitive Data. We do not create nor use any sensitive data segments as part of our Behavioral Advertising Services. However, we recognize that consumers may have differing opinions regarding which data segments are sensitive. In order to provide transparency around potentially sensitive data segments collected and used by IgnitionOne pursuant to our Behavioral Advertising Services, we will provide some examples of them here. For example, we may use health related segments such as “allergy sufferer” or “interest in Cold & Flu remedies.” For a more complete list of potentially sensitive health segments, please click here. While we don’t consider any of our data segments to be sensitive, we think it’s important to provide this transparency to help you have a better idea of which segments might be collected by us, so you can make informed decisions. And we don’t use any data segments to determine credit worthiness, for insurance underwriting or similar purposes.
Children under 13. IgnitionOne adheres to the Children’s Online Privacy Protection Act. We do not create nor use any segments of children under 13 as part of our Behavioral Advertising Services.
Integrity / Security / Purpose Limitation. We use reasonable organizational, technical and administrative measures to protect the information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.
Retention Period. As of January 1, 2012, the online behavioral advertising cookies we place on your computer will expire two (2) years after you last visit a site on our advertising network. We retain our other server logs related to our Behavioral Advertising Services for no more than two (2) years. Our Optimization and Analytics Services customers as well as our Audience Management Services customers can each individually determine how long we retain information on their behalf, so please check their privacy policies for more information. In places like the EU, our cookies last thirteen (13) months.
Data Disclosure and Onward Transfer. We may disclose Personal Information:
– to our affiliates so that they may use such Personal Information for the purposes described in this policy. IgnitionOne is the party responsible for the management of the jointly-used Personal Information.
– to our third party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, email delivery services, credit card processing and other similar services to enable them to provide services. For example, we may use third party analytics services, and they may place cookies on your computer and record data about your Site usage on our behalf. IgnitionOne is potentially liable for the onward transfer to third parties of personal data of EU and Swiss individuals pursuant to the EU-US and Swiss-US Privacy Shield programs, respectively.
– to our Clients and their agents.
– to an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
– as we believe to be appropriate: (a) under applicable law including laws outside your country of residence; (b) to comply with legal process including where we are required to disclose an individual’s information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain.
Special Data Protections for EU Data Subjects. As of May 25, 2018, the General Data Privacy Regulation (“GDPR”) will afford additional rights to EU data subjects. Those rights include the right to complain to EU Supervisory Authorities and the right to access, correct and delete certain personal data processed by IgnitionOne by visiting our EU data subject access request page. Moreover, with respect to EU data subjects, Personal Information includes pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID. Where IgnitionOne is a processor of data (e.g., via our Optimization and Analytics Services), the legal basis for processing such data is determined by our Clients. Where IgnitionOne is a controller of data (e.g., via our Behavioral Advertising Services), the legal basis will be both legitimate interest and consent depending on the type of information subject to processing and the information we receive from upstream partners. Where we rely upon legitimate interest, we have assessed the processing is not high risk and will not violate fundamental human rights. Where IgnitionOne receives from an EU data subject a request to cease processing of data via one of the choice mechanisms listed above, IgnitionOne will stop all data processing with respect to the opted out browser or device unless such processing is required by law. The retention period for data collected from EU data subjects will be based on the specific data collected and the purpose of processing such data. IgnitionOne’s data protection officer and EU Representative is Cedric Brosens and he may be contacted at Cedric.Brosensemail@example.com.
FTC. IgnitionOne is subject to the investigatory and enforcement powers of the FTC.
470 Park Avenue South, 6th floor
New York, NY 10166
Please note that email communications will not necessarily be secure; accordingly you should not include credit card information in your email correspondence with us.
Enforcement. We encourage interested persons to raise any concerns using the contact information provided above and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information.
IgnitionOne has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to the 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.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
Opt-out from SMS messages from the IgnitionOne Audience Console. If you would like to stop receiving SMS marketing messages sent via the IgnitionOne Audience Console, you may respond to the SMS message with the words “stop” or “quit”.
Accessing, Changing or Suppressing Personal Information. While we don’t collect Personal Information in connection with our Behavioral Advertising Services, if you would like to change, suppress or otherwise limit our use of your Personal Information that has been collected pursuant to our Optimization and Analytics Services or via the IgnitionOne Audience Console, you may contact us by sending an email containing your request to firstname.lastname@example.org. IgnitionOne acknowledges that EU and Swiss individuals have the right to access the Personal Information that we maintain about them. An EU or Swiss individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his or her query to email@example.com. For your protection, we will only implement such requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity and/or obtain more information from you before implementing your request.
In each event, you must clearly indicate the information that you wish to have changed, or suppressed or clearly indicate the limitations you wish to put on our use of your Personal Information. We will endeavor to comply with your request as soon as reasonably practicable. We may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records. We are not responsible for changing or suppressing information in our customers’ databases.