Last Modified: October 23, 2014
At Conversant, Inc., or any of its subsidiaries or affiliates, including Commission Junction, Inc., a Conversant Company (“Conversant,” “we,” “us,” or “our”), we provide online advertising services. To do this we follow information usage practices based on two beliefs: first, that protecting user privacy is essential to the growth and prosperity of the Internet; second, that a personalized web experience can provide significant benefits to Internet end users if done properly. In accordance with these beliefs, Conversant creates results for advertisers and publishers in revolutionary ways without compromising individual privacy.
If you have questions or concerns regarding this statement, email us at firstname.lastname@example.org.
To start, it is important for you to know two definitions that are key to understanding our programs and privacy practices:
Personally Identifiable Information (“PII”): Information that can be linked to an identifiable individual person. This type of data includes things like full name, home address, telephone number, or email address.
Non-Personally Identifiable Information (“Non-PII”): Information that cannot identify an individual person, such as IP address, browser types, operating systems, domain names, access dates and times, referring website addresses, online transactions and browsing and search activity.
Please take some time to read about what our business does, learn how we ensure that data you share with us is collected and used safely, and visit resources that provide more depth on our industry.
- What Conversant Does
- Privacy by Design
- Information Collection & Use
- Self-Regulation & Voluntary Compliance
- Your Choices
- Safe Harbor
- Use of the Conversant Sites as a Visitor or Client
- Contact Us
- Your Representations
Information Collection: PII
We do not collect PII except as expressly provided for herein. For example, PII may be collected should a consumer contact Conversant on his/her own initiative, register with a publisher to download a mobile app, or as part of our lead generation business.
Information Collection: Non-PII
The Non-PII we collect may include, as an example, IP address, browser types, operating systems, domain names, platform type, language preference, access dates and times, referring website addresses, online transactions and browsing and search activity.
How Information is Used
We may use your Non-PII for purposes such as enhancement of our services, marketing, and to more effectively match advertisements, applications, and website content to your interests.
Sharing Your Information
We may share your information with third party service providers with whom we have contracted, Conversant and its subsidiaries and affiliates, third party marketing partners, business partners and our clients and publishers, and as expressly provided for herein.
You may regulate the collection and use of Non-PII in your browser, by uninstalling or electing not to install an app, or via the opt-out options provided herein.
We use reasonable and appropriate security measures to protect your data.
We retain Non-PII for no more that eighteen (18) months for advertising purposes. Aggregate Non-PII data for reporting may be retained for a longer period.
WHAT CONVERSANT DOES
While you may only visit certain websites, there are other companies working behind the scenes to help provide you with a great experience online. These third party companies provide vital services such as analytics, advertising, and fraud prevention to retailers, publishers, and other organizations. These services enable them to, among other things, provide the advertising that keeps your favorite blogs free, your favorite stores in business, and your advertising experience more relevant.
We help companies provide advertising online, and we do it in a variety of ways, from banner ads to coupon codes. To make some of these things possible, we need to have information available to provide smarter decision making. Technologies such as cookies and advertiser IDs enable companies like ours to provide more relevant advertising while keeping your identity anonymous.
In addition to our advertising services, we also utilize our technology to provide life-saving messages during tornadoes and AMBER Alerts, geotargeted to individuals in affected areas. To learn more about these internationally-recognized programs established by Conversant through an organization called the Federation for Internet Alerts, click here.
PRIVACY BY DESIGN
Our philosophy on privacy at Conversant follows the framework of Privacy by Design. We integrate privacy in strategy, product development, and more. We set the tone for privacy protection early and often, proactively working to keep PII out of our systems, and building technologies that are effective without the use of PII. We can protect consumer privacy AND provide relevant advertising, which benefits everyone involved, especially advertisers, consumers, and small business websites. Ensuring the protection of privacy throughout the entire lifecycle of the data is of the utmost importance and Conversant is careful to protect privacy as data is collected, used, and destroyed responsibly.
We constantly strive to maintain unparalleled visibility with consumers. We provide transparency and choice through our website, encourage the same practice throughout the Internet, and utilize AdChoices on each banner advertisement tailored to consumers’ interests.
Conversant has developed a strong privacy foundation and has a company culture aimed at the prevention of the receipt and use of PII. We respect consumer privacy, and give consumers the ability to opt out of receiving interest-based advertising (“IBA”).
INFORMATION COLLECTION AND USE
Information Collected by Conversant
Conversant only collects Non-PII from you (unless PII is provided by you voluntarily), and may collect this in a variety of ways. We may use technologies such as cookies, log files, pixel tags or other similar technologies to collect Non-PII about the browser or device you are using, including browsing activity, online transactions, and IP addresses. We may also receive Non-PII from third parties. Some clients contribute PII such as your name, address, email address, and associated transactional information directly to a third party with whom Conversant has a contractual relationship. This third party renders all such PII anonymous before providing it to Conversant for our use in providing advertising to you. All Non-PII received and collected by Conversant may be combined and used to provide you advertising, and for other purposes as determined by Conversant.
“Log files” track actions occurring on Sites and collect data including, as an example, your IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamp, click data and types of advertisements viewed.
"Web beacons" are objects that are embedded in a web page or e-mail and are usually invisible to the user but are used to track a web user’s navigation of a website or collection of websites or pages, interaction with an e-mail, use of mobile applications, the completion of transactions, submittal of applications and browsing behavior.
The Non-PII collected is used for marketing purposes, enables us to determine which advertisements perform well, allows us to more effectively match ads, mobile application and website content to your interests, assists us in improving the operation of our services, helps us to maintain the quality of our services, enhances our services to our business partners and clients and enables us to provide general statistics to our business partners and clients regarding use of Conversant’s services. Conversant may also act as delivery agent when its products and services are used directly by client to facilitate advertisements and other communications.
Conversant is in full compliance with the NAI health transparency program. Any health-related information collected relates only to high-level health segments. Conversant and its subsidiaries do not collect information that may be considered detailed or cause concern to consumers in regards to health-related privacy matters. For a list of health segments used by Conversant, click here.
When a consumer responds to or views an Internet advertisement served by Conversant (such as through third-party websites or email solicitations) or visits a Conversant site, we may assign an anonymous, unique identifier to the end user's Internet browser or device, often via a cookie. One function of these technologies is to provide Conversant with information for the purpose of paying third-parties affiliate commissions when an Internet user clicks on a link, creates a lead, or makes a purchase on an advertiser's website. If the Internet user re-visits the advertiser's site directly, Conversant is able to continue to track the user's activities (excluding PII) on the advertiser's site and reward the third-party website that referred the user. We also may use Internet browsing and online purchase data associated with an anonymous identifier to develop a predictive statistical user profile of the end user's needs and interests.
Information Sharing by Conversant
In the event that Conversant is acquired by or merged with a third party, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your information is treated, transferred, or used.
Service-specific Provisions for Information Collection and Use:
Some products and services offered by Conversant have privacy considerations unique to those offerings. These considerations are covered here.
We may receive PII that our clients have collected in connection with our services for our clients or that clients have collected for access or transmittal purposes to other clients. We may hold such information and/or transmit or allow access to such information to the intended recipients or categories of recipients as requested by our clients.
As part of the Lead Gen services, online forms hosted by us, our clients, or third parties acting on the behalf of us or our clients may collect PII that a consumer has voluntarily provided. This information may be used for the same purposes listed in “Information Sharing by Conversant,” above. This information may also be used to verify any information submitted to use or any of our clients, and for any suppression or opt-out purposes.
Conversant may serve advertisements to you based, in part, on the demographic and geographic information you submitted to our clients during the website registration process, and lifestyle information about you that we obtain from them and other Conversant entities and third parties.
Conversant offers clients an email marketing product, Conversant Mail. Conversant Mail is used to configure and send email communications and promotional offers to permission-based email lists provided by its clients. In this process, certain PII is stored and managed in Conversant Mail. This PII is provided by the client to Conversant. Conversant does collect general email campaign performance data in order to report aggregated results to clients.
You can control the email you receive through Conversant Mail. To opt-out of emails sent by Conversant clients using Conversant Mail:
- Click the unsubscribe link that at the bottom of the email.
- Reply to the message with "unsubscribe" in the Subject line or body of the email.
If you have attempted to opt out without success, forward a copy of the email you are trying to opt-out of along with your full name and email address to email@example.com so that we can investigate and resolve the problem.
Conversant promotes proper Internet practices and full compliance with the CAN-SPAM Act of 2003 (15 U.S.C. § 7701) which requires advertisers to provide an opt-out mechanism for consumers to unsubscribe from future emails. Conversant does not allow clients to use Conversant Mail to send unsolicited commercial email ("UCE" a/k/a spam). Conversant Mail may only be used for communications to Internet users who have opted-in to receive the client's email marketing messages.
The security of your information is important to us. We have implemented appropriate security measures to protect the information in our care, both during transmission and once we receive it. We take physical and technical security measures to protect our data from unauthorized access, as well as unauthorized disclosure or destruction of data.
No transmission of data over the Internet is guaranteed to be completely secure. While we strive to protect your data, it may be possible for third parties not under the control of Conversant to unlawfully intercept or access transmissions or private communications. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. Conversant cannot ensure or warrant the security of information you transmit to us. You acknowledge and assume this risk when communicating with Conversant.
We retain Non-PII for IBA for no more than eighteen (18) months. Aggregate reports generated from such data may be retained for a longer period, as ad delivery and reporting data.
SELF-REGULATION & VOLUNTARY COMPLIANCE
Our industry has a rigorous voluntary self-regulatory regime, and we are active members of industry groups such as the Network Advertising Initiative (NAI), Interactive Advertising Bureau (IAB), and Digital Advertising Alliance (DAA) who promulgate codes of conduct to which their members must adhere. These codes impose requirements on participating companies such as transparency and choice around the use of data for IBA, and require regular audits of member privacy practices.
Conversant is an active member of these and other groups, and where Conversant engages in activities regulated by these programs, we comply fully with both the NAI Code of Conduct, and the DAA Self-Regulatory Principles.
You will need to make this selection on each browser or device on which you do not want to receive IBA from Conversant. If you or your privacy software deletes the opt-out cookies from your computer, you will need to repeat the process.
As an alternative, you may also visit the Network Advertising Initiative opt-out page at: www.networkadvertising.org/choices.
Conversant may place ads on websites that are part of the Google Display Network. Based on your visits to these websites, Google uses an advertising cookie (from DoubleClick) to associate your browser with interest and demographic categories. Google then uses these categories for IBA on these websites. To learn more about this and your choices from Google, please click here.
Mobile Device Choices
For mobile websites, you can delete our cookie via the browser settings. For mobile apps, you can typically limit ad tracking within the settings function. On most Android devices, in the “Ads” menu, you can opt out of receiving IBA, or reset your advertising ID. On most Apple iOS devices, you can use the Ad Tracking settings to limit receipt of IBA or reset your device’s Advertising Identifier. Please note that your experience may be different depending on your individual device and service. In addition to using the options above, you may also uninstall the application from your device.
The European Union ("EU") maintains strict privacy laws. These rules differ significantly from the laws of the United States of America (“US”). To reconcile these differences, the US and the EU have created a safe harbor (“Safe Harbor”) that defines mutually acceptable privacy operations.
Conversant complies with the U.S.-EU and U.S.-Swiss Safe Harbor Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. We have certified that we adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view the company's certification, please visit http://www.export.gov/safeharbor.
Conversant has further committed to refer unresolved privacy complaints under the U.S.-EU and U.S.-Swiss Safe Harbor Privacy Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, 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 by Conversant, please visit the BBB EU SAFE HARBOR website at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
USE OF THE CONVERSANT SITES AS A VISITOR OR CLIENT
You can browse the Conversant Sites without providing any PII. You may choose to provide PII to us voluntarily if you interact with our Site in certain ways, such as applying for employment with Conversant, responding to an advertisement for Conversant, or using one of our contact forms. This information is used only for the reasons it was collected, such as responding to your communication, and is not shared with third parties other than to fulfill the purpose for which it was collected.
Conversant may also collect Non-PII, through the use of technologies such as cookies, including IP address, browser type, operating system, domain name, language preference, access dates and times, referring website addresses, online transactions and browsing and search activity. We may use this Non-PII for purposes including enhancement of our services; marketing; IBA, and to more effectively match website content to your interests. We may share your information with our third party service providers, Conversant and its subsidiaries and affiliates, third party marketing partners, our clients and publishers, and as expressly provided for herein.
For Clients and Publishers
The Conversant network includes our clients and publishers involved in advertising campaign transactions. Information collected from clients and publishers includes PII that is necessary to conduct business, such as name, phone number, and email address. Payments made to and from Conversant require the collection of PII that may include credit card numbers and bank account information. Phone numbers may be used for sales or inventory acquisition purposes. This information is collected, modified and stored in a password protected environment and is used for purposes including service, media delivery, contact, billing and accounts payable. We will not sell or rent this information to non-Conversant entities. All client and publisher information collected for these purposes is explicit, voluntary, manually entered, and can be opted-out.
See “Security” under Information Collection and Use, above.
This client and publisher information is not shared with any third party outside Conversant and its affiliated companies, except for that necessary to conduct business, such as clearing a credit card transaction for an advertising campaign purchase or making an ACH direct deposit to pay a publisher, or as required by law. The security of this information is crucial to our success in the highly competitive field of online advertising. Conversant may, from time to time, use "gallery" pages to identify clients or publishers by business identity ONLY (e.g. Adcycle.com is a new Publisher in the Conversant Network).
We record the IP address of new clients and publishers at sign-up. This can assist in administering the Site and client or publisher accounts, including features designed to enhance the Client experience. This information is part of the secure member database and is password protected.
We send all new clients and publishers a welcoming email to verify password and user name, and may communicate with you about program or other information at the contact information you provide.
Site and Service Updates:
We may send Site and service announcement updates by email. Because these announcements contain important information about services, it is not possible to unsubscribe. We also communicate with clients and publishers to provide requested services and in regards to issues relating to their account via email or phone.
If a client’s or publisher’s PII changes (such as email address) or they would like PII removed from our system, we provide several ways to correct or update PII. The following options are provided:
Make the changes online by entering the member area.
Contact your account manager.
All requests to remove a client or publisher from our system will be verified prior to removal to ensure the proper identity of the requester.