Privacy Policy

[ PRIVACY POLICY ]

YOUR PRIVACY CHOICES

Effective Date: January 1, 2020
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TRUSTX is committed to the highest standards for personal privacy and user choice. That’s why we’ve created this simple privacy FAQ that addresses common user questions and explains the choices you have when TRUSTX handles your personal information in our Digital Advertising Marketplace.

In addition, we’ve included a detailed Privacy Policy and some direct links to a few important privacy-related resources. If you have any questions about privacy and TRUSTX, don’t hesitate to reach out to privacy@trustx.org. We’ll do our best to get back to you right away.

FAQ: THE TRUSTX AD MARKETPLACE AND YOUR PERSONAL INFORMATION

TRUSTX is a Digital Advertising Marketplace. We provide supply-side programmatic advertising technology and services to a select group of digital content publishers, which enables them to sell advertising in an automated, programmatic fashion to advertisers. One of the benefits we provide for publishers is the facilitation of ad targeting, or what is often referred to as “interest-based advertising.”

The most common question we hear from consumers when it comes to interest-based advertising is, “What type of personal information do you collect and use to deliver this type of targeted advertising?”

When you browse one of our publisher’s websites, the publisher collects certain information about you and your device, which the publisher sends us each time they want us to attempt to sell an advertisement on their behalf. This information does not directly identify you – that is, publishers don’t send us your name, email address or any other contact details. They do send us technical identifiers, such as your browser’s cookie, a mobile device ID and an IP addresses. These technical identifiers are considered “personal information” under certain privacy and data protection laws.

When a publisher provides us this type of personal information about its users, we act as their service provider or processor of this information on their behalf, by passing the information to advertisers so they can respond with an ad they believe will be relevant to you.

How does TRUSTX facilitate interest-based advertising?

The TRUSTX Advertising Marketplace passes technical identifiers – cookies, device identifiers and similar technologies – to buy-side technology providers or buyers, who use this information to transact in an automated fashion. Because some of these identifiers are persistent across the Internet, ads may be customized based on interests generated from a user’s visits to different websites via the same browser or device. This type of customization – or targeting – is often referred to as “online behavioral advertising” or “interest-based advertising.”

Interest-based advertising means that publishers and advertisers share some level of personal information about users, which helps companies like TRUSTX better match a relevant advertisement with the user.

What kinds of personal information does TRUSTX collect from publishers?

Broadly speaking, the term “personal information” can mean directly identifiable data, such as a person’s name, email address or physical address, or it can mean technical information that identifies a user’s device or browser (e.g., mobile device ID or browser cookie) and an IP address.

As we explained in the introduction to this section, TRUSTX accepts technical information from publishers, although in some cases, publishers may send us generalized user-level attributes, such as a broad demographic segment (e.g., “female, 18 to 39 years old”), which we’ll include when we offer the ad inventory for sale on publishers’ behalf as part of the programmatic ad delivery process. We have contracts with our publishers that bind them to send us only these categories of personal information, and only in accordance with laws and their own privacy policies.

What kinds of personal information does TRUSTX collect directly from users?

TRUSTX also collects technical information that identifies a user’s device or browser, and we can independently identify each user’s IP address.

Do we sell your personal information?

No, we do not “sell” personal information in the traditional sense of the word. However, the California Consumer Privacy Act of 2018 (the “CCPA”) defines the word “sell” as any exchange of personal information for something of value, such as the delivery of an interest-based ad.

For TRUSTX to facilitate programmatic real-time bidding, TRUSTX (a supply-side platform) must pass technical information (and in some cases, user-specific attributes) from our publishers to demand-side platforms (who provide technology and services to advertisers) in order to execute an ad sale. Thus, under the CCPA definition, TRUSTX facilitates the “sale” of personal information from publishers so that advertisers may purchase interest-based advertising from our publisher members.

Can you opt-out of the sale of your personal information?

Yes. You may instruct any of our publishers to not sell your personal information, as defined by the CCPA. We encourage you to opt-out directly with those specific publishers for whom you’d like to exercise your “do not sell” choice. You may find a list of our publishers here, and can find opt-out links within their privacy policies. TRUSTX will honor the “do not sell” choices you have made with any and all of our publishers.

If you prefer to opt-out of the sale of your personal information through TRUSTX directly, which will affect how we handle your personal information received from all of our publishers, you may opt-out by clicking this Do Not Sell My Personal Information link. Please note that by using this opt-out method, TRUSTX will treat your choice not only as a “do not sell” choice, but also as if you have opted-out of all interest-based advertising across all of our publishers. In other words, an opt-out with TRUSTX eliminates all ad targeting based on any type of personal information.

Importantly, please understand that if you choose to opt-out with TRUSTX, your choice will apply only to programmatic advertising processed by TRUSTX; we cannot affect how our publishers or other supply-side providers handle your personal information.

Can you opt-out of interest-based advertising?

Yes. You may opt-out of receiving interest-based advertising that we facilitate on behalf of our publisher members. These methods, however, may require that you opt-out separately from each browser and each device you use, since different browsers and devices use different identifiers. If you opt-out of interest-based advertising, we will no longer collect the personal information described above from the opted-out device.

There are two ways in which you can directly opt-out of TRUSTX facilitating interest-based advertising.

We honor the Do Not Track (DNT) signal, which can be turned on or off in your browser. When the DNT signal is on, we will treat your browser as if you have opted out of interest-based advertising.
You may opt-out by clicking this Do Not Deliver Interest-Based Advertising link, which will set a TRUSTX opt-out cookie on your browser. The opt-out cookie is unique to the device through which you have opted-out, and there are cases where the cookie may not function properly if you have configured your browser to reject certain cookies. Further, if you change browsers or your device, or delete the cookies on your device, you will need to opt-out again

Even if you opt-out of interest-based advertising with TRUSTX, you may still receive interest-based advertising when browsing our publishers’ websites unless you use the other choice mechanisms we outline in our detailed Privacy Policy and in our publisher members’ privacy policies.

Want to understand more about your privacy choices?

We encourage you to read our Privacy Policy. And if you have any questions about privacy and your choices, please contact us via email at privacy@trustx.org or at the following address:
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TRUSTX Digital Advertising Services, Inc. PBC
Attention: Chief Privacy Officer
530 Seventh Avenue, Floor M1
New York, NY 10018
United States of America

TRUSTX PRIVACY POLICY

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Effective Date: January 1, 2020

Introduction and Overview

This Privacy Policy describes how TRUSTX Digital Advertising Services, Inc. PBC (“TRUSTX,” “we,” “our,” or “us”) collects, uses and shares information about you. It also explains your rights and choices about such use and sharing. This policy applies primarily to the TRUSTX Digital Advertising Marketplace, inclusive of all features and other services that we own, control and make available through the Marketplace (collectively, the “Services”).

The privacy policies that follow explain how TRUSTX employs technology to facilitate automated digital advertising buying and selling, how you, as a user of our Service, may control data we collect and use, and how you can take more control of your digital privacy.undefined

It’s important to note that we may use information about you to fulfill any other purpose, business or commercial, disclosed to you and with your consent. We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law.

Information We Collect in the TRUSTX Marketplace

We provide Services for our publisher members and collect and process various data, including personal information, at the direction of our publisher members (“Publisher Data”)

Publisher Data has historically included service use data, device connectivity and configuration data, location data, demographic data, content, and other non-personal information. Our processing of Publisher Data is governed by the terms of our service agreements with our publisher members, and not this Privacy Policy. We take full responsibility for the Publisher Data we collect in order to perform the Services, however, are not responsible for how our publisher members treat the information they collect directly. We recommend you review their privacy policies.

In the delivery of advertising through the Services, TRUSTX may independently collect information that is linked or reasonably linkable to a particular computer or device, such as: browser and device information; IP address; time spent on a particular webpage, pages visited including the analysis of the content contained on such pages, language preferences, date and time an ad was served, clicks on ads, and other traffic data; general location inferred from IP address; unique identifier, including operating system type and version.

TRUSTX engages a limited number of third-party service providers who may also collect this information through a variety of ways, including via your browser or device; or your mobile advertising identifier, such as Apple’s IDFA and Google’s Android Advertising ID. These providers may use statistical identifiers (which collect and use certain characteristics of your device to help us identify it over time); may evaluate your use of the apps; use pixel tags and other similar technologies; and collect and evaluate your IP address and cookies.

How We Use Information

We use Publisher Data for the following purposes as specified by our publisher members:

to operate, improve, analyze and manage the Services for our publisher members;
for our publisher members’ advertising business purposes, such as fraud prevention, billing, logging the number and type of ads served on a device to cap the number of times a consumer sees an ad or to sequence ad creative (aka “frequency capping” and “ad sequencing”);
to measure and report on the success of marketing campaigns via pixel tags (also known as web beacons and clear GIFs); and
on their behalf, to enable our publisher members to offer, and our advertising partners to buy, interest-based advertising.

We also use Publisher Data and the information we directly collect for our legitimate business interests, some of which are “business purposes” under California law, including:

To operate and improve the Services;
To use aggregated information to compile statistics and conduct research for our internal business purposes;
To prepare reports that summarize advertising activity;
To enable advertising frequency or sequencing controls;
To measure and report on ad viewability;
To analyze and report on ad performance (such as tracking ad views or click-through rates), campaign reporting and campaign forecasting; and
To identify, investigate and prevent fraudulent, unauthorized or illegal activity.

Sharing Your Information

We share information collected in connection with the Services in the following two ways:

With select third-party service providers for measurement, fraud and malware prevention and ad verification purposes. We have agreements with these third-party service providers that compel them to treat information we share as confidential, and to process such information solely to provide us with the services for which we have contracted. For a list of the third-party service providers we use in connection with the Services, please contact us at privacy@trustx.org.
With demand-side platform providers, to enable our publisher members to offer, and our advertising partners to buy, interest-based advertising. These demand-side platform providers may make certain information available to their media buying clients (e.g., advertisers) who may use it to make decisions regarding buying advertising inventory, and to analyze the effectiveness and performance of their advertising campaigns.

Your Rights and Choices

You have the right to opt-out of having your personal information used for the delivery of interest-based advertising. There are a number of ways in which you can exercise this right.

Directly with any of our publishers: TRUSTX requires that our publishers post a clear and conspicuous privacy policy that includes explicit instructions on how to opt-out of interest-based advertising. These policies are generally available on all content pages where personal information is collected or used.
By enabling the Do Not Track setting in your browser: Most web browsers offer users the opportunity to set a Do Not Track (“DNT”) flag, which sends a signal to online adverting technology companies, like TRUSTX, not to collect or use information associated with the browser for interest-based advertising purposes. TRUSTX respects this signal. When the DNT signal is on, we will treat your device as if you have opted-out of the collection or use of any personal information for interest-based advertising.Please note that while TRUSTX will observe your DNT settings, each of our publisher members may or may not elect to comply with DNT, as may be described in each publisher’s privacy policy.
By declining or deleting cookies: You can instruct your browser, by changing its settings, to decline or delete cookies. Most browsers accept cookies by default. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
By resetting your mobile device’s advertising ID: You can do this at any time through your device settings, which allows you to limit the use of information collected about you. For information on how to this on Apple or Android devices, please visit your device manufacturer’s websites.
By opting-out through the DAA AdChoices or NAI Opt-Out Programs: We require our publishers and advertisers to comply with the Digital Advertising Alliance AdChoices program, an industry self-regulatory program that allows consumers to opt-out of the use of cookie and non-cookie-based information for the purpose of delivering interest-based advertising. You can read more about the DAA AdChoices program and how to opt-out of interest-based advertising here. You may read more about the Network Advertising Alliance’s opt-out choices here.
By opting-out with TRUSTX directly: Clicking this Do Not Deliver Interest-Based Advertising link sets a TRUSTX opt-out cookie on your browser. The opt-out cookie is unique to the device through which you have opted-out, and there are cases where the cookie may not function properly if you have configured your browser to reject certain cookies. Further, if you change browsers or your device, or delete the cookies on your device, you will need to opt-out again.

California residents and data subjects in Europe have additional rights as set forth in the section below entitled “Additional Disclosures for California Residents.”

TRUSTX as a Limited Service Provider, Third Party and Data Processor

When TRUSTX provides Ad Marketplace services to publishers, we may use personal information provided by publishers to facilitate the delivery of interest-based advertising. Our role, with respect to personal information, is defined under various laws in different parts of the world.

In the United States, in accordance with the CCPA, TRUSTX acts as a limited service provider, or a third party, with respect to your personal information, depending on the circumstances. We operate on behalf of publishers, each of whom are separate legal entities.

You have the right to opt-out of having your personal information used for the delivery of interest-based advertising. There are a number of ways in which you can exercise this right.

The European Union (“EU”) data protection law (the General Data Protection Regulation, or GDPR) makes a distinction between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). TRUSTX currently does not provide the Services to our publishers in jurisdictions covered by the GDPR, however, at such time that the Services are made available in these jurisdictions, the TRUSTX will act as a processor with respect to your personal data. We will continue to operate on behalf of a publisher, a separate legal entity, which is the data controller.

California law defines personal information a little differently than EU law defines personal data, but both are subject to this policy. When we refer to personal data or personal information throughout our policies, we mean to include anything covered by either term under applicable law.

Outside of our Ad Marketplace, there are circumstances where TRUSTX may act as a first party or data controller with respect to personal information collected on our website or for our own marketing purposes. For more details, please see the section entitled, “When TRUSTX is a Marketer,” further below.

Additional Disclosures for California Residents

If you are a California resident, you have the right to know certain information about our data practices in the preceding twelve months, the right to request more details about the personal information we have collected about you, and the right to delete the personal information we have collected from you. If you would like to exercise any of these rights, please see our California Consumer Rights policy for instructions on how to do so.

Additional Disclosures for European Residents

Please note that if you live in certain jurisdictions, such as the European Economic Area (“EEA”), the United Kingdom (“UK”) or Switzerland, you also have certain rights and protections under the law regarding the collection, processing, and use of information about you. However, at this time, TRUSTX does not operate in any of these jurisdictions and thus does not collect or process any information subject to privacy and data protection laws in these jurisdictions. When TRUSTX expands our geographic Services footprint to include jurisdictions subject to laws, such as the GDPR, we will update our Privacy Policy accordingly.

Do Not Sell My Personal Information

To the extent TRUSTX sells your personal information as the term “sell” is defined under the California Consumer Privacy Act, you have the right to opt-out of the sale of your personal information by us to third parties at any time. TRUSTX provides this right to all users, irrespective of the jurisdiction in which you live.

You may opt-out by clicking Do Not Sell My Personal Information.

If you select to opt-out, TRUSTX will set an opt-out cookie on your browser. This cookie is unique to the device through which you have opted-out, and there are cases where the cookie may not function properly if you have configured your browser to reject certain cookies. Further, if you change browsers or your device, or delete the cookies on your device, you will need to opt-out again.

Even if you opt-out of the sale of your personal information by TRUSTX, you may still receive interest-based advertising from our publishers unless you use the other choice mechanisms identified in this privacy policy and in our publisher members’ privacy policies.

You will continue to receive contextual and other advertising even if you opt-out of interest-based advertising.

Do Not Deliver Interest-Based Advertising

You have the right to opt-out of the use of your personal information for the delivery of interest-based advertising by clicking Do Not Deliver Interest-Based Advertising.

Even if you opt-out of interest-based advertising with TRUSTX, you may still receive interest-based advertising from our publishers who use other digital advertising marketplaces. You may need to use other choice mechanisms identified in this Privacy Policy and in our publisher members’ privacy policies to more completely opt-out of interest-based advertising.

You will continue to receive contextual and other advertising even if you opt-out of interest-based advertising.

Authorized Agent

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment by us for the exercise of any of your rights. In the delivery of advertising through the TRUSTX Marketplace Services, TRUSTX may collect information that is linked or reasonably linkable to a particular computer or device, such as: browser and device information; IP address; time spent on a particular webpage, pages visited including the analysis of the content contained on such pages, language preferences, date and time an ad was served, clicks on ads, and other traffic data; general location inferred from IP address; unique identifier, including operating system type and version.

We and our third-party service providers may collect this information in a variety of ways, including through: your browser or device; your mobile advertising identifier, such as Apple’s IDFA and Google’s Android Advertising ID; the use of statistical identifiers (which collect and use certain characteristics of your device to help us identify it over time); your use of the apps; the use of pixel tags and other similar technologies; your IP address; the aggregation of information; HTTP entity tags and web cache; and cookies.

Children’s Privacy

We do not intentionally gather personal information from visitors to the Site or through the Services who are under the age of 16. If we learn that a child under 16 submits personal information to us, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 16, please contact us at privacy@trustx.org.

When TRUSTX is a Marketer

As a business, TRUSTX may collect and use personal information from clients and business partners, and in some cases, may also collect personal information through web forms for its own marketing purposes. In these cases, TRUSTX acts as a data controller with respect to personal information collected.

In addition to data you provide to us explicitly, when you browse our website at trustx.org or respond to an email communication, we may also collect contact data, IP address, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. We use this information to enable communications about our Services to our clients and business partners, as well as to analyze trends, and to administer, protect and secure the Services.

You may opt out of the use of your personal information through opt-out links provided when we send list-based email communications. You may opt out of individual communications by request simply by replying, or by sending a separate email to privacy@trustx.org.

International Visitors to the TRUSTX.org Website

If you are a non-U.S. user of the Site, by visiting the Site and providing us with information, you acknowledge and agree that your personal information may be processed for the purposes identified in this policy. In addition, your personal information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. By providing your information, you consent to such transfer.

Data Security

We implement and maintain a requisite level of administrative, physical, and technical security safeguards to help protect your information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information.

Changes

This policy may be updated from time to time by us. We will notify you of any changes to our policy by posting the new policy and changing the “Last Updated” date above. We recommend you consult this page regularly for any changes.

Contact Us

If you have any questions about privacy and your choices, please contact us via email at privacy@trustx.org or at the following address:
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