Privacy policy

Effective Date: July 23, 2018

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 as well as your rights and choices about such use and sharing. This policy applies to your use of the trustx.org website (the “Site”) and any other online service location that posts a link to this Privacy Policy. It also applies to all features, content, and other services that we own, control, and make available through such online service locations (collectively, the “Services”). In addition, this Privacy Policy describes how we use data to provide the TrustX Marketplace Services to our publisher members.

When TrustX is a Data Controller or Data Processor

EU data protection law 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 may act as either a controller or a processor in respect of your personal data, depending on the circumstances.

TrustX, located at the address in the section entitled “Contact Us” below, is the controller with respect to information you provide through the Site.

More often TrustX operates as a processor on behalf of a publisher member, a separate legal entity, which is the data controller. TrustX provides advertising exchange services to its publisher members and processes personal data on their behalf to help them engage in targeted digital advertising. Please visit the applicable publisher’s privacy policy for information about their privacy practices. Any questions that you may have relating to such personal data and your rights under data protection law should therefore be directed to the publisher as the controller, not to TrustX.

A Little About Digital Identifiers and Tracking Technology

Many commercial websites and programmatic marketplaces employ one or more Digital Identifiers in conjunction with user tracking technologies, which are essential for measurement and verification, and can also be used to enable interest-based advertising. Below is a brief summary of the Digital Identifiers and tracking technologies TrustX may employ in conjunction with our publishers and demand partners, along with a brief explanation of each.

  • “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
  • “Log files” track actions occurring on sites. Logs may include IP addresses, browser types, Internet service provider identifiers, referring/exit pages, platforms and device types, date/time stamps, and impression and click data.
  • “Web beacons” or “tracking pixels” are electronic files used to track user navigation and browsing behavior within and across website. They can also be used to verify the completion of transactions, or to connect advertising exposure with a conversion (e.g., purchase).
  • Device fingerprinting is the process of analyzing and combining sets of information elements from your device’s browser and other device-specific information in order to uniquely identify your device.
  • In the context of user tracking, software development kits (SDKs) are code that can be used to send information about your use of a web or mobile app to a server. An SDK can, in effect, enable the app version of a tracking pixel. These SDKs allow companies like ours to deliver advertising both on and off the Service, to track conversions and for other measurement and verification purposes.
  • GPS, WiFi, Bluetooth, and other location-aware technologies may be used to collect precise location data when you enable location-based services through your device. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.

The privacy policies that follow explain how TrustX employs these technologies, how you, as a user of our site and Service, may control data we collect, and other information to help you take control of your digital privacy.

Your Privacy Choices when you Visit the TrustX Website

Information We Collect on Our Site

Similar to most commercial websites, we collect information about how our website is used. Some of this information, including, for example, your IP addresses and certain unique device identifiers, may identify a particular computer or device, and may be considered “personal data” in some jurisdictions in the European Union and elsewhere. The website usage information we collect may include the following: IP address, MAC address, device advertising ID (e.g., IDFA or AAID), domain, browser type and language, referring website addresses, date/time of visits, page view data, the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, data about your device’s location (which can be precise such as latitude/longitude data or imprecise such as location derived from an IP address or data that indicates a city or postal code level), and search keywords. In this privacy policy, we refer to this information as “Digital Identifiers,” which we have described above.

In addition, when you visit our Site you may optionally choose to submit information such as contact information, demographic information, and/or questions. In so doing, you may provide us with personal information about you that you knowingly choose to disclose, such as name and email address, and of course, the content of your question. You may choose to voluntarily submit such information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.

How We Use Information

We and our third-party service providers may use personal information you provide for our legitimate interests, including:

  • to respond to your inquiries and fulfill your requests;
  • to send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies;
  • to alert you of TrustX developments we believe may be of interest to you;
  • for our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services and identifying usage trends; and
  • to prevent and address fraud, breach of policies or terms, and threats or harm.

We also use information about you to fulfill any other purpose 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.

For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.

Sharing Your Information

We share information collected on the Site with:

  • a very limited number of third-party service providers (“Service Providers”) who assist with the operation of our Site. Service Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes;
  • with our subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy;
  • third parties, in connection with any transaction in which we raise money or transfer all or a portion of our business or assets;
  • with third parties for purposes of facilitating your requests (such as when you choose to share information with a social network about your activities on the Service) and in measuring and improving our Service;
  • Law enforcement agencies and others in conformance with applicable law or to respond to subpoenas or warrants served on us;
  • with third parties to protect or defend our rights and property or those of our users, and to investigate or assist in preventing any violation or potential violation of the law or our terms, conditions, and policies; and
  • with third parties for any other purpose disclosed to you and with your consent.

Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.

Other Parties

In connection with the operation of the Site, we may allow analytic services who use cookies and other technologies to analyze how users use the Site.  These companies use the information collected on our Site in accordance with their own privacy policies.  For a list of such companies, please contact us at: info@trustx.org.

Your Privacy Choices when you Visit a Website that uses TrustX Marketplace Services

Information We Collect in the TrustX Marketplace

We provide products and services for our publisher members (“TrustX Marketplace Services”), and collect and process information about individuals (including through tracking technologies) at the direction of our publisher members (“Publisher Data”). Publisher Data has historically included contact data, demographic data, content, service use data, device connectivity and configuration data, and location data, among other information. Our processing of Publisher Data is governed by the terms of our service agreements with our publisher members, and not this Privacy Policy. To the extent we combine Publisher Data with information we have collected about you through the Service, we will treat the combined information in accordance with the practices described in this Privacy Policy, plus any additional restrictions imposed by our publisher members. We are not responsible for how our publisher members treat the information we collect on their behalf, and we recommend you review their privacy policies.

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.

How We Use Information for our Publisher Members

We use Publisher Data:

  • to operate, improve, analyze and manage the TrustX Marketplace Services for our publisher members;
  • for our members’ advertising 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
  • to enable our publisher members to offer, and our advertising partners to deliver, interest-based advertising. (To learn more about your advertising choices, see Consumer Privacy and Your Choices

Sharing Your Information

We share your information collected in connection with the TrustX Marketplace Services that we provide to our publisher members in the same ways that we share your information collected in connection with the Site, and in the following additional ways:

  • with TrustX publisher members to allow them to analyze the effectiveness and performance of our TrustX Marketplace Services;
  • with our media buyer clients who use it in a number of ways including to allow them to make decisions regarding buying advertising inventory, and to analyze the effectiveness and performance of their advertising campaigns via our TrustX Marketplace Services;
  • and with our third-party service providers for measurement, fraud prevention and verification purposes.  For a list of the third-party service providers we use in connection with the TrustX Marketplace Services, please contact us at: info@trustx.org.

Your Choices

You may access, update, or remove certain information that you have voluntarily submitted to us through the Service by sending an e-mail to the e-mail address set forth in the section entitled “Contact Us” below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. California residents and data subjects in Europe have additional rights as set forth in the sections entitled “Your California Privacy Rights” and “Your European Privacy Rights” below.

Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. 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.

You can reset your device advertising ID at any time through your device settings, which is designed to allow you to limit the use of information collected about you. For information on how to do this on Apple devices, visit Apple.com or https://support.apple.com/en-us/HT202074. For information on how to do this on Android devices, visit Google.com. You can stop all collection of information via an app by uninstalling the app.

The location data collected through an app depends on your device settings and app permissions. You can exercise choice over the location data collected through many apps by (i) for GPS data, disabling location in your device settings or disabling location permissions to that app; (ii) for Bluetooth data, disabling Bluetooth and any Bluetooth scanning option in your device settings; or (iii) for WiFi data, disabling WiFi and any WiFi scanning option in your device settings. You can stop collection of all location data via an app by uninstalling the app.

You can opt-out of your data being used by Google Analytics through cookies by visiting https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.

In connection with the TrustX Marketplace, publishers and advertisers engage in interest-based advertising, which is the collection of information about viewing behaviors, over time, from one or more devices for the purpose of using such information to deliver advertising more likely to be of interest to the person using the device(s).   We require our publishers and advertisers to comply with the Digital Advertising Alliance Ad Choices program (the “Ad Choices 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 program and how to opt-out of interest-based advertising here.

Because we want to make it easy for consumers to exercise their choice, and for that preference to be persistent, we also 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 device as if you have opted out via the Ad Choices program. Please note that each of our publisher members may or may not elect to comply with DNT, as may be described in each publisher’s privacy policy.

Your California Privacy Rights

California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing.

TrustX may share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set forth in the section entitled “Contact Us” below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that TrustX is not required to respond to requests made by means other than through the provided e-mail address or mail address.

Your European Privacy Rights

If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

To exercise any of these rights, contact us as set forth in the section entitled “Contact Us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

TrustX acknowledges that you have rights in connection with Publisher Data. If your information has been processed by TrustX on behalf of a publisher member and you wish to exercise any rights you have with such information, please inquire with our publisher member directly. If you wish to make your request directly to TrustX, please provide the name of the TrustX member on whose behalf TrustX processed your information. We will refer your request to that publisher member, and will support them to the extent required by applicable law in responding to your request.

If you have any issues with our compliance, you have the right to lodge a complaint with a European supervisory authority.

Children’s Privacy

We do not intentionally gather personal information from visitors to the Site or Services who are under the age of 13.  If we learn that a child under 13 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 13, please contact us at: info@trustx.org.

International Visitors

If you are a non-U.S. user of the Site or Services, by visiting the Site or Services 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 reasonable 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: info@trustx.org or at the following address:

TrustX Digital Advertising Services, Inc. PBC
Attention: Chief Privacy Officer
530 Seventh Avenue, Floor M1
New York, NY 10018
United States of America