Effective Date of Current Policy: JULY 12, 2018
Bounce Exchange is a member of the Internet Advertising Bureau and Network Advertising Initiative (“NAI”) and adheres to the NAI self-regulatory codes and the Digital Advertising Alliance self-regulatory code and the IAB Europe OBA Framework.
The Types of Information that We Collect
We collect two types of information from visitors to our Websites: personally identifiable information and pseudonymous information. Personally Identifiable Information (“PII”) is information that may be used to identify or locate an individual and includes email address, telephone number or postal address. We generally don’t collect PII via the Websites unless it is provided to us.
For example, if you purchase our products or services we may request certain personally identifiable information from you on our order form. This includes contact information such as your name, email address, and address, as well as financial information such as a credit card number and its expiration date. We use this information for billing purposes and to fill orders. If we have trouble processing an order, we also will use this information to contact you.
In addition, if you contact us by email or otherwise provide your email address to us through our Websites, we may keep a record of your contact information and correspondence. We reserve the right to use your email address and any other PII that you provide to us to respond to your inquiries and to send you marketing materials for our own products and services. We also reserve the right to share contact information you provide to us in connection with accessing certain content through our Websites (for example, webinars with industry partners) to our production partners or sponsors of such content. We will not otherwise share your contact information with outside parties for the purposes of marketing other products and services to you without your consent.
We also collect pseudonymous information via the Websites such as the name of your internet service provider, the IP address of the computer or device you are using, the type of browser and operating system that you use, the date and time you access our Websites, the website referrer address and other log file information. Like most websites, our Websites use “pixel tags”, “web beacons”, “cookies” and/or similar tracking technologies that allow us to track the actions of visitors to our Websites as described here. We use this information to help us improve our Websites and the products, services, applications, content and features that we provide. We reserve the right to aggregate this information with similar data collected from other visitors to the Websites for any purpose, including publishing aggregate statistics about our Clients’ and/or Websites’ visitors.
The Ad Serving Platform
The Bounce Exchange ad serving Platform does not intentionally collect PII. The type of pseudonymous information collected via the ad serving Platform includes IP address, browser type, operating system, Internet Service Provider, referrer address, the time/date an ad is served and the site or mobile app that the ad is served in addition to other log file information. This information is used to offer products and services designed to help our Clients better understand how their websites are being utilized, draw insights on how to better engage Users on their sites, to deliver more relevant advertising messages based upon the User visits to individual Client sites, and to provide Clients with ad delivery reports.
The Behavioral Automation Platform
Bounce Exchange collects email addresses and other PII such as telephone number via our behavioral automation Platform. We typically obtain this information from our Clients that collect it via online forms on Client websites or directly from Users via online forms on Client websites. Where requested by Clients and in accordance with applicable law, our systems may access this information upon each data points entry into a particular web form automatically. We combine this with pseudonymous information also collected via Client websites such as a Client’s User ID, mobile o/s advertising ID, hashed emails and/or other pseudonymous IDs to help our Clients with conversion tracking, site optimization and conversion. Bounce Exchange and our Clients may also use this information to send customized and retargeted email marketing messages to our Clients’ customers and prospective customers and we may use aggregate information to improve all of our Platforms, products or services.
The Data Onboarding Platform
As directed by our Clients, we may process information such as hashed email addresses, cookie IDs, mobile advertising o/s IDs and other pseudonymous identifiers. We use this information to help us understand whether two devices are likely to be used by the same User or household. For example, where a User opens an email and we are able to place a cookie on that User’s browser, we may be to determine that this was the same User that had recently visited and logged into our Client’s website. Once we’ve established that linkage, we may use the information across Clients to enable Clients to onboard demographic data and other data onto profiles linked to those pseudonymous identifiers. We also may enable Clients to leverage those pseudonymous identifiers to purchase advertising on digital media platforms. We are careful to segregate this data to ensure that neither Bounce Exchange nor our Clients are permitted to use information collected across non-affiliated Client sites and apps to personally identify and/or re-identify individual Users.
The Interest Based Ad Platform
Bounce Exchange also operates an Interest Based Advertising Ad Platform that enables our Clients to both create and utilize interest segments (e.g., frequent shopping, interest in fishing) from data collected across multiple non-affiliated websites or mobile apps. These segments are provided to us by Clients (and sometimes supplemented by third-party data partners) and attached to one or more pseudonymous identifiers described below for the purpose of delivering, customizing and reporting on advertising messages purchased via digital media platforms.
Profiles created by the BounceX Platforms
The BounceX platforms processes data to draw inferences about Internet Users based upon website visits and mobile app usage. Some of our platforms also help our Clients collect email addresses. We use the collected information to create profiles the help us help our Clients engage their site visitors and bolster their advertising programs. Some examples of behaviors which generate profiles include: whether or not a visitor has visited a particular website, purchased something from that website, interacted with certain ads or other features placed on the website and/or submitted their email address to the website. We don’t create profiles which are considered sensitive or high risk under applicable law, but the profiles created by our platforms enable our Clients to offer a more engaging experience when you visit their websites.
The Tracking Technologies used by our Platforms
Our Platforms may utilize tracking technologies such as pixel tags, HTML5 cookies, HTTP cookies, web beacons, statistical identifiers, and mobile o/s advertising identifiers such as Apple’s IDFA, the Android Advertising ID and other pseudonymous information. For more information about cookies and web beacons, please visit allaboutcookies.org. Statistical identifiers are created when our systems read pseudonymous information about your computer or device, including the user agent, IP address, and the browser and operating system of your computer and device. Statistical identifiers enable our systems to determine within a reasonable level of certainty that they are encountering the same computer or device, including in environments where third-party cookies are not supported. If you want to see whether our Platforms are using a statistical identifier on the browser you are currently using, please visit http://optout.networkadvertising.org/#!/. If you would like to reset the value of this identifier, you may do so here. More information on this reset functionality under “choice mechanisms” below.
How We May Transfer the Information We Gather to Third Parties
Generally, we will not disclose the PII that we collect through your use of our Websites to unaffiliated third parties without consent. We reserve the right, however, to provide such information to our employees, contractors, agents, and designees to the extent necessary to enable them to perform certain services for us, including order fulfillment and Websites-related services such as web hosting, to improve Websites-related services and features, to perform maintenance services, to distribute advertisements and other marketing materials on our behalf and to host our data. BounceX may transfer data collected through BounceX’s website and marketing activities, to entities such as: (i) website analytics vendors, who collect cookie and website engagement information to help understand website performance, (ii) advertising vendors, who collect cookie and website engagement information to target relevant advertising, and (iii) email marketing and lead database vendors, who collect email address and other personal information to improve email marketing efforts
Our platforms are designed to interact with a number of other affiliated technology platforms as described here. Where we are acting as an agent (i.e., a data processor) for our Clients, we will transfer information as directed by such Clients. This collection and use is generally subject to our respective Clients’ privacy policies, not ours. We also reserve the right to disclose any personally identifiable information that we collect to any third party if we believe that we are required to do so for any or all of the following reasons: (i) to comply with the law; (ii) to comply with legal processes or governmental requests including sharing data of EU and Swiss individuals in response to lawful requests from public authorities to meet national security and law enforcement requirements; (iii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of our Websites or our network; and/or (iv) to protect the rights, property, safety and security of Bounce Exchange and its employees, our Websites’ visitors, and/or the public. Finally, we may transfer information, including any PII, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change and will provide notice of such change on our Websites.
In cases of onward transfer to third parties of the personal data of EU and Swiss individuals received pursuant to the EU-US and Swiss-U.S. Privacy Shield, Bounce Exchange is potentially liable.
Bounce Exchange supports high standards for digital privacy. We enable Users to opt-out from our Data Onboarding Platform and our Interest Based Ads Platform.
Web based Opt-Out Choice Mechanism. You can opt-out of our Data Onboarding Platform, and our Interest Based Ads Platform on your browser as follows:
- You can visit the Network Advertising Alliance self-regulatory opt-out page at http://optout.networkadvertising.org/#!/ to opt-out and to see whether Bounce Exchange is using a statistical identifier on the browser you are currently using. You should select the “opt out” button there for Bounce Exchange.
- You can visit the Digital Advertising Alliance self-regulatory program opt-out page at http://www.aboutads.info/choices. You should select the “opt out” button there for Bounce Exchange.
- EU data subjects may visit IAB Europe OBA Framework’s opt-out page at http://youronlinechoices.com/ and select Bounce Exchange.
- 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 DAA participating companies.
When you opt out via the web based choice mechanism, we will attempt to place a cookie that instructs us not to use information about your browser on our Data Onboarding Platform and our Interest Based Ads Platform.
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.
Statistical device ID reset. BounceX also creates a non-cookie based statistical device-level identifier which is used in cookie-challenged environments. Information collected as outlined in “The Types of Information that We Collect” may be associated to this identifier over time. If you would like to reset the value of this identifier, you may do so here. This will effectively remove any associations between the identifier and any data that BounceX has collected. Note that any new data collected after resetting your identifier may resemble data previously collected if you engage in similar activities on websites.
Mobile App Opt-out Choice Mechanism. 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 information collected about your mobile app usage on our Data Onboarding Platform and our Interest Based Ads Platform. This choice mechanism is only applicable to the apps you are using on your current mobile device.
Precise Location Choices. If you’d like to adjust your choices regarding the use of precise location data by third parties such as Bounce Exchange, 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.
Some of our Clients may utilize third-party advertisers on their websites. These third-party advertisers generally collect pseudonymous information across multiple non-affiliated websites and mobile apps to create interest segments for ad targeting and content customization purposes. This practice is sometimes referred to as interest based advertising (“IBA”) or online behavioral advertising (“OBA”) and is distinct from the Behavioral Automation Platform and Data Onboarding Platform offered by Bounce Exchange. To learn more about third-party advertising companies and your choices regarding how that information is used, please visit http://www.networkadvertising.org/managing/opt_out.asp, http://www.aboutads.info/choices/ or http://youronlinechoices.com/.
The World Wide Web Consortium (W3C) is attempting to develop a Do Not Track (DNT) standard. Currently, the standards regarding the DNT signals and appropriate responses are not generally accepted. Accordingly, we do not assign a meaning to DNT signals.
Bounce Exchange ensures that push marketing messages sent using our behavioral automation Platform contain a choice mechanism as required by applicable law.
Bounce Exchange adheres to the Children’s Online Privacy Protection Act. Our Websites are not directed at children. If we are made aware that we have received personally identifiable information from someone under 18, we will use reasonable efforts to remove that information from our records.
We are Committed to Making Sure Your Information is Protected
Our physical, electronic, and procedural safeguards meet or exceed current industry standards regarding the protection of the information in our systems. We also require contractors and outside companies who work with us to adhere to strict privacy standards through their contracts with us. Unfortunately, no security system, or system of transmitting data over the Internet, can be guaranteed to be 100% secure. Consequently, while we use commercially reasonable efforts to protect information in our systems, we cannot guarantee the absolute security of our servers, the means by which information is transmitted between your computer and our servers, or any information provided to us or to any third party through or in connection with the Websites or Platform. Any information that you provide to us is done so entirely at your own risk.
Data Minimization and Retention
Bounce Exchange has internal procedures which are designed to ensure that we only process the minimum data required. We retain the IBA data that we collect for up to 13 months from the date of collection. Cookies used for IBA expire 13 months after they are last updated. EU data subjects may have additional rights or information as described below.
Data Subject Access Rights
Upon request Bounce Exchange will provide you with information about whether we hold any of your PII. If you’d like to update, correct, delete, or deactivate any PII that you have provided to the company on this Website, please send your request to firstname.lastname@example.org, and we will process your request. We will respond to your request to access within a reasonable timeframe. EU data subjects may have additional access rights as described below.
In the Event We Engage in a Business Combination, We Reserve the Right to Transfer Any Information in Our Systems.
If we sell all or any part of our business or sell or transfer all or a material part of our assets or are otherwise involved in a merger or other transfer or disposition of any part our business, we reserve the right to access, transfer or disclose any and all information that we collect from our Websites’ visitors, or that we otherwise collect in connection with the Websites or Platform, to the party or parties involved in the transaction as part of that transaction.
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, port, restrict processing, correct and delete certain personal data processed by BounceX by visiting our EU data subject access request page. Moreover, with respect to EU data subjects, PII (sometimes referred to as personal data) includes pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID. Where BounceX is a processor of data (e.g., via the Behavioral Automation or Ad Serving Platforms), the legal basis for processing such data and the retention period is determined by our Clients. Where BounceX is a controller of data (e.g., via the Interest Based Advertising or Data Onboarding Platforms), the legal basis will be both legitimate interest (e.g., where we have evaluated that our interests are not overridden by Users’ fundamental rights) and consent depending on the type of information subject to processing and the information we receive from upstream partners. Where BounceX receives from an EU data subject a request to cease processing of data via one of the choice mechanisms listed above, BounceX will stop all data processing with respect to the opted out browser or device unless such processing is required by law and we use both HTTP and HTML5 opt-out cookies to record your objection in order to better protect it. BounceX’s Data Protection Officer is data protection officer and EU representative is Dr. Christoph Bauer, CEO at ePrivacy GmbH and he may be contacted at email@example.com.
Our Websites may Contain Links to Other Websites.
Contact Bounce Exchange Regarding Our Privacy Practices.
Ryan Urban, CEO
Bounce Exchange, Inc.
Attn: Privacy Officer
620 8th Avenue, Floor 21
New York, NY 10018-1618
Enforcement and Privacy Complaints by EU and Swiss Citizens
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.