Effective Date of Current Policy: January 24, 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.
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. 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. 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.
The Tracking Technologies used by our Platforms
Our Platforms may utilize tracking technologies such as pixel tags, 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, installed fonts, 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/#!/.
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. Where we are acting as an agent 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:
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.
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 or http://www.aboutads.info/choices/.
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 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 email@example.com, and we will process your request. We will respond to your request to access within a reasonable timeframe.
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.
Our Websites may Contain Links to Other Websites.
Contact Bounce Exchange Regarding Our Privacy Practices.
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.