Last Modified: February 27, 2020
At Trancos, Inc., or any of its subsidiaries, including Freeflys, CoregMedia, Adfish, Trancos affiliate networks (“Trancos,” “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, Trancos creates results for advertisers and publishers in revolutionary ways without compromising individual privacy.
If you have questions or concerns regarding this statement, please contact us by emailing: firstname.lastname@example.org
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.
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.
|Information Collection: PII||We do not collect PII except as expressly provided for herein. For example, PII may be collected should a consumer contact Trancos 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, our subsidiaries and affiliates, third party marketing partners, business partners and our clients and publishers, and as expressly provided for herein.|
|Your Choices||You may regulate the collection and use of Non-PII via the opt-out options provided herein or by uninstalling or electing not to install a web browser or mobile application.|
|Security||We use reasonable and appropriate security measures to protect your data.|
|Retention||We retain online 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.|
WHAT TRANCOS DOES
While you may only visit certain websites and mobile applications, there are other companies working behind the scenes to help provide you with a great digital experience. These third party companies provide vital services such as analytics, advertising and fraud prevention for retailers, publishers, and other organizations. These services enable these third party companies 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 digital advertising on browsers, mobile applications and televisions, and we do it in a variety of ways, from banner and video ads to coupon codes. To make some of these things possible, we need to utilize information to provide smarter decision making. Technologies such as cookies and mobile device IDs enable companies like ours to provide more relevant advertising while keeping your identity anonymous to Trancos.
PRIVACY BY DESIGN
Our philosophy on privacy 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 Trancos’s 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 and mobile applications. Ensuring the protection of privacy throughout the entire lifecycle of the data is of the utmost importance, and we are 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 tailored to consumers’ interests.
Trancos 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 interest-based advertising (“IBA”).
INFORMATION COLLECTION AND USE
Information Collected by Trancos
Trancos 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 similar Non-PII from third parties, which may additionally include the types of programming you view on your television. Some clients contribute PII such as your name, address, email address, and associated transactional information directly to a third party with whom Trancos has a contractual relationship. This third party removes the PII data points and provides Trancos only the Non-PII for our use in providing advertising to you. All Non-PII received and collected by Trancos from the various sources may be combined and used to provide you relevant advertising, and for other purposes as determined by Trancos.
“Device IDs” are unique identifiers associated with your mobile device to be used for advertising. These identifiers are assigned by your mobile device operating system, such as Apple’s iOS and Google’s Play Services for Android, and do not reveal your identity. Device IDs can be reset in your mobile device settings.
“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.
“Location Data” recognizes a consumer’s location while they are on their device which is utilized by Trancos to deliver advertisements. As with all data Trancos collects, this is limited to non-precise as defined by the Network Advertising Initiative’s current definition of imprecise location data unless the consumer has opted in to allow their precise location to be used for IBA.
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 Trancos’s services. Trancos may also act as a delivery agent when its products and services are used directly by a client to facilitate advertisements and other communications.
Trancos supports the NAI Code of Conduct’s obligations around the collection and use of health information for interest-based advertising. This health-related information, when collected and/or used for relevant advertising, is non-sensitive and consumers may exercise choice through an opt-out basis. The NAI also permits Trancos to collect and use sensitive health information when the user provides explicit opt-in consent in the United States.
When a consumer responds to or views an Internet advertisement served by Trancos (such as through third-party websites or email solicitations) or visits a Trancos 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 Trancos 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, Trancos is able to continue to track the user’s activities (excluding PII) on the advertiser’s site and credit the third-party website that referred the user. In other words, if a user reads a blog about a pair of shoes and decides to visit that advertiser’s website and purchase that pair of shoes, we would ensure that the blog gets compensated for referring the user to that advertiser’s website.
We also may use Internet browsing, cross-mobile application browsing and online purchase data associated with a user, on a Non-PII level, across multiple devices to develop a predictive statistical user profile of the end user’s needs and interests for the purpose of sending them relevant advertisements on multiple browsers and devices. This is called cross-device IBA. We may also use this cross-device functionality for the purpose of more accurately paying third-parties affiliate commissions, as described in the paragraph directly above.
Information Sharing by Trancos
In the event that Trancos 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 Trancos 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 Trancos,” 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.
Trancos 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 Trancos entities and third parties.
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 Trancos to unlawfully intercept or access transmissions or private communications. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. Trancos cannot ensure or warrant the security of information you transmit to us. You acknowledge and assume this risk when communicating with Trancos.
We retain online 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 support members of industry groups such as the Network Advertising Initiative (NAI), Interactive Advertising Bureau (IAB), Digital Advertising Alliance (DAA) and Digital Advertising Alliance of Canada (DAAC) 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.
Trancos supports these and other groups, and where Trancos engages in activities regulated by these programs, we comply with the NAI Codes of Conduct. We also support the DAA Self-Regulatory Principles and the DAAC Self-Regulatory Principles.
We will attempt to opt you out across all of your browsers and devices. However, since we don’t collect data which directly identifies you, we cannot guarantee that all of your browsers and devices will be opted out. To ensure you are opted out across all of your browsers and devices, we recommend that you opt out of each one individually. If cookies aren’t enabled in your browser or if you’re using ad-blocking tools, our opt-out mechanism may not work.
Please note that opting out does not necessarily mean that you will no longer receive any advertising from Trancos, it means that you will no longer receive advertising tailored to your interests.
Trancos 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 follow the opt-out instructions provided above.
To learn how to opt out receiving relevant advertisements on mobile applications, please visit this page: http://www.networkadvertising.org/mobile-choices.
USE OF THE TRANCOS SITES AS A VISITOR OR CLIENT
You can browse the Trancos 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 Trancos, responding to an advertisement for Trancos, 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.
Trancos 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, Trancos and its subsidiaries and affiliates, third party marketing partners, our clients and publishers, and as expressly provided for herein.
For Clients and Publishers
The Trancos 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 Trancos 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-Trancos 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 Trancos 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. Trancos may, from time to time, use “gallery” pages to identify clients or publishers by business identity ONLY (e.g. freeflys.com is a new Publisher in the Trancos 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. We me also email individuals that have provided us with their contact info so that we can communicate information about Trancos’s services. You can request to opt out of these emails by emailing: email@example.com
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.
Have a question on something not addressed or have a complaint? Please use email: firstname.lastname@example.org
CALIFORNIA PRIVACY RIGHTS
NOTICE TO CALIFORNIA RESIDENTS – CALIFORNIA CONSUMER PRIVACY ACT
In the below tables and sections, we describe (as required by the CCPA):
- Our Collection of Personal Information – the types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from,
- Our Disclosure and Sale of Personal Information – the types of recipients to whom we disclose or sell Personal Information.
- Our Business Purposes – our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.
- Your California Privacy Rights and Choices – what rights you have under the CCPA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights), or to request categories and personal information that we may have collected about you.
The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information:
1. OUR COLLECTION OF PERSONAL INFORMATION
Depending on how you interact with us, we may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.
|Category||Categories of Sources|
|Identifiers, e.g., obfuscated name, obfuscated address, obfuscated email address, obfuscated phone number, online identifiers, and IP address.||
|Categories of personal information described in Cal. Civ. Code Â§ 1798.80(e). e.g., estimated household income||
|Characteristics of protected classifications under California or US law|
E.g., race; sex/gender; marital status; medical condition; and age.
|Commercial or transactions information|
E.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
|Internet or other electronic network activity information|
E.g., browsing history; search history; online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer’s interaction with a website, application, or advertisement.
|Professional or employment-related information|
E.g., current or past job history
2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION
We will share the information collected from and about you as discussed above for various business purposes, with service providers and with third parties including our customers. The chart below how and with whom we share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.
|Category||Categories of Third Parties||We Share With Whether We “Sold” This Category of Personal Information in the Last 12 Months|
|Identifiers, e.g., obfuscated name, obfuscated address, obfuscated email address, obfuscated phone number, online identifiers, and IP address.||Advertising networks, advertisers, and publishers||Advertising networks, advertisers, and publishers|
|Characteristics of protected classifications under California or US law|
E.g., race; sex/gender; marital status; medical condition; and age.
|Commercial or transactions information. E.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||Advertisers and publishers||Advertisers|
|Internet or other electronic network activity information. E.g., browsing history; search history; online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer’s interaction with a website, application, or advertisement.||Advertisers and publishers||Advertisers|
|Geolocation data||Advertising networks, advertisers, and publishers||Advertisers|
|Professional or employment-related information|
E.g., current or past job history
We also may share any of the personal information we collect as follows:
Sharing In Event of a Corporate Transaction: We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.
Sharing With Service Providers: We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use (“Aggregate/De-Identified Information”) for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.
3. OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION
Our Purposes for collecting, using and sharing Personal Information
Online targeting, for example:
- Helping clients to target ads to online audiences based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., consumers interested in winter apparel). When we do this, we handle information provided by our Clients (for instance, their own customer files) and “match” their information through pseudonymization techniques (such as through coded data “hashing”) with online cookies and other identifiers. We then use these cookies and identifiers to target and measure ad campaigns online across various display, mobile and other media channels.
- Assisting Clients by creating “identity” graphs, to help locate users across various channels, such as connecting identities based on common personal, device-based, or network-based identifiers (e.g., IP address, email address).
Additional marketing and analytics services, for example (which may overlap with “Online targeting,” above):
- Assisting in targeting and optimizing of direct mail and email campaigns, display, mobile and social media marketing.
- Measuring the effectiveness of online or offline ad campaigns by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases.
- Analyzing and optimizing our Clients’ (or their service providers’) proprietary databases, or helping Clients to identify and mitigate potential fraud.
- Providing “verification” or data “hygiene” services, which is how companies update and/or “clean” their databases by either verifying, updating, removing or correcting old, incorrect or outdated information.
- In addition, for own our corporate purposes, we sometimes use personal contact information such as name or email address to contact businesses that we believe may benefit from using our services.
Operating our Services, for example:
- Improving, testing, updating and verifying our own data and data services.
- Developing new products.
- Operating, analyzing, improving, and securing our Services.
Other internal purposes, for example:
For internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance. We use the information collected from our own website for the above, as well as for our own marketing purposes.
4. YOUR CALIFORNIA RIGHTS AND CHOICES
Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests, to the extent as act as a “business” (as opposed to a “service provider”) for purposes of handling personal information. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.)
a. Right to Opt-out of the sale of your personal information.
California residents may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” – including in the definition making available a wide variety of information in exchange for “valuable consideration.” We may act as a “business” or a “service provider” under the CCPA. When we act as a business under the CCPA, you may “opt out” of our “sale” of your personal information (as those terms are defined by the CCPA) by emailing: email@example.com. Please note that this is not an opt out of interest-based advertising. To opt out of interest-based advertising, please visit the Network Advertising Initiative.
b. Right to request deletion of your personal information
You may also request that we delete any personal information that we collected from you, including data provided to us by our clients. (Note that this is different from your right to “opt out” of us selling your personal information, which is described above; also note that we do not generally collect personal information directly from consumers, in which case “deletion” rights generally do not apply.) However, we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations, and (f) as necessary to comply with client contracts, including allowing advertisers to properly compensate publishers for driving traffic to their web properties. California residents can delete your personal information by emailing: firstname.lastname@example.org or by contacting us at (925) 249-7110.
c. Right to request access to your personal information
California residents also have the right to request that we disclose what categories of your personal information we collect, use, or sell. As a California resident, you may request access to the specific pieces of personal information that we have collected from you. California residents can access their personal information by emailing: email@example.com or by contacting us at (925) 249-7110.
However, we may withhold some personal information where the risk to you or our business is too great to disclose the information, or where we cannot verify your identity in relation to such personal information. Thus, for security purposes (and as required under California law), we will verify your identity – in part by requesting certain information from you — when you request to exercise certain of your California privacy rights.
- The categories of personal information that we have collected about you.
- The categories of personal information that we have sold.
If we are unable to complete your requests, we will provide you additional information about the reasons that we could not comply with your request.
d. Right to nondiscrimination.
We do not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.
e. Information About Persons Under 16 Years of Age
We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).
f. Authorized Agents
You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.