WITHINSITES provides targeted advertising and marketing services for our clients (“Clients” or “Advertisers”).
Our products help show our clients’ ads to the people that are most likely to find them interesting. We aim to make advertising in the digital space more useful and relevant to consumers by showing ads based on keyword intent across digital channels. This data may come from outbound data mining, unique data partnerships with the world’s leading data companies and innovative data share agreements with publishers, SSP, Ad Exchanges and Ad Networks. All of this is used to make sure that users receive relevant ads at the right time.
To do this, when you visit a website or a mobile application operated by an Advertiser (collectively ”Digital Properties”), open an email from an Advertiser, or we serve you an ad on behalf of an Advertiser on a third party site, we may collect data as described in this Privacy Notice. Our platform uses that data, as well as other data described below, to help Advertisers provide ads to you that are more relevant to you.
For example, let’s say you just joined a local soccer club and are in the market for a new soccer ball. If you visit ACME Soccer Ball Co.’s website in search of the perfect soccer ball, but don’t purchase one just yet because you are still looking, we may later show you ACME Soccer Ball Co. ads to encourage you to come back and purchase one of their soccer balls, perhaps even with a discount offer or notice of an upcoming sale. We may also show you ads from ACME Soccer Ball Co. or other companies with additional product recommendations you may be interested in, such as for soccer cleats, or tickets to an upcoming soccer match, as you browse the internet.
We also provide various analytics to help advertisers measure whether their campaigns were successful or not — for instance, by measuring whether particular campaigns led to consumers taking a particular action, like buying a product or visiting a website (sometimes called a “conversion”).
We also monitor what IP address ranges visitors to our customers’ websites are from, match those IP address ranges to companies, and use that information to provide aggregated reports to companies regarding their website traffic.
Privacy and data protection
2. What Data We Collect
We collect the following categories of information for the purposes explained below.
Activity on Advertisers’ Digital Properties: This is data about your browsing activity on the Advertiser’s website or application. For example, which pages you visited and when, what items were clicked on a page, how much time was spent on a page, whether you downloaded a white paper on a business to business (“B2B”) website, what items you placed into your online shopping cart, what products were purchased and the price of the products purchased.
Device and browser information: This is technical information about the device or browser you use to access the Advertiser’s Digital Property. For example, your device’s IP address, cookie string data, operating system, and (in the case of mobile devices) your device type, and mobile device’s identifier (such as the Apple IDFA or Android Advertising ID, and any other unique identifier that may be assigned to the mobile device).
Ad data: This is data about the online ads we have served (or attempted to serve) to you. For example, how many times an ad has been served to you, what page the ad appeared on, and whether you clicked on or otherwise interacted with the ad. This data includes information about how well our clients’ ads and campaigns have performed, whether on our platform or on other platforms.
Data from Advertising Partners: This is data that we lawfully receive from other digital advertising companies that we work with (“Advertising Partners”) to help us deliver ads to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers (meaning identifiers that help identify your browser or device, but do not directly identify you as a person) which some Advertisers or other third party Advertising Platforms choose to share with us – for example, your “Customer ID” with an Advertiser, a pseudonymous identifier (such as a cookie) associated with a hashed version of your email address, or demographic data such as age range. We may work with our Advertisers and Advertising Partners to synchronize their unique, pseudonymous identifiers to our own to enable us to more accurately recognize a particular unique browser or device and the advertising interests associated with it.
Email and CRM data from Advertisers: Some Advertisers choose to share clear email addresses (as opposed to hashed email addresses, described below) or other contact information belonging to their customers with us, so that (with the help of Advertising Partners) we can help the Advertiser serve, measure and analyze targeted ads to customers. For example, if you have given ACME Soccer Ball Co. your email address, through our service, ACME Soccer Ball Co. may send you a promotional email for a soccer ball you looked at but did not purchase. Similarly if you provided your email to a software website when you downloaded a white paper, through our services the software company may send you a follow up email providing you with more information about the software company’s products or services. We use our Advertiser’s CRM Data (e.g., their customer lists or other information they provide to us about their customers) that consists of clear email addresses only for the purpose of assisting that particular Advertiser with their own advertising efforts and, in some cases, so we can report performance data back to the Advertiser’s CRM / reporting system. We do not share clear email addresses with other third parties for their advertising purposes
Hashed email addresses: If an Advertiser permits us, we collect hashed versions of the emails that consumers have entered on that Advertiser’s site. Hashing is a “one-way function” that effectively pseudonymizes email addresses. For instance, when email@example.com is run through a typical hashing function, it becomes the following string of digits: 0F0B7B1A1A7E8BDBBC6AA545F8CCD6F83671B32479271BFCB6CC8498912058D5. We take this step to de-identify data and protect email addresses, while being able to use an identifier to better connect devices and browsers. We then employ these hashed emails (along with other information) for cross-device targeting, in order to try to recognize users across devices and browsers – for instance, to find the same user across multiple devices such as computers, tablets, and mobile devices. We describe how this helps us better provide our services in “How We Use the Data We Collect” below.
Contact Information: We obtain and collect contact information from various third party sources, including from public sources and through licenses with data providers. We may also infer contact information based on email addresses and email naming conventions. This contact information is B2B information – in other words, it is usually the contact information of someone at a business email address, business street address, or sometimes, a business telephone number. We will not collect contact information this way for individuals who are located in European Territories.
Shopping Information: Some Advertisers provide us with information about their customers’ shopping habits, including transactional information, product codes, and check-out activity (along with browsing information that we collect). This information may come from their websites or other transactional information they (or their service providers) maintain. We generally use this information to help us better target, personalize, and measure the effectiveness of advertising campaigns.
Information We Receive in Our Corporate Capacity: We also collect information from our own customers and those who visit our website(s). To learn more about how we collect and use that information, please see our Website Data Privacy page.
3. How We Use the Data We Collect
We use this data to help our Advertisers identify and serve ads to you that are more relevant to you. We also use this data to operate, improve and enhance our services including enhancing the data points we or our Advertising Partners have about a particular user, browser, or device to serve the most relevant ads to you and, in turn, improve performance of an Advertiser’s ad campaigns. Specifically, we use this data for:
Targeting: Selecting ads that are more likely to be relevant to you based on the interests previously associated with your device and the time of day you may be most interested in viewing these specific ads. For example, we may show you ads for your favorite shopping site (or similar sites we think you may like) during lunch or commute hours.
Frequency capping: Making sure that you don’t see the same ad too many times.
Sequencing: If you are being served a sequence of ads, making sure we show you the right ad next in the sequence.
Cross-device matching: Identifying different devices that are likely to be associated with you so that ads can be targeted, capped and sequenced across those devices, and so that campaign effectiveness can be measured and analyzed. For example, cross-device matching helps us NOT show you ads for the shoes you were looking at on your phone but already purchased on your tablet. Instead we’ll try to show you ads for an upcoming triathlon where you can put those shoes to work. It also helps us match devices so we can honor your opt-out choices across all devices we know are connected to the opted-out cookie. You may opt-out of being targeted in the above “cross-device” and “cross-channel” ways by employing the respective opt-out techniques we describe in the “Your Choices and Opting-Out of Targeted Ads” section below.
Attribution: Monitoring when, where, and at what price we served certain ads on behalf of an Advertiser so that we can measure our influence on the marketing results of the Advertiser’s campaigns and overall marketing strategy. For example, being able to measure if a certain ad campaign (the ads shown and to whom they were shown) actually sold more soccer balls for ACME Soccer Ball Co.
Reporting: Providing Advertisers insights into how their ads are performing and gain insights into their customers. Reporting may include ad metrics such as impressions, clicks, and conversions (however the Advertiser may define a “conversion” such as, for example, a sale or a white paper download, or a correlation to an actual or inferred sale, site visit or store visit). This data allows an Advertiser to determine if an ad is not performing well (customers are not clicking on it), so that the Advertiser will be able to see that data and update the ad (perhaps with a better deal!). With respect to specific cookie data, we limit reporting to cookie activity on the specific Advertiser’s website and which ads were shown, whether there was engagement with those ads.
Conducting Our Corporate Operations: As to information we collect in our corporate capacity – our own B2B lists of customers and prospective customers – we use that information to conduct our business operations and communications. Please see our Website Data Privacy page to learn more about how we use that information.
Social media identifiers: (such as single sign on through Facebook, Instagram or other social media accounts) and other information you share with us or make public via your social networking account. You may control what information you share by accessing the networking sites’ privacy settings. We may use this data to personalize your experience and develop better services.
Your device and location: We collect information about your device, mobile phone or tablet, including IP address, browser type, device type, unique device identifiers and operating system. We also collect location data, if you have location services enabled or by matching your IP address. We collect this information for targeting purposes as well as to better our products.
4. Data Sharing
We may disclose information about you:
With an Advertiser whose Digital Properties you have visited: We may share information about how you have interacted with that Advertiser’s Digital Properties, email campaigns or its Ads.
With our service providers: We contract with companies who help with parts of our business operations (e.g., for example, website and data hosting, fraud prevention, viewability reporting, data hygiene, marketing, and email delivery), as well as billing, collections, tech, customer and operational support.
In connection with legal proceedings: When we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of WITHINSITES, our Advertisers or any other third party.
To comply with legal process: To satisfy in good faith any applicable law, legal process, or proper governmental request, such as to respond to a subpoena (whether civil or criminal) or similar process.
To investigate wrongdoing and protect ourselves or third parties: To enforce our Terms of Service or other policies or investigate any potential violation of our Terms of Service and policies, any potential violation of the law, or to protect ourselves, our customers, or any third party from any potential harm (whether tangible or intangible).
In connection with a sale of our business: If a third party acquires some or all of our business or assets, we may disclose your information in connection with the sale (including during due diligence in preparation for the sale).
With our Advertising Partners: We also share hashed email addresses (or other pseudonymous identifiers associated with those hashes), technical data that we collect about your browsing habits and your device (such as data relating to our cookies, tracking pixels and similar technologies) with other companies in the digital advertising ecosystem. This enables them and us to better personalize ads to you.
Privacy-first web analytics
5. Cookies and Related Technologies
Tracking cookies enable us to identify your device when you move between different Digital Properties, so that we can serve targeted advertising to you.
- Specifically, the WITHINSITES cookie we serve through the WITHINSITES platform for this purpose is named “__WITHINSITES” and “__WITHINSITES_fpc”.
Additionally, we use non-tracking cookies (not unique) to store user decisions in terms of your ad consent and opt-out choices:
- We may drop a __WITHINSITES cookie with value opt-out if you opt-out as described below.
- We may drop a __consent cookie that stores the consent choices you have made regarding data processing and advertising by WITHINSITES.
A full list of WITHINSITES cookies is set out below:
6. Your Choices and Opting-Out of Targeted Ads
We recognize how important your online privacy is to you, so we offer the following options for controlling the targeted ads (sometimes called “interest-based ads”) you receive and how we use your data.
Opting-out of this type of advertising through the below methods will not prevent you from seeing ads, but those ads will likely be less relevant because they will not be tailored to your interests. The ads might, for instance, be randomly generated or based on the web page you are visiting.
Web browser: You can opt-out of receiving personalized ads (including retargeted ads) served by us or on our behalf by contacting us at firstname.lastname@example.org. If you use a Safari browser, please also see directions regarding our cookie-less technology opt-out, below.
Cross Device Opt-Out:
In some cases we may link multiple browsers or devices to you. If you opt-out on a browser or device and we have additional devices or browsers linked to you, we will extend your opt-out decision to any other linked browsers and devices. Since we only link users across browsers and devices in some conditions, there could be cases where you are still being tracked in a different browser or device we have not linked, and where we are treating you as a different user.
Mobile Device Opt-Out: To opt-out of receiving targeted ads that are based on your behavior across different mobile applications follow the below instructions, for iOS and Android devices: iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting; and For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: Open your Google Settings app > Select Ads > Enable “Opt out of interest-based advertising”.
Industry Opt-Out Tools and Self-Regulation:
WITHINSITES is a member of the Network Advertising Initiative (NAI) and adheres to the NAI Code of Conduct. You may use the NAI opt-out tool here, which will allow you to opt-out of seeing personalized ads from us and from other NAI approved member companies.
We also comply with the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA). You may opt-out of receiving personalized ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAA website here.
We also comply with the Canadian Self-regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance of Canada (DAAC). You may opt-out of receiving personalized ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAAC website here.
Finally, we also adhere to the European Interactive Advertising Digital Alliance (EDAA) guidelines for online advertising and you may opt-out via their “Your Online Choices” website here.
Note to Safari Users. When you opt-out on a browser, we, other advertising platforms, and other third parties, generally place a cookie on your browser instructing us not to use your other online behaviors to customize the ads you see. However, if you are using a Safari browser, opt-out cookies that are set for purposes of restricting this type of advertising may be deleted prior to their intended expiration date; we have no control over these browser controls or cookie deletions.
Do Not Track Disclosure: Some internet browsers allow users to send a “Do Not Track” signal to websites they visit. We do not respond to this signal at the present time.
Reminder to Users Residing in a European Territory: If you are located in a European Territory you will also have additional data protection rights. These are described under the “Information for European Territory Residents: Our Legal Basis and Your Rights” section below.
7. Data Retention
CRM Data: We are processors of CRM data that we hold on behalf of an Advertiser, such as email address lists. We retain this CRM Data until the Advertiser asks us to delete this data.
Mobile Identifiers and Cookie Identifiers: Cookie identifiers we collect expire (and are then deleted) 13 months from the last time your device accessed a Digital Property using our technology. If you visit another Digital Property that uses our technology inside that 13-month expiry period, then the expiry period will be reset and measured from that date instead. The expiration period for mobile identifiers is controlled by the end-user on their own device.
Personal Data Associated with Mobile and Cookie Identifiers Related to Browsing History: We delete personal data associated with mobile and cookie identifiers after 12 months. For example, data such as an Advertiser’s website you visited or ads that you may have clicked.
Personal Data Associated with Real Time Bids: Data logged for a particular submitted bid or a received real time bid request (including cookie identifiers, mobile identifiers, the advertisable bid on, and the advertisable won or displayed to the end-user) are deleted after 30 days.
Personal Data Associated with the Display of an Advertisable: Data logged for the display of an advertisable (including cookie identifiers, the advertisable won or displayed to the end user as well as data indicated whether an end user clicked on the particular advertisable displayed) are deleted after 12 months.
We apply technical, administrative and organizational security measures to protect the personal data we collect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against other unlawful forms of processing.
Access to our website is secure and we monitor our platforms for security vulnerabilities regularly. Please note that nothing on the internet is totally secure and we cannot guarantee that our security will not be breached. Remember to always protect your personal data to the best of your abilities. Any communication with WITHINSITES via email will be secure to the level of that email platform. Please do not send any sensitive information via unsecure channels to us.
Statement on Children: Note that our targeting efforts and our digital properties are not targeted at children and we do not intentionally collect data on minors. If you are a minor and using our website or other digital properties please do so with the permission of your parent or guardian.
9. International Transfers
We may transfer the information we collect about you to countries (including the United States of America) other than the country where we originally collected it for the purposes of storage and processing of data and operating our services. In general, these countries will be the countries in which we, our Advertisers, or our or their service providers operate.
Those countries may not have the same data protection laws as your country. However, when we transfer your information to other countries, we will protect that information as described in this Privacy Notice and take steps, where necessary, to ensure that international transfers comply with applicable laws.
For example, when we transfer your information from a European Territory to our parent company in the United States, we do so under the European Commission’s Standard Contractual Clauses. These Standard Contractual Clauses are incorporated in the WITHINSITES Data Protection Policy.
10. GDPR compliance and Information for European Territory Residents:
Our Legal Basis and Your Rights
Our Legal Basis: If you interact with our services from the European Territories, our legal basis for collecting and using the personal data described above will depend on the personal information concerned and the specific context in which we collect it. “European Territories” means the European Economic Area and Switzerland. For the purpose of this Privacy Notice, the term “European Territories” shall continue to include the United Kingdom, even after the United Kingdom leaves the European Economic Area following Brexit.
- We will normally collect personal data from you where the processing is in our legitimate business interests to do so. For example, to administer our platforms and services and fulfil our contractual obligations as a service provider.
- In some cases we may collect and process personal data based on consent.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, including if you would like to better understand how our legitimate interests to process your data are balanced against your data protection rights and freedoms, then please contact us using the contact details provided under the “Contact Us” heading below.
Your Enhanced Privacy Rights: In addition, if you are a resident of a European Territory, you have the following enhanced rights under EU data protection law:
- If you wish to access, correct, update or request deletion of your personal information, you can contact us using the contact details provided in the “Contact Us About Questions or Concerns” section below.
- You can object to the processing of your personal information, and/or ask us to restrict processing of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contact us about questions or concerns” heading below.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. Specifically, you can withdraw consent for us or our partners to drop cookies by emailing email@example.com or by refusing consent for WITHINSITES when you see a “consent banner” on a publisher or advertiser site which lists WITHINSITES as a vendor.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Territories are available here.) However, if you have any questions about our collection and use of your personal information, we encourage you to contact us first at firstname.lastname@example.org. If you are unable to obtain the information or resolution that you seek, you may also contact our Data Protection Officer at email@example.com.
Please note that we have no direct relationship with the individuals whose personal data we process on behalf of our clients and partners. Where we act as a processor for our clients and partners (for example, when we handle our clients’ CRM data solely to provide them services), you should direct any requests to access, correct, update, or delete your personal data to the respective client or partner. We will respond to any requests by a client or partner to provide assistance with such requests within 30 days.
11. Changes To This Privacy Notice
Changes to this Privacy Notice will be posted on this page. If we make a material change to our privacy practices, we will provide notice on the site or by other means as appropriate. If we are required by applicable data protection laws to obtain your consent to any material changes before they come into effect, then we will do so in accordance with law.
12. Contact Us About Questions or Concerns
If you have any questions about this Privacy Notice or our privacy practices, you can contact firstname.lastname@example.org.
If you are located in a European Territory and we are processing your data as a data controller, WITHINSITES is the data controller of your information. To contact WITHINSITES please email email@example.com.
If you wish to escalate your inquiry after contacting the support team, you are welcome to contact firstname.lastname@example.org. Locations in Toronto, Canada, and Phuket, Thailand.
If you have questions or concerns that have not been resolved to your satisfaction by customer service, you may contact WITHINSITES’s Chief Privacy Officer in writing at: mailto:email@example.com
WITHINSITES operates the https://www.withinsites.com/ website, which provides digital advertising services and information about our brand.
This page is used to inform website visitors regarding our policies with the collection, use, and disclosure of personal information if anyone decided to use our services on the WITHINSITES website.
Information Collection and Use
For a better experience while using our services, we may require you to provide us with certain personally identifiable information, including but not limited to your name, phone number, email address and postal address. The information that we collect will be used to contact or identify you or your place of business.
We want to inform you that whenever you visit our website, we collect information that your browser sends to us known as log data. This log data may include information such as your computer’s Internet Protocol (“IP”) address, browser version, pages of our website that you visit, the time and date of your visit, the time spent on those pages, and other statistics.
Cookies are files with small amount of data that is commonly used as an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your computer’s hard drive.
Our website uses these “cookies” to collect information and to improve our services. You have the option to either accept or refuse these cookies, and know when a cookie is being sent to your computer. If you choose to refuse our cookies, you may not be able to use some portions of our website.
We may employ third-party companies and individuals for the following reasons:
To facilitate our services;
To provide services on our behalf;
To perform website-related services; or
To assist us in analyzing how our website is used.
We want to inform users of our website that these third parties have access to your personal information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.
We value your trust in providing us your personal information, thus we are striving to use commercially acceptable means of protecting it. Remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.
Links to Other Sites
Our services are not targeted at anyone under the age of 13. We do not knowingly collect personal identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to take the necessary steps to remove this information from our data storage.
If you have any questions about this Privacy Notice or our privacy practices, you can contact firstname.lastname@example.org.