Effective as of June 15, 2018
We have prepared this Privacy Notice to explain how, why, and when we collect data from you to provide targeted advertising services for our clients, and your rights in respect of this data. If you have additional questions, you can contact firstname.lastname@example.org.
1. About Sparksight’s Services
Sparksight collects information to serve you more relevant marketing material, allow you to access gated content more efficiently, and to see what content you’re interested in on our site. These functions serve to provide you with a more streamlined and personalized experience.
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 app. 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 website, what items you placed into your online shopping cart, what products were purchased and how much was paid.
Device and browser information: This is technical information about the device or browser you use to access the Advertiser’s website. 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 unique identifier such as the Apple IDFA or Android Advertising ID.
Ad data: This is data about the online ads we have served (or attempted to serve) to you. It includes things like 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.
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, an 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, anonymous identifiers to our own to enable us to more accurately recognise a particular unique browser or device and the advertising interests associated with it.
Email from Advertisers: Some Advertisers choose to share actual email addresses from their customers with us, so that (with the help of Advertising Partners) we can help the Advertiser serve 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 clear emails supplied by Advertisers 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 email addresses with other third parties for their advertising purposes.
Hashed email addresses: If an Advertiser allows, we may collect hashed versions of the emails that are 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 code: 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 describe how this helps us better provide our services in “How we use the data we collect” below.
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 all devices that are likely to be associated with you so that ads can be targeted, capped and sequenced across those devices. For example, cross-device matching helps us NOT show you ads for the shoes you were looking at on your phone but that 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.
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 result 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,” for example, a sale or a white paper download). For example, if an ad is not performing well (customers aren’t clicking on it), 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.
Data is reported in the aggregate for the campaign and, at times, at the cookie level. For some customers, ad metrics are reported at the domain level at the contact level. For some customers, ad metrics such as impressions, clicks, conversions etc. are aggregated at the domain level (the domain representing the company/account the Advertiser wanted to target) as well as at the contact level (the individual to whom the ad is being targeted) represented with an email address that was initially provided by the Advertiser.
4. Our legal basis for processing personal data (European Territory Visitors only)
We provide the representations and information in this Section 4 in compliance with European privacy laws, in particular the European General Data Protection Regulation (GDPR). They are specific to persons located in EEA countries or Switzerland, so please don’t rely on the below, if you’re not in one of those countries.
If you are a visitor 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” mean 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.
However, we will normally collect personal data from you where the processing is in our legitimate business interests to, for example, 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. To the extent our clients and Advertising Partners need to collect and share, or allow us to facilitate collection and sharing of personal data to enable our services, it is the responsibility of these parties to provide necessary privacy notices and obtain required consent(s).
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.
Finally, please note that when an Advertiser sends us email addresses to be used for targeted advertising purposes, we process that data only on behalf of the relevant Advertiser as its processor. If you have any questions about the use of this data by an Advertiser for the purpose of serving targeted advertising to you, please contact the relevant Advertiser.
5. Data Sharing
We do not share the data we collect with third parties.
6. Cookies and related technologies
Pardot is our marketing automation tool that tracks visitor and prospect activities on your website and landing pages by setting cookies on their browsers. Cookies are set to remember preferences (like form field values) when a visitor returns to your site. Pardot also sets a cookie for logged-in users to maintain the session and remember table filters.
Pardot sets first-party cookies for tracking purposes, and sets third-party cookies for redundancy. Using first-party and third-party cookies together is standard in the marketing automation industry. Pardot cookies don’t store personally identifying information, only a unique identifier. Pardot sets first-party cookies on your tracker subdomains and Pardot domains. Pardot uses third-party cookies on https pages and when your account doesn’t have a tracker subdomain set up.
Pardot sets three kinds of cookies.
The visitor cookie is composed of a unique visitor ID and the unique identifier for your account. For example, the cookie name “visitor_id12345” stores the visitor value “1010101010”, and “12345” is the account identifier. This cookie is set for visitors by the Pardot tracking code.
If your account tracks opt-in preferences, the pi_opt_in cookie is set with a true or false value when the visitor opts in or out of tracking.
A session cookie named “pardot” is set when you’re logged in as a Pardot user. This cookie isn’t set on a visitor’s browser.
WE use AdRoll which entails the following;
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 AdRoll cookie we serve through the AdRoll platform for this purpose is named “__adroll”.
We may also drop cookies from our Advertising Partners for the purposes described above. The Advertising Partner cookies dropped will vary depending on who the Advertisers are.
Additionally, we use non-tracking cookies (not unique) to store user decisions in terms of your ad and opt-out choices
We may drop an __adroll cookie with value opt-out if you opt-out as described below and an AdRoll consent cookie to track your consent choices.
We may drop a __consent cookie that stores the choices you have made regarding data processing and advertising by AdRoll.
7. Your choices and opting-out
We recognize how important your online privacy is to you, so we offer the following options for controlling the targeted ads you receive and how we use your data:
You can opt out of receiving personalized ads served by us or on our behalf by clicking on the blue icon that typically appears in the corner of the ads we serve and following the instructions provided or by clicking here. Please note that this “opt out” function is browser-specific and relies on an “opt out cookie”: thus, if you delete your cookies or upgrade your browser after having opted out, you will need to opt out again.
In some cases we may link multiple browsers or devices to you. If you opt out of on a browser or device and we have more linked to you, we will extend your opt out decision to the other linked browsers and devices. Since we only link users across browsers on 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.
To opt out of all tracking and marketing emails please send the request to firstname.lastname@example.org
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.
8. Data retention
Personal data collected is held no longer than necessary for our business purposes but is anonymized. For example, we retain anonymized impression and click data to ensure we can meet auditing requirements related to services provided or to meet legal requirements.
We apply technical, administrative and organizational security measures to protect the data we collect against accidental or unlawful destruction and 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.
10. International transfers
We do not perform data transfers internationally.
11. Additional data protection rights for EEA residents
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 at email@example.com
12. 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.
13. 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
7718 Wood Hollow Dr.
Austin, Texas 78731