Current as of November 8, 2016
Current as of November 8, 2016
Trueffect systems and practices are built around these principles from the ground up, reflecting our commitment to practices that provide customers and consumers with the value and confidence necessary to build long-term relationships.
The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged Trueffect.
Trueffect complies with the U.S. – Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data. Trueffect has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Trueffect’s certification, please visit http://www.export.gov/safeharbor/.
Trueffect participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Trueffect is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List https://www.privacyshield.gov/list.
Trueffect is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Trueffect complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Trueffect is subject to the regulatory enforcement powers of the [U.S. Federal Trade Commission AND/OR the U.S. Department of Transportation]. In certain situations, Trueffect may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Trueffect is a member of the Network Advertising Initiative (NAI) and adheres to NAI Codes of Conduct as well as the Digital Advertising Alliance’s Self-Regulatory Principles.
Technologies such as: cookies, beacons, tags and scripts are used by Trueffect and our partners, affiliates, or analytics or service providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
We use Local Storage (LS) such as HTML5 to store content information and preferences. Various browsers may offer their own management tools for removing HTML5 LS.
Except for the specific business-to-business marketing activities indicated under Privacy and This Website, we do not gather or manage personally-identifiable information, collect or process inbound leads or store other personally-identifiable information. Children’s data, financial account numbers, Social Security numbers and data related to visitor health-related conditions or medical records are all inappropriate for ad targeting and not used by Trueffect. We rigorously educate our customers on these principles and require their compliance as well.
Trueffect implements reasonable security measures to protect both personal and non-personal information from loss, misuse and unauthorized access, disclosure, alteration or destruction. Our employees are made aware of and are accountable for compliance with these procedures.
Trueffect performs long-term trending and analysis for our customers, and may retain ad transaction data for this purpose, including non-PII identifiers (such as a browser ID) and IP address information, for up to eighteen months. This archival data is not used for online behavioral advertising or ad targeting, and is programmatically deleted within 31 days of concluding its eighteen-month lifespan.
This website (Trueffect.com) serves primarily as our interface with our market and customers, and we use it to showcase best practices in privacy and data security:
Unlike our advertising platform, site visitors may voluntarily provide personal information in certain areas on this website as well as at industry events, trade shows or other forums. The personal information we collect is used only for the purpose for which it is requested:
As with most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We use this information to analyze trends, track user’s movements around websites/mobile devices to which we provide advertisements and to gather demographic information about users who interact with our services as a whole. This information does not allow us to determine specific identities.
We may employ the use of Device Identifiers to better manage advertising on websites/mobile devices by informing us (without using cookies) of the content with which users interact. Statistical Identifiers collect information about user devices, for example, your device’s IP address, cookie string data, 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. Many devices have unique or near unique device profiles, so collecting this information enables us to determine to a reasonable level of statistical accuracy the level of user’s engagement with advertisements and to recognize the user devices that interact with content. We do not tie the information gathered through the use of Statistical Identifiers to user’s personal information.
Sometimes we may use or make available to clients the non-PII we collect or receive (such as IP Address) to recognize users or try to resolve a commonality of users (or households) across platforms or across devices, such as smartphones, computers, tablets or related browsers. For instance, we might infer that a common IP address seen across different devices represents a common user (or a related or similar user), and use that inference in tailoring ads.
Trueffect can recognize a consumer’s location while they are in use of the device and this location information can be utilized by Trueffect to deliver advertisements. As with all data Trueffect collects, this is non-personally identifiable information (Non PII) and is limited to non-precise as defined by the Network Advertising Initiative’s (NAI) current definition of imprecise location data.
We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
We may also disclose your personal information as required by law such as to comply with a subpoena, or similar legal process and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. If Trueffect is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. To any other third party with your prior consent to do so.
Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
We post customer testimonials on our web site, which may contain personally identifiable information. We do obtain the customer’s consent via email prior to posting the testimonial to post their name along with their testimonial. To request removal of your personal information from Testimonials please contact us at firstname.lastname@example.org.
If you choose to use our referral service to email an article to a friend, we will ask you for your friend’s email address. We will automatically send your friend a one-time email inviting him or her to visit the site. Trueffect stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. Your friend may contact us at http://www.trueffect.com/ to request that we remove this information from our database.
Some of our advertising customers choose to host advertising on ad.adlegend.com, which Trueffect owns and maintains for this purpose. They follow the same privacy rules and practices as any other TruEffect customer. Please visit http://ad.adlegend.com/TE_optout.html for more information or to opt out of all data collection and targeting across the entire AdLegend.com domain.
The security of your personal information is important to us. When you enter sensitive information (such as a login credentials), we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at email@example.com.
Links to Other Web Sites
Our Site includes links to other Web sites whose privacy practices may differ from those of Trueffect. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.
The majority of our customers deploy our technology within their own domain, allowing them serve ads within the terms and conditions of their existing privacy policies and practices. Unlike other technologies, TruEffect’s patented first-party ad serving allows them to do this without revealing either personal or non-personal data to any third party.
Our customers use their own cookies for this purpose, and must adhere to Trueffect privacy policies and industry best practices. Because of the inherent privacy and security of first-party ad serving, it can only be managed by the advertiser with whom you have a relationship. All of our first-party ad serving clients maintain their own privacy policies and govern the necessary opt-out mechanisms for their own secure, closed advertising networks.
If all or part of the company is sold, merged or otherwise transferred to another entity, previously volunteered customer and prospect information may be transferred as well, along with the conditions and requirements under which it was originally collected and managed.
For more information about Trueffect’s commitment to consumer privacy, please contact Privacy@Trueffect.com or:
10170 Church Ranch Way
Westminster, Colorado 80021
Toll Free: 877.878.2383
Information Related to Data Collected through the Trueffect Platform
Trueffect collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
We collect information for our clients, if you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the client that you interact with directly.
Service Provider, Sub-Processors/Onward Transfer
Trueffect may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.
Access to Data Controlled by our Clients
Trueffect acknowledges that you have the right to access your personal information. If Trueffect has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Trueffect’s Client (the data controller). If the Client requests Trueffect to remove the data, we will respond to their request within 30 business days.
Trueffect will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Trueffect will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.