Privacy Policy

 

Revision Date: 01.05.2013

In Think Digital we take your privacy very seriously. Think Digital as a signatory Member of the IAB Europe EU framework for Online Behavioral Advertising (OBA), complies and adheres to its Principles in relation to the advertisements it serves and are based on User’s Online Behavior. We have prepared this Privacy Policy to explain when, how and who collects, uses, protects, and shares information about you when you visit a website that hosts  advertisements (Ads) that have been served from or use the Think Digital Network advertising technologies and services (the “TD Network”) and/or when you click on those Ads. This Privacy Policy also explains your choices for managing your information preferences. This Privacy Policy applies to all:

  • Internet users who are served advertisements from the TD Network ("End Users");
  • Website publishers that participate in TD Network ("Publishers"); and
  • Advertisers that use TD Network ("Advertisers");

 

This Privacy Policy deals with the information specific to the TD Network, the text and display advertising that appear on participating websites in the TD Network as well as on Third Party and certain third-party applications and covers those activities on behalf of the End User within the TD Network that could also be defined as OBA. This Privacy Policy does not include:

  • Activities of Web Site Operators (including Publishers & Advertisers) that are limited to their own sites and/or sites controlled by them.
  • Contextual Advertising

 
We have tried to keep it as simple as possible, but if you’re not familiar with terms like cookies, IP addresses, OBA, etc., then read about these key terms first.

INFORMATION WE COLLECT THROUGH TD NETWORK
 

Personally Identifiable Information (PII):
Ads may not directly capture any personally-identifiable user information unless the end user provides by virtue of his explicit consent this information through an Ad. Personal information includes, but is not limited to, e-mail addresses, telephone numbers, and credit card numbers. NO sensitive information can be collected through TD Network ads unless the end user provides by virtue of his explicit consent this information through an Ad. Our partners, advertisers and publishers may not associate cookies or other tracking mechanisms with PII for any purpose or with precise user location for behavior targeting unless the user has knowingly and expressly opted in. You can always access to correct, or change your Personally Identifiable Information, or opt out of our direct marketing efforts, by changing the relevant settings in your profile or account (if available) or by contacting the relevant Website Operator.

Non-Personally Identifiable Information- Behavioral Information:
We may collect anonymous usage data that does not identify, or precisely locate an End User ("Non-Personally Identifiable Information") when the end user is visiting participating Publishers and Advertisers in the TD Network or/and on their website in order to deliver OBA advertisements to End Users. We may collect information with regard to websites visited, content viewed, ad interaction, interaction with Advertiser or/and Publisher web sites, search terms used and other click and browsing behavioral data. When text and display ads are served on certain advertising services, partner sites, applications, those ads may be served based on a variety of non identifiable information related to the End User and his/her online behavior, including but not limited to: the content, domain and language of the page where the ad is displayed; the End User’s recent search queries, the language technical systems believe he/she prefers when performing a search, including but not limited to, cookie and device information, IP address, browser type, operating system and the date and time of his/her request. When the End User is accessing the web through a web browser, to serve ads that are relevant and tailored to his/her interests, our partners may use information about his/her activity on partner sites or services that rely on the use of cookie. Some of these sites and services also may use Non-Personally Identifiable Information, such as demographic data, to provide relevant advertising. Our partners and advertising services may display ads from both Think Digital advertisers and other third-party ad serving companies, including and not limited to other ad networks.

HOW WE TRACK USER BEHAVIOUR

When the End User is accessing the web through a web browser, our partners or a third party using our advertising services may serve an ad to the End User and may place a cookie in his/her browser. Our partners or a third party using our advertising services use cookies or other technologies to record information about what ads the End User’s browser has shown, as well as what ads he/she clicks on and other actions he/she takes on our sites, services and partners. Cookies help us analyze consumer behavior and allow serving more relevant and useful ads to the End User.

To serve ads in applications where cookie technology is not available, to serve ads that are relevant and tailored to the End User’s interests, our partners or a third party using our advertising services may use or allow other third parties to use information about his/her online behavior and activity in applications that use i.e. an anonymous identifier. Some of these applications or other clients also may use Non-Personally Identifiable Information, such as demographic data, to provide relevant advertising. Applications and other clients may display ads from both Think Digital advertisers and other third-party ad serving companies, including and not limited to other ad networks.

 

USE OF COOKIES

The following describes how cookies work to support our advertising services and conversion tracking. 

Applications and other clients may display ads from both Think Digital advertisers and other third-party ad serving companies, including other ad networks by using a cookie, to help advertisers and publishers serve and manage ads across the web. When the End User visits a website and views or clicks on an ad served through these sites, partners, applications, services, networks may place a cookie on his/her browser.
The advertising cookie information is provided to advertisers and publishers who use Think Digital advertising services. In addition, Think Digital is relying on its participating advertiser and publisher partners that may use advertising cookie to collect information about the End User’s visit to the website and exposure to a particular advertisement. Think Digital is relying on its participating advertisers and publishers, not to combine advertising cookie information with his/her Personally Identifiable (PII) Information without his/her opt-in consent.

 

COOKIE OPT-OUT PROCEDURE

You are always free to decline cookies, but by doing so you may not be able to use certain features on the websites or take full advantage of all website offerings and targeted advertising.
You can configure your web browser to accept all cookies, reject all cookies, erase cookies, or notify you when a cookie is set. For more information about how to configure your browser to manage cookies click HERE.  If you are an End User and you want the Ads served to you through TD Network to be free of cookies, click HERE to disable your cookie. Alternatively, you are always free to opt out of the Cookies that potential participating advertisers, publishers or Think Digital might use as third party by following one of the links listed further down in this chapter.

For your help and guidance to your rights and options as far as the collection of your online behavioral information is concerned, an “icon” placed in or around OBA Ads served through TD Network will provide you access to user friendly information regarding the data collection, use practices associated with that advert and an easy-to-use consumer control tool related to OBA.    

If you decide to opt-out, advertisements may still be delivered to your web browser on behalf of Advertisers, Publishers participating in  TD Network but those advertisements may not be as relevant to you because the advertisement request will only use information that is automatically transmitted through an Internet communication and not the information collected by using a Cookie.

The opt-out functionality is cookie-based. In order for the opt-out to work on your computer, your web browser must be set to accept third-party cookies. If you buy a new computer, change web browsers, or delete this cookie, you will need to perform the opt-out task again in case you still do not wish advertising cookies to be served to you.

Third-party ad networks may also participate in TD Network and may also utilize cookies to deliver advertisements and monitor the performance of such advertisements. Many third-party ad networks have agreed to provide an "opt out" mechanism for their ad cookies. The collection of information through cookies by such third parties will be governed by their own privacy policies and practices, over which Think Digital has no control.

For more information about the use of the cookie, best practices in advertising services managing cookie preferences and opting out, as well as a guide to online behavioral advertising and online privacy please visit www.youronlinechoices.eu.

HOW WE USE INFORMATION WE COLLECT THROUGH THE TD NETWORK
 

Personally Identifiable Information: We use Personally Identifiable Information for internal purposes only, such as to notify you of new products or services after you expressly opted in to receive such information and to send service notifications. We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
 

Non-Personally Identifiable Information: We use Non-Personally Identifiable Information to customize the advertising and content you see, to fulfill your requests for products and services, to improve the TD Network, to conduct research, to solicit your feedback and input about the TD Network and to provide more relevant and effective products, services, and advertisements on or through the TD Network. We may use, and disclose to third parties, certain Non-Personally Identifiable Information regarding the TD Network (e.g., number of visits, page views, and the like) without your permission. However, such information does not identify you individually. For example, we use data collected via the TD Network to create anonymous consumer segments. These segments will be used to target and optimize Publisher and Advertiser campaigns. Non-Personally Identifiable Information may be combined with data collected from other sources so that we may further improve the relevance and effectiveness of products, services, and advertisements offered on or through the TD Network. This combination will never result in the End User becoming identifiable.
 

Compliance with Laws and Law Enforcement: We may disclose Personally Identifiable Information and Non-Personally Identifiable Information to government or law enforcement if it is necessary in order to respond to legal requests (including court orders and subpoenas).

DATA RETENTION

End Users can delete Cookies at any time, as explained in this Privacy Policy. We keep data collected via the TD Network, including user behavior data, that we control for no longer than one year and only for the purpose of providing our services. Publisher's and Advertiser’s Privacy Policy Applies To End Users. End Users should read each Publisher's or/and Advertiser’s privacy policy to learn how the Publisher or/and Advertiser collects, uses, and protects information that they may collect or that may be collected in connection with the Publisher's or/and Advertiser’s website. While we encourage Publishers or/and Advertisers to adopt information privacy practices consistent with ours, we are not responsible or liable for any Publisher's information privacy practices.

ADVERTISERS – THIRD PARTY WEBSITES

Advertisers that participate in TD Network use Think Digital to display advertisements on participating Publisher websites. As per above, these companies (participating publishers & advertisers) may use their own ad serving technologies to display and track advertisements. Be aware that some Advertisers or/and Publishers might use information received from TD Network for their own behavioral advertising. We are not responsible or liable for such Advertisers' and or Publishers’ information privacy practices. We encourage you to read Advertisers' and or Publishers’ privacy policies and contact them directly if you have questions about their information privacy practices.
The TD Network may contain links to web sites or content operated and maintained by third parties, over which we have no control. You access such third-party websites or content at your own risk. You should always read the privacy policy of a third-party website before disclosing any information to the website.
Occasionally, at our discretion, we may include or offer third party products or services on/through our website. These third parties have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked parties, content or services. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these third party products or services.

SECURITY

We recognize the importance of safeguarding the confidentiality of your information. Accordingly, we employ standard security measures (such as firewalls and encryption of cookies) designed to protect your information from unauthorized access. All supplied sensitive personal information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the TD Network, we cannot and do not guarantee the security of any information you transmit on or through the TD Network, and you do so at your own risk.

CHILDREN’S PRIVACY STATEMENT

We DO NOT knowingly collect information from children under the age of 12. If we become aware that we have inadvertently received information from a child under the age of 12, we will delete such information from our records. Because we do not knowingly collect any information from children under the age of 12, we also do not knowingly distribute such information to third parties.

PRIVACY POLICY EFFECT AND CHANGES

This online privacy policy applies only to information collected through TD Network and not to information collected offline.
From time to time, we may change this Privacy Policy. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on our website. Those changes will go into effect on the Revision Date shown at the top of the revised Privacy Policy. Your continued use of the TD Network constitutes your consent to the revised Privacy Policy.

TERMS AND CONDITIONS

Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our website.

CONTACT

If you have any questions about this policy or you may wish to file a complaint in relation to your Online Behavior Data or any of your data, please feel free to contact us online. We will contact you back the soonest possible, so as to try to resolve any such issue that may arise.

 

DEFINITIONS

Advertisers: Advertisers are those who use the TD Network in order to publish and promote advertising campaigns and advertisements.

Anonymous identifier: An anonymous identifier is a random string of characters that is used for the same purposes as a cookie on platforms, including certain mobile devices, where cookie technology is not available.

Contextual Advertising: Is advertising based on the content of the web page being visited, a consumer’s current visit to a web page, or a search query. Such advertising does not rely on the use of “segments”.

Cookie:

A cookie is a small file of letters and numbers downloaded on to your computer when you access certain websites. Cookies allow a website to recognize a user’s computer. A cookie itself does not contain or collect information. Cookies are used in behavioural advertising to identify users who share a particular interest so that they can be served more relevant adverts.

End Users: End Users are internet users who are served advertisements from the TD Network
Icon: An icon is a visible web based object that contains a hyperlink to the OBA User Choice Site.
Information: For the purposes of this document information is the personally identifiable information, the sensitive personal information and the non-personally identifiable information. 

IP address: Every computer connected to the Internet is assigned a unique number known as an Internet protocol (IP) address. Since these numbers are usually assigned in country-based blocks, an IP address can often be used to identify the country from which a computer is connecting to the Internet.

Non-Personally Identifiable Information: This is information that is recorded about users so that it no longer reflects or references an individually identifiable user.
Online Behavioral Advertising: Online Behavioral Advertising means the collection of data from a particular computer or device regarding web viewing behaviors over time and across multiple web domains for the purpose of using such data to predict web user preferences or interests to deliver online advertising to that particular computer or device based on the preferences or interests inferred from such web viewing behavior. Online Behavioral Advertising does not include the activities of Web Site Operators, Ad Delivery or Ad Reporting or contextual advertising.
Personally Identifiable Information (PII): This is information that, either by itself or in conjunction with other information, can uniquely identify an individual. Examples of personally identifiable information include a name, street address, email address or telephone number. PII is defined in EU directive 95/46/EC.
Publishers: Publishers own and legally use websites which can host advertising campaigns and advertisements.

Sensitive personal information: Any personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the processing of data concerning health or sex life.

Think Digital Network: The Think Digital network includes all media, websites, advertising technologies and services that Think Digital uses to host and publish advertisements.

Third Party: An entity is a Third Party to the extent that it engages in Online Behavioral Advertising on a website or websites other than a website or websites it or an entity under Common Control, owns or operates.

Third-party applications (Applications): Third party applications are programs written to work within operating systems, but are written by individuals or companies other than the provider of the operating system. Third party applications can be standalone programs or they can be small plugins that add functionality to an existing parent program.

Website Operator: A Website Operator is the owner, controller or operator of a website with which the web user interacts.